REAL GRADER INC.
PRIVACY POLICY
(REALGRADER® AND INSTACARD® PRODUCTS AND SERVICES)
Last Updated: June 9, 2026
1. INTRODUCTION AND SCOPE
This privacy policy (this “Privacy Policy”) describes how Real Grader Inc., a Connecticut-based company, and its affiliates and related companies (“Real Grader,” “we,” “us” or “our”) collect, use, disclose and otherwise process personal data when you visit our websites located at realgrader.com, realgrader.ai and instacard.info (collectively, the “Websites”), or access or use the RealGrader® platform, the INSTACARD® product, or any other Real Grader mobile application, dashboard, product, service, feature, technology or content (collectively with the Websites, the “Services”). This Privacy Policy applies to the personal data of individuals located in the United States. “Personal data” (or “personal information”) means information that identifies, relates to, or could reasonably be linked with an identified or identifiable individual, and does not include de-identified or aggregated data.
Our role with respect to customer data. The Services are designed for use by real estate and other sales professionals. Where we process personal data on behalf of and at the direction of a business customer in connection with that customer’s use of the Services (for example, contact or lead information that a customer uploads or shares through the Services), we act as a “processor” or “service provider” with respect to such data, and the applicable customer is the “controller” or “business.” In those circumstances, the customer’s own privacy policy governs, and individuals should direct privacy requests to that customer; we will assist our customers in responding to such requests as required by applicable law and our agreements. This Privacy Policy addresses our processing of personal data for which we act as a controller.
2. PERSONAL DATA WE COLLECT
Information you provide to us. We collect personal data that you provide directly to us, including: (a) the name, postal address, email address, telephone number, username, password, photograph and demographic and professional information (such as your occupation and brokerage affiliation) that you provide when you register for, or use, the Services (“Account Information”); (b) payment card and related billing information processed when you purchase Services, which is collected and processed by our third-party payment processor (“Payment Information”); and (c) the contents of communications you send to us, including support requests.
Information collected automatically. When you visit the Websites or use the Services, we and our service providers automatically collect certain information about your device and usage, including your operating system type, browser type and language, pages viewed, time spent on pages, access times, referring URLs, actions taken within the Services, IP address and, for mobile devices, device identifiers, model, manufacturer and operating system version (“Usage Information”). We collect Usage Information through cookies, pixels, software development kits and similar technologies, as described in Section 4 (Cookies and Tracking Technologies).
Information from other sources. You may choose to connect the Services to your accounts on third-party platforms such as Google, Facebook, LinkedIn, Realtor.com, Zillow and Homes.com (“Social Networking Services”). When you do so, we collect and process certain personal data from those Social Networking Services, such as your account and profile data (“Social Media Information”), for the purpose of integrating your social media presence within the Services and enabling the sharing features you direct. We may also receive information about you from analytics providers, advertising partners and publicly available sources.
The following table summarizes the categories of personal data we have collected in the preceding twelve (12) months, representative data elements, the purposes of collection, and the categories of recipients to which such data is disclosed for a business purpose:
| Category of Personal Data | Representative Data Elements | Purposes of Collection and Use | Categories of Recipients |
| Identifiers | Name, postal address, email address, telephone number, username, unique account identifiers, IP address | Account creation and administration; providing the Services; communications; security and fraud prevention | Service providers (hosting, email delivery, customer support); Social Networking Services at your direction |
| Customer records / professional information | Occupation, brokerage or company affiliation, professional licenses, business contact information | Providing and personalizing the Services; customer support; marketing | Service providers; Social Networking Services at your direction |
| Commercial and payment information | Products or Services purchased, billing records, payment card information (collected and processed by our payment processor) | Order processing; billing and collections; accounting and tax compliance | Payment processors; professional advisers |
| Internet or other electronic network activity | Browser type and language, operating system, device identifiers, pages viewed, time on page, access times, clickstream data, cookie and pixel data | Analytics; Service improvement; security; advertising and measurement | Analytics providers; advertising partners |
| Social media information | Account and profile data from Social Networking Services you elect to connect (e.g., Google, Facebook, LinkedIn, Realtor.com, Zillow, Homes.com) | Integrating and displaying your social media presence; enabling sharing features you direct | Social Networking Services and recipients you designate |
| Audio/visual information | Profile photographs and images you upload | Providing the Services (e.g., digital business cards and profiles) | Recipients you designate |
| Inferences | Profile metrics, scores and analytics derived from your digital presence | Providing grading, reporting and benchmarking features of the Services | None, other than to you and recipients you designate |
Sensitive data. We do not seek to collect, and ask that you not provide, “sensitive data” as defined under applicable state privacy laws (including, under the Connecticut Data Privacy Act as amended effective July 1, 2026, data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, disability or treatment, sex life, sexual orientation, status as nonbinary or transgender, citizenship or immigration status, genetic or biometric data, neural data, precise geolocation, certain financial account information, government-issued identification numbers, and personal data of a known child). To the extent the Services process any data element constituting sensitive data (e.g., government-issued identifiers or financial account numbers), we obtain consent prior to such processing and do not sell sensitive data.
3. HOW WE USE PERSONAL DATA
We use personal data for the following purposes: to provide, operate, maintain and personalize the Services; to create and administer your account; to process payments and transactions; to respond to your comments, questions and support requests; to send transactional communications, including confirmations, invoices, technical notices, updates, security alerts and administrative messages; to send marketing communications about our products, services, promotions and events, subject to your right to opt out; to monitor and analyze usage, trends and performance of the Services; to improve and develop the Services; to detect, investigate, deter and protect against fraudulent, unauthorized, illegal or malicious activity; to comply with legal obligations and enforce our agreements; and for other purposes disclosed to you at the time of collection or with your consent.
Data minimization. We collect personal data only as reasonably necessary and proportionate to the purposes disclosed in this Privacy Policy, and we will not process personal data for a material new purpose that is neither reasonably necessary to, nor compatible with, the disclosed purposes without providing notice and obtaining any consent required by applicable law.
Artificial intelligence; large language models. We do not use personal data to train large language models.
De-identified and aggregated data. We may de-identify or aggregate personal data such that it can no longer reasonably be linked to you, and we may use and disclose such data for any lawful purpose, including analytics, benchmarking and Service improvement. Where we maintain de-identified data, we commit to maintaining it in de-identified form and not attempting to re-identify it, except as permitted by law to test our de-identification processes.
4. COOKIES AND TRACKING TECHNOLOGIES; OPT-OUT PREFERENCE SIGNALS
We and our service providers use cookies, web beacons (clear GIFs), pixels, tags, scripts and similar technologies to operate the Services, remember your preferences, authenticate users, measure the effectiveness of content, and perform analytics. Some of these technologies collect information over time and across different websites or online services. You can manage cookies through your browser settings; if you remove or reject cookies, certain features of the Services may not function properly.
Opt-out preference signals. We recognize and honor opt-out preference signals, such as the Global Privacy Control (GPC), as a valid request to opt out of the sale of personal data and the processing or sharing of personal data for targeted or cross-context behavioral advertising, as required by applicable state privacy laws. When our Websites detect such a signal from your browser or device, we will apply the applicable opt-out to that browser or device.
5. HOW WE DISCLOSE PERSONAL DATA
We disclose personal data in the following circumstances: (a) to service providers and processors that perform services on our behalf, including hosting, payment processing, data analytics, email delivery, customer support and marketing assistance, in each case subject to written contracts that restrict their use of personal data as required by applicable law; (b) to Social Networking Services and other recipients at your direction, when you connect your accounts or use the sharing features of the Services; (c) in connection with business transfers, including any merger, acquisition, financing, reorganization, bankruptcy or sale or transfer of all or part of our business or assets, in which case personal data may be disclosed or transferred as part of the transaction subject to applicable law; (d) for legal, protection and safety purposes, including to comply with law, respond to lawful requests and legal process, enforce our agreements and policies, and protect the rights, property and safety of Real Grader, our customers, our personnel and others; and (e) with your consent or at your direction.
Sale of personal data; targeted advertising. We do not sell personal data, and we do not process or share personal data for targeted or cross-context behavioral advertising.
6. YOUR U.S. STATE PRIVACY RIGHTS
Residents of certain states (including, as of the date of this Privacy Policy, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia) have rights with respect to their personal data under applicable state privacy laws, subject to certain conditions and exemptions. Depending on your state of residence, these rights may include the right to: (a) confirm whether we are processing your personal data and access such personal data; (b) correct inaccuracies in your personal data; (c) delete personal data provided by, or obtained about, you; (d) obtain a portable copy of personal data you provided to us; (e) opt out of (i) the sale of personal data, (ii) the processing of personal data for targeted advertising (or the “sharing” of personal data for cross-context behavioral advertising), and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you; (f) limit the use and disclosure of sensitive personal information (California) or withdraw consent to the processing of sensitive data; (g) obtain a list of the third parties to which we have disclosed or sold personal data (Oregon and Rhode Island residents; see Section 7); and (h) question the result of profiling and obtain certain explanatory information (Minnesota residents).
How to exercise your rights. You may exercise your rights by emailing us at hello@realgrader.com. You may also access, review, change and delete certain Account Information at any time through your account settings.
Verification; authorized agents. We will take reasonable steps to verify your identity before responding to a request, which may include matching information you provide against information we maintain. Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf; we may require proof of the agent’s authority and verification of your identity. We will respond to verifiable requests within forty-five (45) days, subject to extension as permitted by applicable law.
Appeals. If we decline to take action on your request, you may appeal our decision within a reasonable period by contacting us at hello@realgrader.com with the subject line “Privacy Request Appeal.” Within the period required by applicable law (generally forty-five (45) to sixty (60) days), we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons. If your appeal is denied, you may contact your state attorney general; Connecticut residents may contact the Connecticut Attorney General at portal.ct.gov/ag.
Nondiscrimination. We will not discriminate against you for exercising your privacy rights, including by denying goods or services, charging different prices, or providing a different level of quality, except as permitted by applicable law (for example, where the difference is reasonably related to the value of your data in connection with a bona fide loyalty or rewards program).
7. STATE-SPECIFIC DISCLOSURES
California. The table in Section 2 describes the categories of personal information we collect, the purposes of collection, and the categories of recipients, as required by the California Consumer Privacy Act, as amended (the “CCPA”). We have not sold or shared personal information in the preceding twelve (12) months, and we have no actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age. We retain each category of personal information for the periods described in Section 9. California residents may exercise the rights described in Section 6, including the right to limit the use of sensitive personal information. Do-Not-Track: because we honor opt-out preference signals such as the Global Privacy Control, our treatment of browser-based signals is as described in Section 4; we do not otherwise respond to legacy “Do Not Track” browser settings for which no standard has been adopted.
Connecticut. We comply with the Connecticut Data Privacy Act, as amended effective July 1, 2026 (the “CTDPA”), including its requirements regarding data minimization and proportionality, consent for the processing of sensitive data, the prohibition on selling sensitive data without consent, recognition of opt-out preference signals, heightened protections for minors, and the disclosures regarding large language models set forth in Section 3.
Texas. Real Grader does not currently sell sensitive or biometric personal data.
Oregon and Rhode Island. Oregon residents may request a list of the specific third parties to which we have disclosed personal data. For purposes of the Rhode Island Data Transparency and Privacy Protection Act, the third parties to which we have sold or may sell personal data are: None.
Nevada. Nevada residents may submit a verified request directing us not to sell certain covered information by emailing hello@realgrader.com with the subject line “Nevada Opt-Out.” We do not currently sell covered information as defined by Nevada law.
Maryland. For Maryland residents, we collect and process personal data only as reasonably necessary and proportionate to provide or maintain the specific products and services you request, and we do not sell sensitive data.
8. CHILDREN AND MINORS
The Services are intended for business use by adults. We do not knowingly collect personal data from children under thirteen (13) years of age, and you must be eighteen (18) years of age or older to establish an account or use the Services. We do not sell the personal data of, or process for targeted advertising the personal data of, any consumer we know or willfully disregard to be under eighteen (18) years of age, and we do not use system design features to significantly increase the use of the Services by minors. If you become aware that an individual under eighteen (18) has provided personal data to us, please contact us at hello@realgrader.com, and we will delete such information as required by applicable law.
9. DATA RETENTION
We retain personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal, tax, accounting and audit obligations, resolve disputes, enforce our agreements, and maintain security and backup integrity. As a general matter: Account Information and Social Media Information are retained for the duration of your account plus 12 months following closure; Payment Information is retained by our payment processor in accordance with its policies and as required for financial recordkeeping; and Usage Information is retained for 12 months. When personal data is no longer required, we delete or de-identify it; residual copies may persist on backup media for a limited period before deletion in the ordinary course.
10. SECURITY
We maintain reasonable administrative, technical and physical safeguards designed to protect personal data against unauthorized access, use, alteration, disclosure and destruction, both during transmission and upon receipt. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of personal data. If you have questions about security, you may contact us at hello@realgrader.com.
11. PROCESSING IN THE UNITED STATES
The Services are operated from, and personal data is processed and stored in, the United States. If you access the Services from outside the United States, you understand that your personal data will be transferred to, processed and stored in the United States, where privacy laws may differ from those of your jurisdiction.
12. THIRD-PARTY WEBSITES AND SERVICES
The Services may contain links to, or integrations with, websites, applications, platforms and services operated by third parties, including the Social Networking Services. This Privacy Policy does not apply to such third-party websites and services, and we are not responsible for their content, availability or privacy practices. We encourage you to review the privacy policies of any third-party websites and services you use.
13. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. If we make changes, we will revise the “Last Updated” date above and post the updated Privacy Policy on the Websites. If we make material changes, we will provide notice through the Services or by other means (such as email) prior to the changes taking effect and, where required by applicable law, obtain your consent before processing your personal data for a material new purpose. Your use of the Services following the effective date of an updated Privacy Policy will be subject to the updated Privacy Policy to the extent permitted by applicable law.
14. CONTACT US
If you have any questions or concerns about this Privacy Policy or our privacy practices, or wish to exercise your rights, please contact us at: Real Grader Inc., Attn: Privacy, SHU iHub West Building, 3135 Easton Turnpike, Fairfield, CT 06825; email: hello@realgrader.com.