Privacy Policy

Effective Date: June 12, 2026

Your privacy is important to us. At MemmoCRE, LLC (“MemmoCRE,” “we,” “us,” or “our”), we follow a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information we collect through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We aim to make it simple for you to control the information in your account and on your website.
• We aim for transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

MemmoCRE provides website provisioning, hosting, content tools, and marketing features for commercial real estate professionals and brokerages. This Privacy Policy applies to information that we collect about you when you use:

• Our website at memmocre.com;
• The MemmoCRE dashboard and account features;
• Agent websites provisioned and hosted through the MemmoCRE platform, to the extent we collect information as the operator of the platform; and
• Our other products, services, and features available on or through the platform (collectively, the “Services”).

An important distinction: this Policy describes how MemmoCRE handles information about our customers and prospective customers (the agents and brokerages who subscribe to the Services) and visitors to memmocre.com. If you are a visitor to an agent’s website hosted on our platform — for example, you submitted a contact form to inquire about a property — the agent or brokerage that operates that website controls your information, and their privacy practices apply. We process that information on their behalf, as described in the section below on Visitors to Our Users’ Websites.

Creative Commons Sharealike License

This Privacy Policy is adapted from the Automattic Privacy Policy, which is made available under a Creative Commons Sharealike license. We’ve revised it to reflect MemmoCRE’s actual practices, and this adapted version is available under the same license.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect information from three sources: if and when you provide it to us, automatically through operating our Services, and from outside sources.

Information You Provide to Us

• Basic account information: We ask for basic information to set up your account, such as your name, email address, and password. To provision your agent website, we may also collect professional information such as your brokerage name, real estate license number and state, phone number, business address, professional bio, headshot, and market specializations — much of which you intend to publish on your website.
• Payment information: If you subscribe to a paid plan, payment is processed by our third-party payment processor, Stripe. Stripe collects your payment card details directly; MemmoCRE does not store full payment card numbers. We keep records of your subscription tier, billing history, and transaction status.
• Content information: You may provide information about yourself in the content you create on the platform — property listings, market pages, articles, photos, and other materials you publish to your website, as well as contact and company records you store in your dashboard.
• Custom domain information: If you connect a custom domain, we collect the domain name and related DNS configuration details.
• Communications with us: When you contact us for support, respond to surveys, or otherwise communicate with us via form, email, or phone, we keep a copy of those communications.

Information We Collect Automatically

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as browser type, IP address, unique device identifiers, language preference, referring site, date and time of access, and operating system.
• Transactional information: When you purchase a subscription, we collect information about the transaction, such as the plan purchased, price, and date.
• Usage information: We collect information about your usage of the Services — for example, which dashboard features you use, pages you create, and actions you take — so we can provide the Services, troubleshoot problems, and improve the product.
• Location information: We may determine the approximate location of your device from your IP address — for example, to understand which regions our users come from.
• Information from cookies and similar technologies: A cookie is a small string of information that a website stores on a visitor’s computer and that the visitor’s browser provides each time the visitor returns. We use cookies and similar technologies to keep you logged in, remember your preferences, understand how the Services are used, and measure the effectiveness of our marketing. You can usually set your browser to remove or reject cookies, with the drawback that some features (like staying logged in) may not work properly.

Information We Collect from Other Sources

We may receive information about you from other sources — for example, publicly available professional information (such as your brokerage affiliation or listing activity from public listing platforms and licensing records) that we use to provision or improve your website content with your direction, or to communicate with you about our Services. If you log in through a third-party service, we receive associated login information (such as a connection token and your email address). Third-party services may also provide us contact information for real estate professionals who are not yet our users, which we may use to tell them about our Services.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, provision and host your website, store your content and contact records, provide customer support, and process subscription payments.
• To power AI-assisted features. Certain features use third-party AI services to generate or assist with content, such as drafting page copy or summarizing contact activity. When you use these features, relevant content and context are transmitted to our AI service provider for processing in order to return results to you.
• To ensure quality, maintain safety, and improve our Services. For example, by monitoring and analyzing how users interact with the Services so we can fix problems and build better features.
• To market our Services and measure the effectiveness of our marketing. For example, by sending information about new features or offers, and analyzing the results of our campaigns. You can opt out of marketing communications at any time.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; complying with our legal obligations; and protecting the rights and property of MemmoCRE and others.
• To fix problems with our Services. For example, by monitoring, debugging, and preventing issues.
• To communicate with you. For example, by emailing you about your account, responding to support requests, or sharing tips for getting the most out of the platform. If you opt out of promotional messages, we’ll still send important updates relating to your account.

Legal Bases for Collecting and Using Information

For individuals in regions covered by the EU or UK General Data Protection Regulation, our use of your information is based on the grounds that: (1) the use is necessary to fulfill our commitments to you under our Terms of Service or to administer your account; (2) the use is necessary for compliance with a legal obligation; (3) the use is necessary to protect your vital interests or those of another person; (4) we have a legitimate interest in using your information — for example, to provide, improve, and safeguard our Services, communicate with you, and measure our marketing; or (5) you have given us your consent.

Sharing Information

How We Share Information

We share information about you in limited circumstances, with appropriate safeguards on your privacy:

• Third-party vendors: We share information with vendors who need it to provide their services to us or to you. This includes our payment processor (Stripe), our database and infrastructure providers (such as Supabase), our website hosting and content delivery providers (such as Cloudflare and Vercel), our AI service provider (such as Anthropic, for AI-assisted features), and email delivery services that help us communicate with you. We require vendors to commit to appropriate privacy and security protections as a condition of receiving information.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of MemmoCRE, third parties, or the public at large — for example, in connection with fraud prevention or an imminent threat of harm.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that MemmoCRE goes out of business or enters bankruptcy, user information would likely be among the assets transferred. This Privacy Policy would continue to apply to your information, and the receiving party may use it only consistent with this Policy.
• With your consent: We may share information with your consent or at your direction.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified so that it can no longer reasonably be used to identify you — for example, aggregate statistics about platform usage.

We do not sell your personal information for money, and we do not operate a third-party advertising program on your website or ours.

Information Shared Publicly

Information that you choose to publish to your agent website — your name, bio, headshot, contact details, listings, and other content — is, by design, public. It is visible to anyone who visits your website and may be indexed by search engines. Please keep this in mind when deciding what to publish.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it, and we’re not legally required to keep it. For example, web server logs are retained for a limited period to analyze traffic and investigate issues. When you delete content from your website or dashboard, it may remain in backups for a limited period until those backups are purged. After your subscription ends, we retain your account information and content for a limited wind-down period (during which you can export your content, as described in our Terms of Service), after which it may be permanently deleted, except where retention is reasonably needed to comply with legal obligations or for our legitimate business interests (such as billing records).

Security

While no online service is 100% secure, we work hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, including encryption in transit, tenant isolation at the database level, and access controls. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: You can choose not to provide optional information, though certain features may not be available without it.
• Opt out of marketing communications: You may opt out of promotional emails by following the unsubscribe instructions in those messages or by contacting us. We may still send you non-promotional communications, like those about your account and legal notices.
• Set your browser to reject cookies: You can usually set your browser to remove or reject cookies, with the drawback that certain features of the Services may not function properly.
• Close your account: You can cancel your subscription and close your account at any time through your dashboard or by contacting us. We may continue to retain certain information after closure as described in How Long We Keep Information above.

Your Rights

Depending on where you are located — including certain US states and countries covered by the GDPR — you may have rights regarding your personal information.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by law, including the rights to: request access to your personal data; request correction or deletion of your personal data; object to our use and processing of your personal data; request that we limit our use and processing of your personal data; and request portability of your personal data. You also have the right to make a complaint to a government supervisory authority.

US State Privacy Laws

Laws in some US states require us to provide residents with additional information about the categories of personal information we collect and share, where we get it, and how and why we use it. Depending on the Services used, in the last 12 months we collected the following categories of personal information: identifiers (like your name, contact information, and device and online identifiers); commercial information (like your billing information and subscription history); internet or other electronic network activity information (like your usage of our Services); geolocation data (approximate location based on IP address); audio, electronic, visual, or similar information (like your headshot, if you uploaded one); professional or employment-related information (like your brokerage and license information); and inferences we make (like product usage patterns).

We collect personal information for the business and commercial purposes described in How and Why We Use Information, share it with the categories of third parties described in Sharing Information, and retain it as described in How Long We Keep Information.

In some US states, you have rights subject to exemptions provided by your state’s law, including the right to: request a copy of the specific pieces of information we collect about you; request deletion of personal information; request correction of personal information; opt out of the sale or sharing of personal information; receive a copy of your information in a portable format; and not receive discriminatory treatment for exercising your rights.

Right to opt out: We do not sell your personal information in the conventional sense (i.e., for money), and we do not share it for cross-context behavioral advertising. If our practices change, we will update this Policy and provide a means to opt out as required by law.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings, but you can also contact us as described in How to Reach Us below. When you contact us about one of these rights, we’ll need to verify that you are the right person before we disclose or delete anything — for example, by asking you to contact us from the email address associated with your account. You may designate an authorized agent to make a request on your behalf by giving us written authorization; we may still require you to verify your identity.

Appeals Process for Rights Request Denials

In some circumstances we may deny your request — for example, if we cannot verify that you are the account owner, or if we are legally required to retain a copy of your information. If we deny your request, we will communicate this to you in writing, and you may appeal by responding in writing and stating that you would like to appeal. Appeals will be reviewed by someone not involved in the original decision. If your appeal is denied, in some US states you may refer the denied appeal to your state attorney general; we will include information on how to do so in our written response.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned above, please contact us at support@memmocre.com or by mail at:

MemmoCRE, LLC (Mailing address to be posted)

Other Things You Should Know

Transferring Information

MemmoCRE is based in the United States, and our Services are provided from the United States using US-based and global infrastructure providers. If you use our Services from outside the United States, your information will be transferred to, stored, and processed in the United States and other locations where our service providers operate. Where required by applicable law, we take appropriate measures to ensure your personal information is protected, such as entering into standard contractual clauses with relevant providers.

Analytics Services Provided by Others

We may use third-party analytics services to help us understand how visitors use memmocre.com and the dashboard. These providers may set cookies or similar technologies to collect information about your use of our Services. This Privacy Policy covers the collection of information by MemmoCRE and does not cover the collection of information by third-party analytics providers, whose practices are governed by their own privacy policies.

Third-Party Software and Services

If you connect third-party software or services to your account or website — for example, payment, scheduling, or social media tools — interacting with them may mean providing information about yourself or your site visitors to those third parties. Your data will be handled in accordance with the third party’s privacy policy and practices, which you should review before connecting the service.

Visitors to Our Users’ Websites

We process information about visitors to agent websites hosted on our platform — such as contact form submissions, inquiry details, and site analytics — on behalf of, and at the direction of, the agent or brokerage that operates the website, in accordance with our agreements with them. The agent or brokerage, not MemmoCRE, controls that information, decides how it is used, and is responsible for responding to inquiries and privacy requests about it. We encourage our users to post a privacy policy on their websites that accurately describes their own data collection, use, and sharing practices. If you have a question or dispute about an agent’s website or how your inquiry was handled, please contact the agent directly using the contact information on their site.

Privacy Policy Changes

Although most changes are likely to be minor, MemmoCRE may change this Privacy Policy from time to time. We encourage you to check this page periodically. If we make material changes, we will provide notice — for example, by email or a notice in the dashboard. Your continued use of the Services after a change to this Privacy Policy will be subject to the updated policy.

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Attribution: This document was adapted from the Automattic Privacy Policy, available under a Creative Commons Sharealike 4.0 license.