SPLIT CRE — Privacy Policy

Effective date: [EFFECTIVE DATE]
Last updated: [LAST UPDATED DATE]

SPLIT CRE is an online community and technology platform for commercial real estate professionals. [ACTUAL LEGAL OPERATOR NAME AND ENTITY TYPE], doing business as SPLIT CRE (we, us, or our), operates splitcre.com and the community services covered by this policy (the Platform).

This policy explains our current practices. Future paid products, listing services, advertising, or other features may require updated disclosures before they launch. A feature mentioned as a future possibility is not a statement that we currently collect the associated information.

1. Information we collect

Applications and verification. We collect the name, email address, real estate license number, and market or city you submit, along with information you choose to include in communications with us. We check relevant public licensing records, initially through the Louisiana Real Estate Commission, and may record license status, type, expiration, verification date, and information needed to resolve a discrepancy. A license-record check is not a comprehensive identity or background check.

Accounts and profiles. We collect your call sign, avatar or profile image, account settings, and sign-in/session information. We also keep records of agreement to the Terms and relevant policy versions. Any optional professional information you choose to post may be visible to the audience of that feature.

Content and activity. We process posts, replies, images, likes, bookmarks, and related timestamps, along with reports, moderation records, account requests, and correspondence. The visibility of each type of information is explained below.

Technical information. Our infrastructure and security providers process information such as IP addresses, browser/device information, request timestamps, session identifiers, and security signals to deliver the service, maintain sign-in, prevent spam, and investigate errors or abuse. We use Cloudflare hosting and security services, including Turnstile on forms where enabled. These services can process technical information before you become a member.

Cookies and similar technologies. We use cookies and similar mechanisms for sign-in, session management, and service security. We do not currently use third-party advertising trackers or third-party audience analytics. Blocking necessary cookies may prevent parts of the service from working. We will update this policy and obtain any required consent before introducing materially different tracking.

Images. Images can reveal identity or location through visible details and embedded metadata. Do not rely on image processing to remove every identifying detail; remove unnecessary sensitive information before uploading.

2. How we use information

We use information to:

• Evaluate applications and periodically check membership eligibility.
• Create accounts, provide community features, and display Content to its intended audience.
• Maintain security, troubleshoot problems, prevent abuse, and enforce the Terms.
• Review reports, process removal requests, handle disputes, and keep appropriate records.
• Send application, sign-in, security, service, and policy communications, and deliver notifications you enable where offered.
• Operate the founder's application-review workflow, including summaries of pending applications sent to the operator's business inbox.
• Maintain and improve the service and meet legal obligations.

We do not currently sell, rent, or trade personal information, or disclose it for third-party targeted advertising. We do not currently collect payment-card information or process member purchases.

3. Call signs and who sees what

Call signs are display names, not anonymity guarantees. Other members may know or recognize you from your profile, posts, market, photographs, or professional disclosures.

At launch, community posts, replies, call signs, profile images, and displayed market information are intended for signed-in members. Likes may be visible where the interface shows them. Bookmarks, application details, sign-in information, and reports are not intended to be displayed to other members. Information you include in your own posts or profile is visible to the audience for that feature, even if the same information is otherwise held privately in your account.

The founder and authorized people assisting with operations can access information as needed for their roles. Relevant service providers process information needed to provide their services. We do not provide members with the application database or private account records merely because they hold an account.

Members may copy or disclose information contrary to our rules, and access controls cannot guarantee confidentiality. If we introduce public profiles or public listings, the feature will explain its audience before you publish. Existing member-only posts will not automatically become public because we add a public feature.

4. Service providers and other disclosures

We disclose information as reasonably needed in these circumstances:

• Operating the service. Hosting, storage, security, email, and other service providers process information for the functions they supply. Current arrangements include Cloudflare and [EMAIL DELIVERY AND RECEIVING-MAILBOX PROVIDER(S)]. Providers may process data in the United States and other locations where they operate. Provider access and handling are governed by applicable service terms and data-protection arrangements; we do not promise storage exclusively in Louisiana.
• Handling reports and claims. We may share relevant report details with affected users, professional advisers, insurers, or others involved in resolving a matter. We limit disclosures as reasonably appropriate, but cannot guarantee reporter confidentiality. Copyright counter-notices, including required contact information, are forwarded to the notifying party under the applicable process.
• Legal and safety needs. We may disclose information in response to valid legal process or where otherwise legally permitted and reasonably necessary to investigate fraud or abuse, protect safety or legal rights, or establish, exercise, or defend claims. A complaint or informal request does not automatically entitle someone to private account details.
• Business changes. Information may be transferred to an operating LLC, successor, or purchaser as part of a reorganization or business transfer, subject to this policy and applicable law. Transfer is not permission for unrelated new uses without the notice or consent required by law.
• Your directions. We may disclose information when you direct or authorize us to do so, including through a feature with a clearly disclosed audience.

5. AI-assisted development and operations

The founder uses AI tools to assist with development and business work. That use does not, by itself, give AI providers access to member accounts, private reports, or member-only Content.

Our launch practice is to use synthetic, public, or appropriately redacted examples for external development assistance rather than upload identifiable application records, private reports, or member-only Content into general-purpose AI chats. This policy does not authorize selling those records or using them to train general-purpose AI models.

If we later introduce an AI feature or provider that processes member information, we will describe the actual processing and provider role, establish appropriate safeguards, and obtain any required consent before that processing begins. AI tools do not replace responsibility for handling reports or meeting legal deadlines.

6. Retention, deletion, and your choices

We retain information only as reasonably needed for the purposes described here, considering the information's sensitivity, account status, security needs, applicable legal requirements, and disputes. Different records may have different retention periods.

• Application information is retained while an application is pending and for a limited period afterward to resolve questions, handle reapplications, and prevent abuse. Declined applications are not intended to be retained indefinitely.
• Account information and Content generally remain while an account is active or the Content continues to form part of an existing discussion.
• Technical logs are retained for limited operational and security periods. Relevant records may be retained longer for an investigation or legal obligation.
• Account-closure and deletion requests are applied to active systems, subject to the exceptions below. Backup copies expire under the backup rotation rather than necessarily disappearing immediately.

Email [email protected] to request access, correction, or deletion of your information, close your account, or ask about a privacy concern. We may reasonably verify your identity before responding and will respond within applicable legal deadlines. These contact options are available even where a particular privacy statute does not apply.

Tell us if you also want your original posts or images removed; account closure alone does not necessarily erase an entire discussion. Where deletion is requested, we will delete or appropriately de-identify information unless retention is permitted or required for legal, security, dispute, or other applicable reasons. We will explain a material refusal where required. Removal of a display name alone may not de-identify a post; identifying details in the Content must also be considered.

Replies and quotations by other users may remain where reasonably and lawfully retained, but are subject to requests involving personal information, unlawful content, or other protected rights. We cannot retrieve every copy another person made outside our systems. Restricted legal-hold or abuse-prevention records are not retained for new promotional uses. Deletion instructions must be reapplied if a backup is restored.

You may change available account settings and notification preferences. Optional promotional emails, if introduced, will include an unsubscribe method. Necessary account, security, and legal notices may still be sent. Where applicable law grants additional rights, including an appeal or complaint right, we will honor those requirements and explain the available process when responding. We do not penalize you for exercising applicable privacy rights.

7. Security and age limits

We use reasonable administrative and technical safeguards appropriate to the service. No system is completely secure. We will assess security incidents and provide notifications required by applicable law, including Louisiana's Database Security Breach Notification Law where applicable.

Membership is for adults age 18 or older. We do not knowingly permit children to create accounts. If you believe a child has provided information through an account or application, contact us so we can investigate and take appropriate action.

8. Changes and contact

We will post updated versions with a revised date and give notice of material changes through the service or by email. We will obtain consent where required before materially different processing begins. Continued use is not a substitute for legally required consent, and this policy does not preauthorize future data sales, public disclosure, or AI training.

Operator: [ACTUAL LEGAL OPERATOR NAME AND ENTITY TYPE]
Email: [email protected]
Mailing address: [BUSINESS MAILING ADDRESS]