Privacy Policy

1. Information We Collect

We collect personal, professional, technical, and transactional information relevant to the operation of our commercial and residential real estate services and digital platforms. This includes data actively supplied by you, inferred from interaction, or received in connection with authorized third-party integration.

1.1 Information You Provide Directly

This includes (but is not limited to):

• Name, email address, mobile and office phone number
• Business entity, job title, and professional role
• Mailing address, property ownership details, investment objectives, or disposition strategies
• Inquiry details submitted through valuation request forms, lease/buy forms, deal summary submissions, internal CRM or AI-powered prompts
• Content of communications via email, SMS, phone calls, AI-enabled chat, website forms, CRM-generated or automated interaction
• Uploaded documentation such as letters of intent, purchase agreements, offers, proposals, property plans, surveys, financials, rent rolls, cap rate analyses, corporate governance and transactional materials
• Responses to market surveys, financial qualification questions, investment models
• Authorization decisions regarding marketing, AI communication usage, and data processing preferences

1.2 Automatically Collected Information

When you access our websites, portals, CRM or IDX tools, we may automatically collect:

• IP address, device model, browser type, operating system, system language
• Usage telemetry including session length, pages viewed, scroll depth, click paths, button interactions, search filters applied
• Analytics related to MLS/IDX search functions or content engagement
• Geographic data inferred from IP range (non-precise unless explicitly shared)
• Real-time system feedback for AI training (anonymized unless linked to authenticated sessions)

1.3 Third-Party & Transactional Data

We may receive data from:

• MLS/IDX services including listing metadata, photos, media, financial indicators, status changes, acquisition opportunity flags
• Commercial data providers, demographic systems, zoning and land-use intelligence feeds
• Referring brokers, client attorneys, accountants, lenders, or advisors (with consent or written authorization)
• Public records, county property records, and governmental databases

You remain the primary controller of your personal data unless explicitly assigned via transaction documentation, written authorization, or as required by law.

2. How We Use Your Information

We use your data solely for legitimate brokerage, advisory, analytics, operational, and compliance purposes.

2.1 Primary Uses

We use your information to:

• Facilitate acquisitions, dispositions, leases, valuations, and strategy consultations
• Match you with suitable properties and investment opportunities (on-market and off-market where permitted)
• Structure offers, proposals, capital deployment models, and transaction strategies
• Draft and manage real estate documentation (subject to attorney review where applicable)
• Manage ongoing engagement, reminders, follow-ups, and performance monitoring for live transactions
• Conduct commercial trend prediction, repositioning analysis, and asset value impact estimations using AI and analytics

2.2 Improvement & Operational Optimization

We use information to:

• Automate internal processes for tracking, triaging, and prioritizing matters
• Ensure multi-channel follow-up for key negotiations and time-sensitive tasks (with AI-monitored deadlines)
• Improve user interfaces and experience across MLS/IDX search portals, dashboards, and forms
• Analyze the contact-to-closing pipeline to understand performance, conversion, and bottlenecks
• Optimize staffing, resourcing, and internal workflows based on aggregated data

2.3 Compliance, Legal & Risk Mitigation

We use information to:

• Confirm identity, verify transactional input, and help prevent non-circumvention or fraud
• Satisfy anti-money-laundering (AML) and know-your-client (KYC) checks where applicable
• Maintain documentation under legally required retention periods (often 7–10 years)
• Respond to regulatory inquiries, audits, subpoenas, and other legal processes
• Manage disputes, enforcement of contracts, and litigation preparedness (contract preservation and evidence archiving)

We do not repurpose your personal data for unrelated non-real-estate functions.

3. Legal Basis for Processing

We process personal information only when permitted by applicable law, including:

• Contractual necessity: When processing is needed to enter into or perform a brokerage, listing, representation, or services agreement with you, or to respond to your explicit requests before entering a contract.
• Express consent: When you provide consent for marketing communications (email, SMS, phone, AI outreach), advanced analytics or personalization, AI-assisted or automated engagement beyond what is strictly necessary.
• Regulatory and legal compliance: Including real estate licensing and record-keeping requirements, Fair Housing, anti-discrimination, and ADA obligations, AML, KYC, and anti-fraud regulations, tax and accounting obligations.
• Legitimate business interests: Including brokerage operations and internal audit, platform security and fraud prevention, service improvement and product development, network and information security.
• Litigation preparedness and defense: For contract preservation, evidence archiving, dispute resolution, or legal claims.

4. Information Sharing

We do not sell or license your personal data. We may share limited information only when necessary and permissible.

4.1 Transaction-Based Delegation

We may share your information with:

• Buyers, sellers, landlords, tenants, and their authorized representatives strictly for property showings, offers, negotiations, and deal execution
• Title companies, escrow agents, and closing attorneys
• Lenders, appraisers, inspectors, environmental consultants, and other due-diligence professionals (when you or your representatives direct us to do so)
• Accounting, tax, or legal professionals engaged to support your transaction, with your consent

4.2 Operational & Technology Support

We may share data with vetted service providers acting as our processors, including:

• CRM and client management platforms
• MLS/IDX services and data providers
• Hosting and cloud storage providers
• Email, SMS, and communications platforms
• AI and analytics vendors used to support our operations
• Cybersecurity infrastructure providers that perform threat detection, risk scanning, and AI-assisted anomaly detection

Each such provider is contractually required to maintain confidentiality, use data only as instructed by us, and implement appropriate security measures.

4.3 Mandatory Legal Disclosure

We may disclose your information where required by law, including to state or federal agencies, regulators, and law enforcement, and MLS boards and compliance bodies for audits or investigations.

5. Data Retention

We retain data only as long as reasonably necessary for the purposes described in this Policy or as required by law. Retention is based on:

• Transaction relevance: until final closure or termination of a matter
• Legal holding requirements: including real estate, tax, and financial laws (often 7–10 years)
• Regulatory preservation: per Michigan real estate guidelines and applicable federal law

Typical retention schedules:

• Transaction files: 7 years post-closing (commercial real estate industry standard)
• Financial records (including 1099-related records): 7 years (IRS requirements)
• General correspondence: 3 years
• Marketing communications and contact records: Until you opt out, plus up to 30 days to maintain suppression lists
• Legal hold materials: Retained indefinitely if subject to investigation, litigation, or potential claims

At the end of the retention period, data is securely destroyed:

• Physical documents: cross-cut shredding with certificate of destruction
• Electronic records: secure data wiping (e.g., DOD 5220.22-M standard or equivalent) and/or encrypted media disposal

6. Security & Cyber Protection

We use enterprise-grade cybersecurity and data protection practices to safeguard your information.

6.1 Technical Defenses

• Encryption in transit and at rest (e.g., TLS 1.2+ and AES-256 or equivalent)
• Firewalls and intrusion detection/prevention systems (IDS/IPS)
• Proactive bot and DDoS mitigation where applicable
• Regular patching and vulnerability management
• Multi-factor authentication (MFA) for administrative and privileged access
• Secure backup systems with encrypted off-site or cloud storage
• Regular penetration testing and security assessments (at least annually)

6.2 Operational Controls

• Role-based access control (principle of least privilege)
• Strict internal confidentiality agreements for employees and contractors
• Real-time anomaly detection leveraging AI/ML tools
• Employee background checks (for staff handling sensitive data)
• Mandatory annual security and privacy training
• Formal incident response plan with defined escalation procedures

6.3 Security Limitations

Despite robust safeguards, no system can be guaranteed 100% secure. In the event of a security incident affecting your personal information, we will act in accordance with Section 17 (Data Breach Notification).

7. Your Privacy Rights

You have the following rights, subject to applicable law:

• Right of access: Request information about the personal data we hold about you.
• Right to correction (rectification): Request that we correct inaccurate or incomplete information.
• Right to erasure ("right to be forgotten"): Request deletion of your information when it is no longer needed for the purposes collected, you withdraw consent (where consent was the legal basis), or there is no overriding legal or legitimate basis to retain it.
• Right to restrict processing: Request restriction of processing, particularly during dispute resolution, when you contest accuracy, or when processing is unlawful and you prefer restriction over deletion.
• Right to object: Object to processing based on legitimate interests, including certain types of profiling.
• Right to data portability: Request export of your data in structured, commonly used, machine-readable formats (see Section 23).
• Right to withdraw consent: Withdraw your consent for processing at any time (does not affect prior lawful processing).
• Right to opt-out of marketing and AI automations: Opt out of marketing communications and certain AI-assisted workflows.

How to Exercise Your Rights

Submit requests to:

• Email: privacy@tapcre.com
• Phone: (313) 306-SOLD (7653)
• Mail: TAP CRE, LLC, 6001 Cass Ave, Detroit, MI 48202
• Online form: https://tapcre.com/privacy-request

Verification & Response

• We will verify your identity before fulfilling requests (for your protection).
• We generally respond within 45 days; this may be extended up to 90 days for complex requests, with notice.
• Initial requests are free of charge. We may charge a reasonable fee or decline requests that are manifestly unfounded, excessive, or repetitive.
• If we deny a request, we will explain the legal basis for denial and your options.

8. Cookies & Tracking

We use cookies and similar technologies to operate, secure, and improve our sites and services.

8.1 Cookie Types Deployed

Strictly Necessary Cookies (cannot be disabled):

• Authentication and session management
• Security and fraud prevention
• Load balancing and essential performance
• Legal compliance tracking (e.g., cookie consent)

Performance / Analytics Cookies (optional, with consent where required):

• Traffic and usage analytics
• Error tracking and debugging
• Performance measurement (e.g., page load, crashes)
• Duration typically up to 2 years

Functional Cookies (optional, with consent where required):

• Saved MLS search filters and preferences
• Language and display settings
• Saved property searches and favorites
• Chat widget/session history
• Duration typically up to 1 year

Advertising / Targeting Cookies (optional, with consent where required):

• Retargeting and conversion tracking (e.g., social media, ad networks)
• A/B testing for content and layout
• AI-driven personalization (only with opt-in)
• Duration typically up to 13 months

8.2 Managing Cookies

You can control cookie use via our cookie preference center or browser settings (Chrome, Firefox, Safari, Edge, etc.). Disabling some cookies may impair site performance or limit certain functionality (e.g., saved searches, quicker load).

8.3 Third-Party Cookies

We may use cookies from third-party providers such as Google Analytics, Facebook/Meta Pixel, LinkedIn Insight Tag, and other analytics or ad technology providers. These third parties are responsible for their own privacy practices, which you should review separately.

9. AI, Automation & Broker Intelligence Systems

We use AI and automation to enhance speed, modeling, and deal optimization—not to replace licensed human judgment or legal advice.

9.1 AI Use Cases

We may use AI and automated tools for:

• Lead engagement automation, follow-up prioritization, and response timing
• Predictive property and opportunity matching based on your preferences and behavior
• Draft generation of proposals, summaries, and communications (reviewed by licensed brokers)
• Tracking transaction milestones and deadline alerts (e.g., due diligence dates, contingencies)
• Market trend analysis, comparative valuation modeling, and scenario exploration
• Fraud and anomaly detection (e.g., unusual access patterns)
• Communication sentiment analysis and service level monitoring

9.2 Human Oversight

• All critical AI outputs are reviewed by human professionals.
• No AI-generated recommendation constitutes legal, tax, or financial advice.
• AI suggestions are tools; final decisions remain with licensed real estate professionals and the parties involved.

9.3 AI Training & Your Data

• Anonymized or aggregated interaction data may be used to improve AI models.
• Client-identifiable data is not used for general AI training without explicit opt-in consent.
• You may opt-out of certain AI-assisted interactions (see Sections 7 and 19).

10. Third-Party Links & External Data Platforms

Our platforms may reference or link to external websites and tools (e.g., Google Maps, county record search, valuation calculators, MLS partner sites).

• These external platforms are governed by their own privacy policies.
• We do not control, endorse, or assume responsibility for the privacy practices or content of third-party sites.
• We recommend reviewing the privacy policies of any external services before sharing personal information with them.

11. International Storage & Cloud-Based Processing

Your data may be stored or processed in secure data centers outside Michigan or the United States.

11.1 Cross-Border Transfers

Cross-border transfers may occur:

• Under encryption in transit and at rest
• Through service providers that contractually agree to adequate data protection
• Subject to appropriate safeguards (e.g., Standard Contractual Clauses or equivalent mechanisms)

11.2 International Data Transfer Safeguards

We:

• Enter into Data Processing Agreements (DPAs) with international processors
• Conduct security and compliance due diligence on providers
• Perform Transfer Impact Assessments for higher-risk jurisdictions
• Require that providers meet or exceed U.S. data protection standards

You may object to specific international transfers; however, this may impact our ability to provide certain services.

12. Children's Privacy

Our services are intended for individuals 18 years of age or older.

• We do not knowingly collect personal data from anyone under 18.
• If we learn that we have collected data from a person under 18, we will delete it as soon as reasonably practicable (generally within 48 hours of confirmation).

13. Regulatory Compliance: Real Estate, MLS & Fair Housing

We comply with all applicable federal, state, and local laws, including:

• Michigan real estate brokerage licensing and record-keeping requirements
• MLS/IDX participation rules, display standards, and data usage policies
• Fair Housing Act and related anti-discrimination laws
• Americans with Disabilities Act (ADA)–related digital accessibility standards (see Section 26)
• Anti-fraud, AML, and KYC obligations
• Real Estate Settlement Procedures Act (RESPA) and applicable consumer protection laws

13.1 Fair Housing Commitment

We do not engage in and do not tolerate:

• Discriminatory marketing, advertising, or steering
• Redlining or other discriminatory geographic practices
• Unlawful profiling or differential treatment

To report Fair Housing concerns:

• U.S. HUD Fair Housing Hotline: 1-800-669-9777
• Michigan Department of Civil Rights: 1-800-482-3604
• Our compliance officer: privacy@tapcre.com

14. Policy Modification & Continued Acceptance

We may revise this Privacy Policy from time to time to reflect:

• Changes in law or regulation
• Updates to our brokerage or technology practices
• Enhancements in AI, security, or platform capabilities

14.1 Notice of Changes

For material changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Post the revised Policy on our website
• For significant changes, provide additional notice such as email notification

14.2 Your Options

• Continued use of our services after changes take effect constitutes your acceptance of the updated Policy.
• You may withdraw consent for non-essential processing at any time (e.g., marketing, AI personalization).
• If you do not agree with changes, you may discontinue use of our services and request deletion or restriction of your data where applicable.

15. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). TAP CRE, LLC complies with California's privacy legislation for all California residents who visit our website or engage with our services.

We do not sell personal data for monetary consideration, but may "share" information for marketing optimization in a manner defined under CPRA. You may opt-out at any time.

Do Not Sell or Share My Personal Information Link: https://tapcre.com/do-not-sell

15.1 Your California Rights

You have the right to:

• Know what personal information we collect, use, disclose, and "sell" or "share" (if applicable)
• Access your personal information (up to twice in a 12-month period)
• Request deletion of your personal information, subject to legal exceptions
• Opt-out of any "sale" or "sharing" of your personal information (as defined by CPRA)
• Correct inaccurate personal information
• Limit use and disclosure of sensitive personal information
• Not be discriminated against for exercising your privacy rights

15.2 Categories of Personal Information Collected (Last 12 Months)

We may collect:

• Identifiers (name, email, phone, IP address, device ID)
• Commercial information (transaction history, property interests, investment objectives)

15.3 Exercising California Rights

Submit a request via:

• Email: privacy@tapcre.com
• Phone: (313) 306-SOLD (7653)
• Mail: TAP CRE, LLC, 6001 Cass Ave, Detroit, MI 48202

We will verify your identity and respond in accordance with CCPA/CPRA timelines (typically 45 days, extendable to 90 days with notice). You may authorize an agent to act on your behalf, subject to verification of both you and the agent. We do not discriminate against you for exercising your California privacy rights.

16. Biometric Information & Recordings

16.1 Biometric Data

If, in the future, we use systems that process biometric identifiers (e.g., facial recognition, voiceprints), we will:

• Obtain your explicit written consent before collection
• Inform you of the specific purpose and duration
• Never sell or trade biometric information
• Retain biometric data only as long as necessary for the purpose, or within 3 years of your last interaction, whichever is shorter
• Apply data security equal to or greater than that used for other confidential information
• Permanently destroy biometric data upon completion of purpose or end of the retention period

16.2 Call and Video Recording

Telephone calls, video consultations, and AI chat sessions may be recorded or transcribed for:

• Quality assurance and training
• Documentation of transactions and instructions
• Dispute resolution and compliance

By using these channels, you may receive a notice such as: "This call may be recorded." If you do not wish to be recorded, you may request alternative methods (e.g., email, non-recorded calls where feasible). For two-party consent jurisdictions, we will obtain affirmative consent prior to recording.

16.3 AI Transcription & Analysis

Recordings and calls may be:

• Transcribed by AI for internal records
• Analyzed for sentiment, urgency, and service quality
• Used in anonymized form to improve our systems

You may request copies of recordings related to your matter, subject to legal and practical limits.

17. Data Breach Notification

If a breach occurs, we commit to notification within 30 days or sooner, in line with MCL 445.72 and applicable federal law. Contact: privacy@tapcre.com

17.1 Our Commitment

If a data breach occurs that compromises your personal information, we will:

• Investigate promptly
• Contain and remediate the incident
• Notify affected individuals in compliance with Michigan law and other applicable laws

17.2 Notification Timing

Michigan law requires notice without unreasonable delay. Our internal standard is to provide notice within 30 days of discovery, unless law enforcement requests delay to avoid impeding an investigation.

17.3 Notification Methods

We may notify you via:

• Email (primary method)
• Postal mail
• Phone call (for high-risk scenarios, especially involving financial information)
• Website notices or media announcements (for large-scale events or where individual contact is not feasible)

17.4 Contents of Notification

We will generally include:

• Date or estimated date of the breach
• Types of personal information involved
• Steps we have taken to investigate and mitigate
• Recommended actions for you (e.g., credit monitoring, password changes)
• Whether law enforcement has been contacted
• Contact details for more information

18. Telephone & SMS Communications (TCPA Compliance)

Consent required for marketing calls/texts. Reply "STOP" to opt out. Transactional communications may continue for active deals.

18.1 Consent to Calls and Texts

By providing your phone number and affirmatively consenting (e.g., checkbox, web form, written agreement), you agree that TAP CRE, LLC and its agents may contact you via phone calls (live or automated), SMS/MMS text messages, and autodialed or AI-assisted messages.

For purposes including:

• Property listings and market updates
• Transaction-related communications
• Appointment scheduling and reminders
• Marketing campaigns (with your consent)
• AI-initiated follow-ups and notifications

Consent is not a condition of obtaining brokerage services. You may engage us without consenting to marketing texts or calls.

18.2 Message Frequency & Costs

• Message frequency may vary based on your activity and preferences.
• Standard message and data rates from your carrier may apply. We do not charge you for messages.

18.3 Opt-Out

You may revoke consent at any time:

• Text: reply "STOP" to any SMS from us
• Email: info@tapcre.com with "SMS OPT-OUT" or "CALL OPT-OUT"
• Phone: call (313) 306-SOLD (7653) and request removal
• Mail: TAP CRE, LLC, 6001 Cass Ave, Detroit, MI 48202

You may receive one final confirmation message. Transactional messages related to an active deal may still be sent as reasonably necessary.

19. Automated Decision-Making & AI Systems

AI is used as an assistive technology only, not authoritative. You may request human review of any AI-driven engagement. Request human-only service: privacy@tapcre.com with Subject: "Human Review Request"

19.1 Use of Automated Systems

We use AI and automation to:

• Prioritize leads and follow-up timing
• Suggest properties based on your past behavior and preferences
• Generate drafts of communications, proposals, and summaries
• Track transaction timeline and flag deadlines
• Analyze market data and suggest potential strategies
• Detect anomalies and potential fraud patterns

19.2 No Fully Automated Legal Decisions

We do not make decisions solely through automated means that:

• Approve or deny transactions
• Determine price, commissions, or binding offer terms
• Determine creditworthiness or lending approval
• Create legal obligations without human review

Licensed professionals review and approve all material recommendations.

19.3 Your Rights Regarding AI

You may:

• Request human review of AI-assisted conclusions or suggestions
• Obtain a general explanation of how AI was used in your situation
• Object to certain types of AI processing
• Opt-out of AI-assisted communications (understanding this may slow response times or reduce personalization)

Requests: privacy@tapcre.com with subject "HUMAN REVIEW REQUEST" or "AI OPT-OUT".

20. Marketing Communications & Granular Opt-Out

20.1 Types of Marketing

We may send:

• Email newsletters and listing alerts
• SMS campaigns (with TCPA-compliant consent)
• Phone outreach and check-ins
• AI-initiated chat or CRM messages
• Retargeting ads (online)
• Direct mail (postcards, brochures)

20.2 Channel-Specific Opt-Out

You can opt-out per channel:

• Email: click "Unsubscribe" in any marketing email or email info@tapcre.com
• SMS: text "STOP"
• Phone: request Do Not Call status via phone or email
• AI / chat outreach: request "human-only" communications or email privacy@tapcre.com
• Direct mail: email info@tapcre.com with your name and mailing address

20.3 Transactional vs. Marketing

Opt-outs apply to marketing only. We may still send:

• Transaction updates and confirmations
• Closing reminders and time-sensitive notices
• Account security alerts
• Legally required communications

21. Financial Information & GLBA Compliance

When necessary to support transactions, we may collect sensitive financial information, including:

• Bank account info and statements (e.g., proof of funds)
• Tax returns and financial statements
• Credit reports and scores (with your authorization)
• Net worth statements and debt schedules
• Loan applications and related documents

We treat this financial information in line with Gramm-Leach-Bliley Act (GLBA) standards:

• Encryption of financial data at rest and in transit
• Strict role-based access and logging
• Sharing only with parties necessary to complete your requested transaction or as required by law
• No selling or marketing use of financial data

Financial records are typically retained for the duration of the transaction plus 7 years, or longer if legally required, then securely destroyed.

22. Third-Party Service Providers & Sub-processors

We use third-party providers to support our operations, including:

• CRM and client management platforms
• Cloud hosting and storage providers
• Communication tools (phone, email, SMS)
• Analytics and marketing platforms
• MLS/IDX and data providers
• Document management and e-signature services
• AI and machine learning vendors
• Cybersecurity and monitoring services

A current list of sub-processors may be requested by emailing privacy@tapcre.com.

All service providers are bound by contract to:

• Use data only to provide services to TAP CRE
• Maintain confidentiality and security
• Notify us of security incidents affecting our data

We only use third parties with contractual security and confidentiality enforcement.

23. Data Portability

You may request that we provide certain personal information in a structured, commonly used, machine-readable format (e.g., JSON, CSV, XML, or PDF), and, where technically feasible, transmit it directly to another service provider at your request.

Requests: privacy@tapcre.com with subject "DATA PORTABILITY REQUEST".

We will verify your identity and respond within standard legal timeframes.

24. Sensitive Personal Information – Enhanced Protections

Sensitive personal information (e.g., Social Security numbers, driver's license data, bank details, credit reports) is collected only when strictly necessary for:

• Regulatory compliance (e.g., 1099 reporting, AML)
• Identity verification
• Transaction funding and closing

We apply additional safeguards:

• Encryption, segregation, and strict access control
• Limited retention and secure destruction
• No use for marketing, profiling, or AI training

You may request that we limit use of your sensitive personal information to only what is necessary to perform our services, subject to legal requirements.

25. Children's Privacy & Age Verification

Our services are not directed to or intended for children under 18.

By using our services, you represent that you are at least 18 years old. For high-value or regulated transactions, we may request identity verification.

If you believe a minor has provided personal information, contact privacy@tapcre.com with the subject "UNDERAGE USER".

We will investigate promptly and delete any data collected from an underage individual.

26. Web Accessibility

We are committed to providing a website experience in substantial conformance with WCAG 2.1 Level AA where reasonably practicable.

If you encounter accessibility barriers or need alternative formats, contact:

• Email: accessibility@tapcre.com
• Phone: (313) 306-SOLD (7653)
• Mail: TAP CRE, LLC, 6001 Cass Ave, Detroit, MI 48202

We will work to address issues promptly and provide reasonable accommodations.

27. Limitations of Liability & Legal Provisions

27.1 No Contractual Rights

This Privacy Policy describes our data practices and your rights. It does not, by itself, create contractual rights beyond those provided by applicable law, unless expressly incorporated into a separate written agreement.

27.2 Relationship to Other Agreements

This Policy supplements, but does not override:

• Brokerage agreements
• Listing and representation agreements
• Purchase and sale agreements
• Terms of Use or site-specific terms
• NDAs and other contracts

In case of conflict, specific contractual terms generally govern transaction obligations; this Policy governs privacy and data handling.

27.3 Governing Law; Jurisdiction

This Privacy Policy is governed by the laws of the State of Michigan, without regard to conflict-of-law principles. Any disputes related to this Policy shall be brought exclusively in the state or federal courts located in Wayne County, Michigan, and you consent to personal jurisdiction and venue in those courts.

27.4 Limitation of Liability

To the maximum extent permitted by law:

• Our total liability for any claim relating to this Privacy Policy is limited to the greater of $1,000, or the amount you paid to TAP CRE in the 12 months preceding the claim.

These limitations do not apply where prohibited by law, including for gross negligence, willful misconduct, or other non-waivable rights.

27.5 Severability

If any provision of this Policy is deemed unenforceable, the remaining provisions shall remain in full force and effect. The invalid provision will be modified only to the extent necessary to make it enforceable while preserving its intent.

28. Cookie Notice & Consent Management

See Section 8 for detailed information about our use of cookies and tracking technologies.

You can manage your cookie preferences through our website settings or your browser. By continuing to use our site without adjusting your settings, you consent to our use of strictly necessary cookies.

29. Email Authentication & Security

We implement email authentication protocols to help protect you from phishing and email fraud:

• SPF (Sender Policy Framework)
• DKIM (DomainKeys Identified Mail)
• DMARC (Domain-based Message Authentication, Reporting, and Conformance)

If you receive a suspicious email appearing to be from TAP CRE, do not click any links or provide personal information. Forward it to security@tapcre.com for investigation.

30. Michigan-Specific Privacy Provisions

As a Michigan-based real estate brokerage, we comply with all applicable Michigan privacy and consumer protection laws, including:

• Michigan Identity Theft Protection Act (MCL 445.61 et seq.)
• Michigan Breach Notification Law (MCL 445.72)
• Michigan Consumer Protection Act
• Michigan Occupational Code requirements for real estate licensees

Michigan residents have specific rights under state law, which we honor in addition to any broader rights described in this Policy.

31. Privacy Policy Changes & Continued Use

We may update this Privacy Policy periodically. When we make changes, we will update the "Last Updated" date at the top of this page. For material changes, we may provide additional notice (such as email notification or a prominent notice on our website).

Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about our privacy practices.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

• TAP CRE, LLC
• 6001 Cass Ave
• Detroit, MI 48202
• Email: privacy@tapcre.com
• Phone: (313) 306-SOLD (7653)