Privacy Policy

This Privacy Policy explains how [OPERATOR: fill legal entity name], doing business as The Soukup Group ("we," "us," or "our"), a residential real-estate team affiliated with eXp Realty operating in Northern Colorado, collects, uses, discloses, and protects your information when you visit our website, submit a lead form, complete our persona quiz, or otherwise interact with us (collectively, the "Site").

By using the Site, you agree to the practices described in this Policy. If you do not agree, please do not use the Site.

1. Who we are

• Business name: The Soukup Group ([OPERATOR: fill full legal entity name])
• Brokerage affiliation: eXp Realty ([OPERATOR: fill Colorado brokerage license number])
• Service area: Northern Colorado ([OPERATOR: confirm the 5 NoCo cities served])
• Business address: [OPERATOR: fill business mailing address]
• Privacy contact: [OPERATOR: fill contact / DPO email]

2. Information we collect

2.1 Information you provide directly

• Contact information you submit through our landing-page lead forms and persona quiz, including your name, email address, and telephone number.
• Quiz responses and preferences — the answers you give in our persona quiz and any property or lifestyle preferences you share (for example, budget range, buyer/seller/investor interest, desired areas or property types).
• Communications — the contents of messages you send us and records of our correspondence.

2.2 Information we collect automatically

When you use the Site, we and our analytics and advertising partners automatically collect certain behavioral and device information, which may include:

• IP address and approximate location;
• browser type, device type, and operating system;
• pages viewed, links clicked, referring/exit pages, and time spent;
• interactions with property listings and the investor financial module; and
• cookie identifiers and similar advertising/analytics identifiers.

We collect this information using cookies and similar technologies, including Google Analytics 4 (GA4) and the Meta Pixel. See Section 5 (Cookies and Tracking Technologies).

2.3 Information we do not intentionally collect

We do not ask for or intentionally collect sensitive categories of personal data (such as government ID numbers, financial account numbers, health information, or precise geolocation). Please do not submit such information through the Site. Consistent with Fair Housing law, we do not solicit or make decisions based on race, color, religion, national origin, sex, familial status, disability, or other protected characteristics.

3. How we use your information

We use the information we collect to:

• respond to your inquiries and provide real-estate services you request;
• contact you by email, phone call, or text message about properties, your inquiry, and related services (see our separate lead-form consent language and Section 8);
• personalize the Site and the property/persona experience;
• send marketing and informational emails via our email provider (you may unsubscribe at any time);
• measure and improve Site performance and our marketing;
• deliver and measure advertising, including targeted advertising on third-party platforms; and
• comply with legal obligations and enforce our Terms of Service.

4. How we share your information

We do not sell your personal data in exchange for money. However, our use of advertising cookies (such as the Meta Pixel and Google advertising cookies) may constitute a "sale" and/or "sharing" for targeted advertising under the Colorado Privacy Act, which defines a sale to include an exchange for monetary or other valuable consideration. You can opt out — see Section 7. We may share information as follows:

• Service providers / processors who act on our behalf, including:
  • Google LLC — website analytics (Google Analytics 4);
  • Meta Platforms, Inc. — advertising and conversion measurement (Meta Pixel);
  • Mailgun (Sinch) — transactional and marketing email delivery;
  • [OPERATOR: fill SMS / telephony (10DLC) provider name] — text-message (SMS) delivery and call handling for inquiry follow-up;
  • [OPERATOR: fill CRM vendor name] — customer-relationship management and lead storage;
  • [OPERATOR: fill hosting / IT vendor name] — website hosting and infrastructure;
  • Google Signals — cross-device advertising and analytics, only if enabled ([OPERATOR: confirm whether Google Signals is enabled in GA4]); and
  • any additional processors ([OPERATOR: confirm/add any additional processors]).
• Brokerage and agents — our affiliated brokerage (eXp Realty) and licensed team members, to serve your request.
• Legal and safety — when required by law, subpoena, or to protect rights, safety, or property.
• Business transfers — in connection with a merger, acquisition, or sale of assets.

Some sharing with advertising partners such as Google and Meta may be considered a "sale" or "sharing" for targeted advertising under the Colorado Privacy Act. See Section 7 for your opt-out rights.

5. Cookies and tracking technologies

We use two broad categories of cookies and similar technologies:

• Analytics cookies (e.g., Google Analytics 4) to understand how visitors use the Site.
• Targeted-advertising cookies (e.g., Meta Pixel, Google advertising cookies) to measure and deliver ads and to build advertising audiences.

Third-party advertising and remarketing. Third parties, including Google and Meta, serve ads on other sites and apps using first-party and third-party cookies together to deliver advertising based on your prior visits to this Site. This includes remarketing (showing you our ads after you leave the Site).

Your Privacy Choices — always-available opt-out. A persistent "Your Privacy Choices" link and cookie-preference control are available on every page of the Site (in the footer). You can use it at any time to opt out of targeted-advertising cookies. We also honor the Global Privacy Control (GPC) and other recognized universal opt-out mechanisms at page load: when we detect a GPC signal or a saved opt-out, we suppress targeted-advertising pixels (via Google Consent Mode and equivalent Meta signal suppression) so that opting out actually prevents advertising pixels from firing — not merely records a preference. You can also control cookies through your browser settings. Note that blocking some cookies may affect Site functionality.

You can additionally opt out of interest-based advertising through these industry tools:

• Google Analytics opt-out: tools.google.com/dlpage/gaoptout
• Google Ads Settings: adssettings.google.com
• Meta ad preferences: facebook.com/adpreferences
• Digital Advertising Alliance (DAA): optout.aboutads.info
• Network Advertising Initiative (NAI): optout.networkadvertising.org

Housing-ad restrictions (Fair Housing). Because our advertising relates to housing, all housing-related ad campaigns are run under Meta's Special Ad Category for housing and Google's housing (HEC) restrictions. We do not target or exclude audiences by age, gender, ZIP code, or any protected-class characteristic or proxy, and we do not build or use site-derived Custom or Lookalike audiences for housing campaigns except as permitted through Special Ad Audiences. See our Fair Housing commitment in our Terms of Service.

6. Data retention

We keep personal data only as long as necessary for the purposes described in this Policy, to comply with legal, tax, and real-estate recordkeeping obligations, and to resolve disputes. Our standard retention periods are:

• Transaction and brokerage records: [OPERATOR: fill — recommend ~4 years to align with Colorado Real Estate Commission recordkeeping minimums; confirm with counsel].
• Un-converted marketing leads and quiz responses: [OPERATOR: fill retention period, e.g., 24 months].

When no longer needed, we delete or de-identify the data.

7. Your Colorado privacy rights (Colorado Privacy Act)

If you are a Colorado resident, the Colorado Privacy Act (CPA) gives you the right to:

• Access — confirm whether we process your personal data and obtain a copy;
• Correct — correct inaccuracies in your personal data;
• Delete — request deletion of your personal data;
• Data portability — obtain your data in a portable format; and
• Opt out of processing for (a) targeted advertising, (b) the sale of personal data, and (c) certain profiling that produces legal or similarly significant effects.

How to exercise your rights: contact us at [OPERATOR: fill contact / DPO email] or [OPERATOR: fill mailing address / request form URL]. We will verify your request and respond within the timeframe required by the CPA. You may also authorize an agent to act on your behalf.

Universal opt-out / targeted-advertising opt-out: We honor recognized universal opt-out mechanisms (such as the Global Privacy Control) at page load, as required by the CPA. You may also opt out of targeted advertising at any time through the persistent "Your Privacy Choices" / cookie-preference control on every page and via the industry links in Section 5.

Profiling opt-out. Our persona quiz and investor financial module involve profiling. You may opt out of profiling as described above. Our persona classification is used only to rank and personalize the property experience on product, amenity, and quality attributes; it never restricts which properties or price ranges you can see on the basis of any protected class or protected-class proxy, and it does not produce legal or similarly significant effects. See our Fair Housing commitment in the Terms of Service.

Appeals: If we decline your request, you may appeal by contacting [OPERATOR: fill appeals email]. If we deny your appeal, you may contact the Colorado Attorney General at coag.gov.

A note on applicability. We provide these rights and honor these requests as a matter of policy. Depending on our data volumes, we may or may not meet the Colorado Privacy Act's controller thresholds, but we extend CPA rights and the response/appeal timeframes described here regardless. [OPERATOR: confirm the team can meet the CPA response (45-day) and appeal SLAs it commits to here.]

8. Communications and phone/SMS consent

If you provide your phone number and consent, we may contact you by phone call and/or text message (SMS), including through automated technology, about your inquiry and our services. Consent to marketing calls/texts is not a condition of any purchase. Message and data rates may apply. We place calls only between 8:00 a.m. and 9:00 p.m. in your local time. You may revoke consent by any reasonable means (for example, replying STOP or HELP to a text, or calling or emailing us), and we will honor your revocation within 10 business days. You can opt out of emails using the unsubscribe link. See our separate, versioned lead-form consent language for details.

9. Children's privacy

The Site is not directed to children under 13, and we do not knowingly collect the personal data of a child under 13 (consistent with COPPA and the Colorado Privacy Act's treatment of a "child" as an individual under 13). We do not knowingly process the personal data of any known minor for targeted advertising, sale, or profiling without required consent. If you believe a child has provided us information, contact us and we will delete it.

10. Security

We use reasonable administrative, technical, and physical safeguards to protect personal data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Third-party links

The Site may link to third-party websites (including MLS/IDX providers and eXp Realty). We are not responsible for their privacy practices; review their policies separately.

12. Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new "Last updated" date and, where required, provide additional notice.

13. Contact us

The Soukup Group — [OPERATOR: fill legal entity name]
[OPERATOR: fill business address]
Email: [OPERATOR: fill contact / DPO email]
Phone: [OPERATOR: fill business phone]