Privacy Policy

1. Who We Are

The Cosmore brand is used by real estate brokerage and related entities operating in the United States, including, where applicable:

• Cosmore Florida Corp.
  1200 Brickell Avenue, Suite 250
  Miami, Florida 33131
• Cosmore NY Corp.

The particular Cosmore entity responsible for your information may depend on the service you request, your location, and the applicable real estate jurisdiction.

For purposes of this Privacy Policy, these entities may collectively be referred to as “Cosmore,” “we,” “us,” or “our.”

2. Information We Collect

Depending on how you interact with Cosmore, we may collect the following categories of information.

Contact Information

This may include:

• first and last name;
• email address;
• telephone or mobile number;
• mailing address;
• preferred communication method.

Real Estate Information

If you contact us regarding buying, selling, renting, leasing, investing, or other real estate services, we may collect information such as:

• properties of interest;
• property ownership information;
• desired location;
• price range;
• transaction preferences;
• financing-related information you voluntarily provide;
• real estate search criteria;
• information necessary to facilitate a transaction or inquiry.

Real Estate Professional and Recruiting Information

If you are a real estate professional interested in joining or learning more about Cosmore, we may collect:

• current brokerage;
• professional role;
• real estate license information;
• jurisdiction or market;
• years of experience;
• transaction volume;
• areas of specialization;
• professional interests;
• recruiting preferences;
• interview information;
• information submitted through the Join Cosmore application or recruiting process.

Communications

We may collect and retain information contained in communications with us, including:

• emails;
• telephone-call notes;
• SMS or text messages;
• WhatsApp or other messaging communications where applicable;
• website inquiries;
• recruiting communications;
• customer service communications.

Website and Device Information

When you use our websites or digital services, we may automatically collect certain technical information, including:

• IP address;
• browser type;
• device type;
• operating system;
• pages viewed;
• referring website;
• approximate geographic location derived from IP address;
• date and time of visits;
• website interactions;
• cookies and similar technologies.

Information from Third Parties

We may receive information from third parties, including:

• real estate listing services;
• referral partners;
• real estate professionals;
• advertising platforms;
• social media platforms;
• property information providers;
• public records;
• service providers;
• individuals who refer you to Cosmore.

3. How We Use Personal Information

We may use personal information to:

• respond to inquiries;
• provide real estate brokerage services;
• communicate regarding properties or transactions;
• provide property information;
• facilitate introductions and appointments;
• manage client relationships;
• manage prospective client relationships;
• manage real estate agent recruiting;
• schedule recruiting interviews or meetings;
• evaluate applications submitted to Cosmore;
• administer the Join Cosmore recruiting process;
• communicate with real estate professionals who have expressed interest in Cosmore;
• operate and improve our websites and digital services;
• personalize website experiences;
• maintain security and prevent fraud or misuse;
• maintain business and transaction records;
• analyze website and marketing performance;
• comply with legal, regulatory, licensing, and professional obligations;
• enforce our agreements and policies;
• protect the rights and safety of Cosmore, our clients, users, and others.

Where permitted by law and where the appropriate consent has been obtained, we may also use contact information to send promotional or marketing communications.

4. SMS and Text Message Communications

Cosmore may offer users the option to receive communications by SMS or text message.

These communications may include:

• recruiting-related communications;
• responses to inquiries;
• appointment or interview confirmations;
• reminders;
• follow-up communications;
• information regarding Cosmore;
• onboarding-related communications;
• other communications specifically described at the point where consent is obtained.

SMS Consent

Where consent is required, we will request SMS consent separately before sending applicable text messages.

Providing a mobile telephone number alone does not necessarily constitute consent to receive marketing or recruiting text messages.

SMS consent is voluntary and is not required as a condition of purchasing real estate brokerage services, applying to join Cosmore, or otherwise doing business with Cosmore.

Where you opt in to receive SMS communications:

• Message frequency varies.
• Message and data rates may apply.
• You may reply STOP at any time to opt out.
• You may reply HELP for assistance.

You may also contact us at info@cosmore.com for assistance regarding our communications.

5. Important SMS Privacy Disclosure

Cosmore does not sell, rent, transfer, or share your mobile telephone number, SMS opt-in information, or SMS consent with third parties or affiliates for their marketing or promotional purposes.

Mobile information and text messaging originator opt-in data and consent will not be shared with any third parties or affiliates for marketing or promotional purposes.

This restriction applies even where this Privacy Policy otherwise permits Cosmore to share other categories of personal information with service providers, affiliates, business partners, or other third parties.

We may provide mobile information to service providers that perform services on our behalf and are necessary to operate our messaging program, such as telecommunications carriers, messaging technology providers, and platform service providers. Such providers may use the information only as necessary to provide services to Cosmore and are not authorized by Cosmore to use SMS consent information for their own marketing or promotional purposes.

6. How to Withdraw SMS Consent

You may withdraw consent to receive SMS communications at any time.

You may:

• reply STOP to a Cosmore text message; or
• contact us at info@cosmore.com.

After an opt-out request is processed, you will no longer receive messages from the applicable SMS program unless you subsequently provide new consent.

Opting out of SMS does not necessarily prevent Cosmore from communicating with you through other permitted channels, such as email or telephone, where legally appropriate.

7. How We Disclose Personal Information

We may disclose personal information when reasonably necessary for legitimate business purposes or to provide services requested by you.

Service Providers

We may provide information to service providers that help operate our business, including providers of:

• website hosting;
• cloud infrastructure;
• CRM and business software;
• communications services;
• email services;
• telecommunications and SMS services;
• electronic signature services;
• scheduling;
• analytics;
• cybersecurity;
• data storage;
• professional services.

These providers are authorized to process information only for legitimate business purposes and subject to applicable contractual and legal obligations.

Real Estate Transactions

Where appropriate, information may be disclosed to parties involved in a real estate transaction, such as:

• cooperating brokers;
• real estate professionals;
• property owners;
• landlords;
• buyers;
• sellers;
• developers;
• title companies;
• lenders;
• attorneys;
• inspectors;
• condominium or homeowners associations;
• property managers;
• other parties necessary to facilitate a transaction.

Affiliates

We may disclose certain information among affiliated Cosmore entities when reasonably necessary to provide services, manage operations, or respond to your request.

This does not include the sharing of SMS opt-in information or messaging consent for marketing or promotional purposes.

Legal and Regulatory Requirements

We may disclose information where reasonably necessary to:

• comply with applicable law;
• respond to a subpoena, court order, or lawful government request;
• comply with real estate licensing or regulatory obligations;
• prevent fraud or unlawful activity;
• protect legal rights;
• protect the safety of individuals;
• enforce agreements.

Business Transactions

If Cosmore is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction, certain business information may be disclosed as part of that transaction, subject to applicable law.

Any successor receiving personal information remains subject to applicable privacy obligations.

8. We Do Not Sell SMS Consent Data

Regardless of any other provision of this Privacy Policy:

Cosmore does not sell or share mobile telephone numbers, SMS opt-in records, or text messaging consent with data brokers, lead generators, advertisers, affiliates, or other third parties for their independent marketing or promotional purposes.

Consent provided to Cosmore to receive SMS messages applies only to the applicable Cosmore messaging program and is not transferable to another business for marketing purposes.

9. Cookies and Similar Technologies

Our websites may use cookies and similar technologies to:

• operate website functionality;
• remember user preferences;
• understand website traffic;
• measure marketing performance;
• improve website functionality;
• detect security issues.

Some cookies may be provided by third-party technology or analytics providers.

You may be able to control certain cookies through your browser settings or other privacy controls made available on our website.

Blocking certain cookies may affect website functionality.

10. Analytics and Advertising

We may use analytics and advertising technologies to understand how users interact with our websites and marketing campaigns.

These technologies may provide information such as:

• pages visited;
• advertisement interactions;
• referral source;
• browser or device information;
• aggregated website behavior.

Advertising platforms may use their own cookies or similar technologies subject to their own privacy policies.

SMS consent and mobile opt-in information are not provided to advertising platforms or third parties for their marketing or promotional purposes.

11. Social Media

Cosmore maintains profiles and marketing activities on social media platforms.

If you interact with Cosmore through a social media service, the platform may provide us with information consistent with your account settings and the platform’s privacy practices.

Your use of those services is separately governed by the privacy policies and terms of the applicable social media platform.

12. Recruiting and Join Cosmore

Real estate professionals may submit information through Cosmore’s recruiting pages, including the Join Cosmore application process.

Information submitted through this process may be used to:

• evaluate your interest in Cosmore;
• learn about your professional background;
• contact you regarding brokerage opportunities;
• schedule recruiting conversations;
• manage interviews;
• manage recruiting activities;
• communicate regarding joining Cosmore;
• maintain recruiting records.

Submitting a recruiting application does not guarantee affiliation with Cosmore.

If you separately elect to receive SMS communications during the recruiting process, the SMS provisions of this Privacy Policy apply.

13. Referrals

If you access Cosmore through a referral link, recruiter link, campaign link, or similar source, we may collect information regarding the source of your referral.

For example, we may record that you reached Cosmore through:

• a Cosmore agent;
• a recruiter;
• a referral partner;
• Instagram;
• another social media campaign;
• a specific recruiting advertisement.

This information may be used for attribution, recruiting administration, and internal analytics.

Referral attribution does not authorize the referral source to receive your SMS consent information for marketing purposes.

14. Security

Cosmore uses reasonable administrative, technical, and organizational measures designed to protect personal information against:

• unauthorized access;
• misuse;
• loss;
• alteration;
• disclosure;
• destruction.

No internet transmission or storage system can be guaranteed to be completely secure.

Users should use appropriate care when transmitting sensitive information electronically.

15. Data Retention

We retain personal information for as long as reasonably necessary for purposes including:

• providing requested services;
• maintaining transaction or recruiting records;
• satisfying legal or regulatory requirements;
• resolving disputes;
• enforcing agreements;
• maintaining appropriate business records.

Retention periods may vary based on the type of information and the purpose for which it was collected.

SMS consent and opt-out records may be retained as necessary to demonstrate and honor communication preferences.

16. Your Communication Preferences

You may request that we stop sending promotional email communications by using the unsubscribe mechanism contained in applicable emails.

For SMS:

Reply STOP to opt out.

You may also contact us at:

info@cosmore.com

A request to stop marketing communications will not necessarily prevent us from sending communications that are required or reasonably necessary in connection with an existing transaction, contractual relationship, or legal obligation.

17. Your Privacy Rights

Depending on where you reside and applicable law, you may have certain rights regarding your personal information, which may include the right to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of certain information;
• request information regarding how data is used or disclosed;
• withdraw certain consents;
• opt out of certain types of marketing communications.

These rights may be subject to exceptions or limitations under applicable law.

To submit a privacy request, contact:

info@cosmore.com

We may take reasonable steps to verify your identity before processing certain requests.

18. Do Not Track and Browser Privacy Controls

Some browsers or devices provide privacy preference signals.

Our response to such signals may vary depending on applicable law, available technology, and the nature of the signal.

You may also manage cookies through your browser settings.

19. Children’s Privacy

Cosmore’s websites and services are generally intended for adults interested in real estate, professional services, or real estate careers.

Our services are not directed to children under 13, and we do not knowingly seek to collect personal information from children under 13 through our general websites.

If we become aware that personal information from a child has been collected inappropriately, we may take reasonable steps to remove it.

20. Third-Party Websites

Our websites may contain links to third-party websites or services.

Cosmore does not control those third parties and is not responsible for their:

• privacy practices;
• security;
• website content;
• terms and conditions.

We encourage users to review the privacy policies of third-party websites before providing personal information.

21. International Users

Cosmore primarily operates in the United States but may interact with international clients, investors, and real estate professionals.

If you provide personal information from outside the United States, that information may be processed or stored in the United States or other jurisdictions where our service providers operate.

Privacy laws in those jurisdictions may differ from those in your country of residence.

22. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• changes to our practices;
• changes to our services;
• changes to applicable laws or regulations;
• changes to communication or technology requirements.

When we make changes, we will update the Effective Date displayed at the top of this Privacy Policy.

Where required by law, we may provide additional notice regarding material changes.

23. Terms and Conditions

Use of Cosmore websites and digital services may also be subject to our Terms and Conditions.

Our SMS messaging program is also subject to the applicable Terms and Conditions, including information regarding:

• program description;
• message frequency;
• message and data rates;
• opt-out instructions;
• customer support;
• carrier limitations.

The Terms and Conditions should be made available through a clearly labeled public link on the Cosmore website.

24. Contact Us

For questions regarding this Privacy Policy, your personal information, or your communication preferences, contact:

Email: info@cosmore.com

Website: www.cosmore.com

For SMS assistance, reply HELP to an applicable Cosmore text message or contact info@cosmore.com.

To stop receiving SMS messages, reply STOP.