Privacy Policy

Effective Date: February 5, 2026 · Last Updated: March 2026

1. Introduction

TurboBroker™ ("we," "us," or "our") operates the platform available at turbobroker.ai. This Privacy Policy describes how we collect, use, store, disclose, and protect your personal information when you use our AI-powered transaction coordination platform designed for licensed real estate professionals.

This policy applies to all users of our services, including account holders, transaction parties whose information appears in uploaded documents, and any other individuals whose personal information we process in connection with our services.

By accessing or using TurboBroker, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this policy, please do not use our services.

2. Information We Collect

We collect the following categories of information to provide and improve our services:

Account Information

Your name, email address, phone number, DRE license number, and brokerage information provided during registration and account setup.

Transaction Data

Property addresses, purchase prices, contract dates, contingency periods, escrow details, and party information associated with your real estate transactions.

Documents

PDFs of purchase agreements, listing agreements, counter offers, disclosures, and other documents you upload to the platform.

Usage Data

Information about how you interact with the platform, including feature usage patterns, pages visited, and actions taken within the application.

Communication Data

Messages sent through our platform via SMS and voice services, and emails sent on your behalf or to you, including message content, timestamps, and delivery status.

Voice Call Data

When you use our AI-powered voice call features, calls may be processed by AI service providers in real time to facilitate the conversation. We collect call metadata such as call duration, timestamps, and caller identification. Voice calls are not recorded or stored by TurboBroker. See Section 5 for additional details.

AI Interaction Data

Queries and instructions you provide to our AI assistant, along with AI-generated responses, summaries, and extracted data produced by our system.

CRM Data

Contact information you import or create in the CRM, including names, email addresses, phone numbers, lead stage, tags, notes, follow-up dates, and communication preferences. This also includes activity logs such as emails sent, calls made, and drip campaign interactions associated with your CRM contacts.

Form Layout Metadata

When you create or save custom form field configurations in the Form Builder (such as field positions, field types, and signer role assignments), we collect the structural layout data associated with those configurations. This metadata describes where fields are located on a form (coordinates, dimensions, and field type such as “signature” or “date”) and which signer role each field is assigned to. This metadata does not include any document content, client names, transaction details, financial information, or other personal data.

Disclosure Package Viewer Data

When a listing agent shares a public disclosure link, third-party viewers (such as buyer agents and prospective buyers) may voluntarily register to view disclosure documents. Registration data includes name, email address, phone number, brokerage name, and viewer type. We also collect IP addresses and track which documents each viewer opens. This data is shared with the listing agent who created the disclosure package and is retained with the transaction.

Email Signature and Bot Avatar Data

If you configure a custom email signature, we store the structured signature data (name, title, brokerage, phone, links) associated with your profile. If you generate a custom bot avatar (T1+ and above), we store the AI-generated avatar image in your account's storage. Avatar generation is subject to a 14-day cooldown period.

Geolocation Data (Limited)

We collect property addresses associated with your transactions. We do not collect precise geolocation data from your device.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Provide and improve our transaction coordination services, including document management, task tracking, and deadline monitoring.
  • Extract and organize data from uploaded documents using automated processing technology to auto-populate transaction fields, detect signatures, and identify document types.
  • Use de-identified form layout metadata (such as field coordinates, field types, and signer role assignments) from the Form Builder to improve document processing accuracy. This metadata contains no personal information, document content, or transaction details.
  • Generate automated task lists, deadline tracking alerts, and compliance notifications based on your contract dates and applicable real estate regulations.
  • Draft and send communications on your behalf via SMS, email, and voice to transaction parties, including reminders, status updates, and deadline alerts.
  • Facilitate electronic signature workflows for transaction documents.
  • Manage your CRM contacts, automate drip campaigns, and provide AI-assisted communication drafting.
  • Process payments and manage subscriptions for your account.
  • Comply with applicable real estate regulations, including document retention requirements and disclosure obligations.

4. Automated Decision-Making and AI Processing

TurboBroker uses AI language models and automated processing technology to provide its services. We believe in transparency about how these systems work and your rights regarding automated decisions.

How AI Is Used

  • Document classification: AI systems automatically identify document types (e.g., purchase agreements, disclosures) and extract key data fields such as dates, prices, and party names.
  • Communication drafting: AI systems draft email and SMS responses on behalf of your account based on transaction context. Some communications may be sent without human review when the system determines a high confidence level.
  • Task generation: AI systems analyze contract dates and terms to automatically generate task checklists and deadline reminders.
  • CRM assistance: AI systems draft personalized follow-up communications and manage drip campaign messaging based on contact stage and interaction history.
  • Voice call processing: AI systems may process voice calls in real time to facilitate conversations. Calls are not recorded or stored.

Confidence-Based Auto-Send

Certain AI-drafted communications (such as routine status updates and deadline reminders) may be sent automatically without human review when the system assigns a high confidence score. Communications that involve sensitive topics, complex negotiations, or lower confidence scores are held for your review before sending. You can configure your auto-send preferences in your account settings.

Your Right to Human Review

You have the right to request human review of any automated decision made by our AI systems. You may also disable auto-send functionality at any time through your account settings, requiring manual approval of all AI-drafted communications. To request human review of a specific automated decision, contact us at support@turbobroker.ai.

5. Voice Call Processing

TurboBroker provides AI-powered voice call capabilities as part of its transaction coordination services. This section discloses our practices regarding voice call processing.

No Voice Recording

TurboBroker does not record or store voice calls. Voice audio is streamed to AI service providers in real time for conversational processing only. Once the call ends, no audio data is retained by TurboBroker or its AI service providers.

  • Call audio is transmitted to AI service providers in real time to facilitate the conversation. Audio is processed in-stream and is not recorded or stored.
  • Call metadata (duration, timestamps, caller identification) is logged for transaction coordination and compliance purposes.
  • At the start of each voice call, participants are informed that they are speaking with an AI assistant acting on behalf of a licensed real estate agent.
  • We do not create, store, or use voiceprints or other biometric identifiers derived from voice call audio. We do not use voice data to identify, authenticate, or profile individuals based on their vocal characteristics.
  • Voice call metadata is retained in accordance with our communication log retention schedule (3 years).

6. Data Storage and Retention

We take data storage and retention seriously, particularly given the regulatory requirements of the real estate industry.

Data TypeRetention Period
Transaction documentsMinimum required by applicable state law (3-8 years depending on state; see below)
Archived transactionsSame as transaction documents
Communication logs (SMS/email)3 years
Voice call metadata (duration, timestamps)3 years (same as communication logs)
AI response logs2 years
CRM contacts and activitiesUntil deleted by user or account closure
Disclosure package viewer dataSame as transaction documents (retained with the transaction)
Transaction compliance recordsRetained per applicable regulatory requirements; may persist after transaction deletion
Webhook and system logs90 days
Error logs30 days

Real estate document retention requirements vary by state. Examples include: 3 years in California (Cal. Bus. & Prof. Code Section 10148), 4 years in Texas and Colorado, 5 years in Florida, Arizona, Illinois, and others, 6 years in Oregon, Minnesota, New Jersey, and others, 7 years in Connecticut, and 8 years in Montana. When a transaction involves parties or properties in multiple jurisdictions, we apply the longest applicable retention period. Our platform retains documents indefinitely by default to exceed all state requirements. The IRS also recommends retaining real estate transaction records for at least 7 years.

All data is stored on secure cloud infrastructure with encryption at rest (AES-256) and in transit (TLS 1.3). Documents are stored in encrypted cloud storage with access controls.

Inactive and Suspended Account Data Policy

Free-tier (T1) accounts: Accounts with no new transactions for 90 consecutive days are considered inactive. We will send email notifications at 30 days, 15 days, and 3 days before data removal. If no action is taken (creating a new transaction, downloading files, or upgrading to a paid plan), all transaction data, documents, communication logs, and associated resources will be permanently deleted. The account record itself is retained so you can sign back in and start fresh at any time.

Paid-tier (T1+, T2, T3) accounts: Active paid accounts receive indefinite data retention. If your subscription lapses (payment failure, cancellation, or administrative action), your account enters a 90-day read-only suspension period. During this period, you can sign in and download your files. Your dedicated phone number is released after 30 days. If the subscription is not reactivated within 90 days, data will be permanently removed following the same warning schedule (30, 15, and 3 days before removal). Team members on suspended accounts may split off into independent accounts to preserve their data.

Your responsibility: TurboBroker is a software tool, not a licensed broker, and does not assume your statutory record-keeping obligations. We strongly recommend downloading and independently storing your transaction documents, as real estate regulations require brokers to retain records for 3-8 years depending on the state (IRS recommends 7 years).

Deletion vs. Regulatory Retention

You may delete documents and transactions at any time. Deletion permanently removes the data from our systems, except that certain compliance records documenting transaction history may be retained as required by applicable real estate regulations, tax law, or other legal obligations. We recommend archiving transactions instead of deleting them, as archived data is retained in compliance with applicable real estate regulations in all 50 states. For deletion requests under the CCPA, VCDPA, CPA, CTDPA, TDPSA, or any other applicable state privacy law, we will honor your request except where retention is required by law. We encourage users to maintain records beyond the minimum regulatory period, as longer retention may be beneficial for legal protection.

7. CRM Data Retention

CRM data is subject to the following retention and portability practices:

  • CRM contacts and associated activity data are retained for as long as your account is active, or until you manually delete individual contacts.
  • Upon account closure or subscription cancellation, you have a 90-day post-departure access window during which you may export your CRM data in a portable, machine-readable format (CSV).
  • After the 90-day post-departure window, CRM data is either anonymized or permanently deleted in accordance with your account settings and applicable law.
  • Drip campaign logs and automated communication history associated with CRM contacts are retained for the same period as the underlying contact record.
  • You may request a full export of your CRM data at any time through your account settings or by contacting us.

8. Third-Party Service Providers

We use the following categories of third-party service providers to operate our platform. Each provider processes data only as necessary to perform its specific function and is bound by contractual data protection obligations:

Supabase (Cloud Infrastructure)PostgreSQL database hosting, file storage, authentication, and row-level security
Vercel (Application Hosting)Application deployment, serverless functions, and edge network delivery
OpenAI (AI Processing)Document data extraction (GPT-5.2), conversational AI assistant, voice call processing, automated communication drafting, and bot avatar generation (DALL-E 3)
Azure Document Intelligence (Document Analysis)PDF layout analysis, text extraction, form field detection, and checkbox state recognition
Twilio (SMS & Voice)SMS messaging, voice call routing, and phone number management
SendGrid (Email)Transactional and automated email delivery on behalf of users
DocuSign (Electronic Signatures)Electronic signature processing, document signing workflows, and envelope management
Google Places API (Vendor Directory)Vendor search and business information for the Vendor Directory feature
Railway (Voice Server)Hosting for the real-time voice AI WebSocket server
Natural Hazard Disclosure ProvidersNHD report ordering and delivery for transaction compliance

We do not sell, rent, or trade your personal information to third parties. Data is shared with these service providers only to the extent necessary to provide our platform's functionality. Form Builder layout metadata (field coordinates, types, and signer role assignments) is processed and stored internally and is never shared with AI service providers or any third party.

TurboBroker may offer integrations with external CRM platforms and other third-party services in the future. When you choose to connect an external service, data may be synced bidirectionally between TurboBroker and the external service. Data synced to or from external platforms is subject to those providers' respective privacy policies and terms of service. You are responsible for reviewing and accepting those terms before enabling any external integration.

9. Do Not Sell or Share My Personal Information

We do not sell your personal information as defined under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). We do not share your personal information for cross-context behavioral advertising purposes.

A "Do Not Sell or Share My Personal Information" link is available in the footer of our website and within your account settings. Although we do not sell or share personal information, we provide this mechanism to ensure full compliance with applicable law.

Universal Opt-Out Mechanism (Global Privacy Control)

We honor Global Privacy Control (GPC) signals transmitted by your browser. When we detect a GPC signal, we treat it as a valid opt-out request under the CCPA/CPRA and any other applicable state law that recognizes universal opt-out mechanisms. No further action is needed on your part if you have GPC enabled in your browser.

10. Communications and Opt-Out

TurboBroker sends communications through multiple channels on behalf of our users. We are committed to respecting the communication preferences of all recipients.

  • SMS communications are sent from registered phone numbers associated with your TurboBroker account.
  • Recipients can opt out of SMS communications at any time by replying STOP to any message.
  • Email communications include unsubscribe links in compliance with the CAN-SPAM Act and applicable state laws.
  • We comply with the Telephone Consumer Protection Act (TCPA) for all SMS and voice communications and the CAN-SPAM Act for all email communications.
  • We do not send communications during prohibited hours as defined by applicable federal and state regulations.
  • Voice calls include an AI disclosure at the start of each call, informing participants that they are speaking with an AI assistant.

AI/Bot Disclosure (SB 1001 Compliance)

In compliance with California SB 1001 (Cal. Bus. & Prof. Code Section 17941) and Maine Revised Statutes Title 10 Section 1498, the first outbound communication sent to any new party through TurboBroker includes a disclosure that the message was generated or assisted by an AI system acting on behalf of the licensed agent. For voice calls, the AI assistant identifies itself as AI at the beginning of each call and provides the supervising agent's name and contact information. Recipients may contact the licensed agent directly at any time.

11. Cookies and Tracking Technologies

TurboBroker uses a minimal set of cookies and similar technologies strictly necessary for the operation of our platform:

Cookie TypePurposeDuration
Authentication cookiesMaintain your login sessionSession / 30 days
Session tokensSecure API communicationSession
Preference cookiesStore your display preferences (e.g., theme)1 year
Language preference (NEXT_LOCALE)Store your selected language (English, Spanish, or French)1 year

We do not use third-party analytics or advertising cookies. We do not engage in cross-site tracking or retargeting.

Do-Not-Track: We honor Do-Not-Track (DNT) browser signals. Because we do not engage in third-party tracking, our practices are consistent with DNT regardless of your browser setting.

12. Your Privacy Rights

Depending on your state of residence, you may have some or all of the following rights under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and other applicable state privacy laws, including those in Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Florida (FDBR), Iowa (ICPA), Delaware (DPDPA), Nebraska (NDPA), New Hampshire (NHPA), New Jersey (NJCPA), Tennessee (TIPA), Minnesota (MCDPA), Maryland (MODPA), Indiana (ICDPA), Kentucky (KCDPA), and Rhode Island (RIDPA):

Right to Know / Access

You have the right to request information about the categories and specific pieces of personal information we have collected about you, the purposes for collection, the sources of collection, and the categories of third parties with whom we share it.

Right to Delete

You have the right to request that we delete the personal information we have collected from you. We will honor deletion requests except where retention is required by law (such as state-mandated real estate document retention requirements, which range from 3 to 8 years depending on the state) or necessary to maintain compliance records. See Section 6 for details on retention obligations.

Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you. You may also correct certain information directly through your account settings.

Right to Data Portability

You have the right to receive a copy of your personal information in a portable, machine-readable format (such as CSV or JSON). This includes transaction data, CRM contacts, communication logs, and account information.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use and disclosure of your sensitive personal information to only what is necessary to provide the services you have requested. To exercise this right, contact us at the address below.

Right to Opt-Out of Sale/Sharing

You have the right to opt out of the sale of your personal information and the sharing of your personal information for cross-context behavioral advertising. We do not engage in either practice.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. You will not receive different pricing, service quality, or access levels for exercising your rights.

Right to Opt-Out of Automated Decision-Making

You have the right to opt out of automated decision-making, including profiling, that produces legal or similarly significant effects. You may request human review of automated decisions by contacting us. See Section 4 for details.

To exercise any of these rights, please contact us at support@turbobroker.ai. We will respond to verifiable consumer requests within 45 days. If we need additional time (up to 90 days total), we will notify you of the extension and the reason.

You may submit up to two (2) verifiable consumer requests per 12-month period. We will verify your identity before processing any request by confirming your account credentials or, for non-account holders, by matching identifying information you provide against information we already maintain.

Minnesota Residents

If you are a Minnesota resident, you have the right to question the results of any profiling we conduct, request the rationale behind automated decisions, and be informed of what actions may result in a different outcome.

Oregon Residents

If you are an Oregon resident, your right to delete extends to derived data (inferences drawn from your personal information), subject to legal retention obligations.

Sensitive Personal Information

Under the CCPA/CPRA, "sensitive personal information" includes Social Security numbers, financial account numbers, precise geolocation, racial or ethnic origin, religious beliefs, biometric data, health information, and contents of private communications. TurboBroker may process financial information (purchase prices, loan amounts) that appears in uploaded real estate documents. We do not collect Social Security numbers, biometric data, or health information. We use sensitive personal information only as necessary to provide the transaction coordination services you have requested and do not use it for profiling or advertising purposes. You have the right to limit our use of sensitive personal information as described above.

Disclosure Package Viewer Data Deletion

Third-party viewers who registered to view disclosure packages (buyer agents, prospective buyers) may request deletion of their viewer data (name, email, phone, brokerage, IP address, and viewing history) by contacting us at support@turbobroker.ai. We will honor deletion requests within 45 days, except where retention is required for an active transaction or legal compliance.

Sub-User Privacy Rights (Team and Brokerage Accounts)

If you are a sub-user (agent or assistant) on a Team (T2) or Brokerage (T3) account, you retain the same privacy rights described in this section with respect to your personal data. Your account administrator may access transaction data and communication logs associated with your account activity for business oversight purposes, but cannot access or modify your personal profile information, password, or privacy preferences. Upon departure from a shared account, you may request a data export of your personal information and CRM contacts (subject to administrator approval for shared contacts). See our Terms of Service Section 10B for CRM data portability details.

13. Categories of Personal Information (CCPA/CPRA)

The following table describes the categories of personal information we collect, the sources from which we collect it, the business purposes for collection, and the categories of third parties with whom we may share it:

CategorySourcesBusiness PurposeThird Parties
Identifiers (name, email, phone, DRE license)Directly from you; from uploaded documentsAccount creation, communication, transaction coordinationCommunication service providers, electronic signature providers
Professional information (license, brokerage)Directly from youAccount verification, complianceNone
Financial information (in documents)Uploaded documentsTransaction coordination, document extractionAI service providers (for extraction), cloud infrastructure providers
Communications data (SMS, email, voice)Platform communicationsTransaction coordination, compliance, record-keepingCommunication service providers, AI service providers
Voice call metadata (duration, timestamps, caller ID)Voice calls through platformTransaction coordination, compliance record-keepingCommunication service providers
Usage / interaction dataAutomatically collectedService improvement, securityCloud infrastructure providers
Form layout metadata (field coordinates, types, roles)User-created form configurations in Form BuilderImprove document processing accuracy for all usersNone
Geolocation (property addresses only)Uploaded documents; directly from youTransaction coordination, NHD report orderingNatural hazard disclosure providers

We have not sold personal information in the preceding 12 months. We do not share personal information for cross-context behavioral advertising.

14. Authorized Agent Requests

You may designate an authorized agent to submit privacy rights requests on your behalf. To do so, you must:

  • Provide the authorized agent with written, signed permission to act on your behalf.
  • Verify your own identity directly with us (we may contact you to confirm the request).
  • Submit the agent's authorization along with the privacy rights request to support@turbobroker.ai.

Alternatively, if you have provided your agent with a power of attorney pursuant to California Probate Code Sections 4000 to 4465, we may accept the agent's request without separately verifying your identity.

15. AI Model Training Disclosure

In accordance with the Connecticut Data Privacy Act (CTDPA) and other applicable state laws:

We do not use your personal data to train large language models or other generative AI systems. Your documents, communications, transaction data, CRM contacts, and other personal information are processed by AI service providers solely to provide the services you have requested (such as document extraction, communication drafting, and task generation). Your data is not used to improve, fine-tune, or train the underlying AI models used by our service providers. We contractually require our AI service providers to maintain the same restriction.

Separately, when you save form field configurations in the Form Builder, de-identified structural metadata (field coordinates, types, and role assignments) may be used to improve our document processing accuracy. This metadata does not contain personal information, document content, or transaction details, and its use is distinct from AI model training.

16. Data Security

We implement industry-standard security measures to protect your information:

Encryption in Transit
TLS 1.3 for all data transmission
Encryption at Rest
AES-256 for stored data and documents
Access Control
Row-level security on all database tables
API Protection
Rate limiting and authentication on all endpoints
Security Audits
Regular audits of infrastructure and code
Authentication
Secure session management with multi-factor support

17. Data Breach Notification

In the event of a data breach involving your personal information, we will notify affected individuals in accordance with applicable state and federal breach notification laws. We will provide notification within 30 days of discovering a breach, consistent with the most restrictive applicable state deadline. Where required by law, we will also notify the applicable state attorney general or other regulatory authority.

Our breach notification will include:

  • A description of the nature of the breach, including the categories of personal information involved.
  • The approximate date and time of the breach, if known.
  • A description of the steps we have taken or plan to take in response to the breach.
  • Contact information for our privacy team so you can ask additional questions.
  • Recommendations for steps you can take to protect yourself from potential harm.

Notifications will be provided in the most expedient time possible and without unreasonable delay, consistent with any legitimate needs of law enforcement and any measures necessary to determine the scope of the breach and restore the integrity of our systems.

18. International Data Transfers

TurboBroker is operated in the United States. All personal information collected through our platform is processed and stored in the United States.

If you access our services from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence. By using our services, you consent to the transfer of your information to the United States and acknowledge that your information will be subject to United States law.

19. Children's Privacy

TurboBroker is designed exclusively for licensed real estate professionals and is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to promptly delete that information.

In some cases, information about minors may appear in uploaded real estate documents (for example, as trust beneficiaries or dependents named in transaction paperwork). Such information is processed only for the purpose of transaction coordination and is subject to the same security protections and retention policies as all other data on the platform. We do not use information about minors for any marketing or profiling purpose.

20. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by posting the updated policy on our website, updating the "Last Updated" date at the top of this page, and, where required by applicable law, sending you a notification via email or in-app alert. We encourage you to review this policy periodically.

Last updated: March 2026.

21. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or need to submit a complaint, please contact us:

TurboBroker™ Privacy Team

Email: support@turbobroker.ai

TurboBroker™, [Address TBD], Delaware

We will respond to verifiable consumer requests within 45 days. If we need additional time (up to 90 days total), we will notify you of the extension and the reason. For urgent privacy concerns, please include "URGENT" in your email subject line.