JASON MITCHELL GROUP

PRIVACY POLICY

Last Updated: September 16, 2025

Jason Mitchell Group (“JMG,” “we,” “us,” or “our“) values your privacy and is dedicated to protecting your personal information while delivering the high-quality real estate services our clients expect. As evidenced by our thousands of 5-star ratings across Google, Zillow, and Realtor.com, we are committed to earning your trust. This Privacy Policy (“Policy“) explains our practices regarding the collection, use, disclosure, and retention of personal information (“PII“) through your interactions with https://thejasonmitchellgroup.com (the “Site“) and any services, products, platforms, features, or content we offer, including real estate brokerage, referral services, and related marketing activities (collectively, the “Services“). The Services are intended for use by United States residents only. Should our Services expand to users outside the U.S., we will comply with international privacy standards, such as the General Data Protection Regulation (GDPR), to ensure robust protection of your personal information. By using our Site or Services, you agree to the terms of this Policy. If you do not agree, please do not use our Site or Services.

1. Scope and Applicability

1. Policy Governance: This Policy governs our collection, use, processing, disclosure, and retention of PII and all other data obtained through any interaction with or access to the Services, via both digital and analog channels. This includes information gathered through our Agents or during in-person transactions when such information is aggregated with PII collected through our digital Services.
2. Definitions:
   1. “Affiliates” means any entity controlled by, controlling, or under common control with JMG, including real estate brokerages, title companies, or escrow companies with which JMG maintains business relationships.
   2. “Agents” refers to independent contractor licensed real estate salespersons or brokers engaged by JMG to provide real estate services.
   3. “Services” refer to the Site https://thejasonmitchellgroup.com and any services, products, platforms, features, or content offered by JMG, including but not limited to real estate brokerage, referral services, and related marketing activities
   4. “PII” refers to Personally Identifiable Information
   5. “SPI” refers to Sensitive Personal Information
3. Exclusions: This Policy does not apply to third-party websites, services, applications, or platforms (“Third-Party Services”) accessed via our Services or through hyperlinks on our Site. JMG is not liable for the privacy practices, data handling procedures, or content of Third-Party Services, including those provided by landlords, tenants, purchasers, vendors, Agents (outside our platform), or any other third parties. Users should review the privacy policies of any Third-Party Services they engage with. JMG does not control these third parties’ cookies, pixels, or tracking technologies or how they may be used
4. Agent Independence: This Policy does not govern interactions with Agents outside the scope of the Site or Services, which may be subject to separate privacy terms provided directly by those Agents. While Agents provide services under our guidance, their use of your information outside our platform is governed by their own privacy policies.

2. Information Collection and Processing

1. Categories of Information: We collect the following categories of information in connection with your interaction with our Services:
   1. User-Provided Information:
      1. Personal Identifiers: Name, date of birth, age, email address, mailing address, phone number, and geolocation data.
      2. Employment Information: Current and historical employment details, Social Security number, and demographic information.
      3. Financial Data: Credit card or payment information, bank statements, income tax returns, and gross commission income (“GCI“).
      4. Transaction-Related Information: Background check data, rental or purchase application details, and lease or purchase agreement information.
      5. Identification and References: Photo identification, reference letters, and property listing addresses.
      6. Supplementary Information: Additional data as required by law or shared with Agents to facilitate real estate transactions or referrals.
   2. Automatically Collected Information: IP address, search queries, cookie data, mobile device identifiers, pages or listings viewed, browsing history, and interactions with our Site.
   3. Cookie-Based Information: Small text files stored by your browser upon accessing our Site that assist in recognizing your browser, tracking usage patterns, and improving your experience. We use JMG’s use of cookies and third-party cookie usage to refine our Services. You may disable cookies in your browser settings, which might limit certain functionalities. We display a cookie consent banner upon first access, in compliance with applicable state privacy laws.
   4. Third-Party Information Sources: We may receive PII or other data from third-party services, including real estate platforms or social media entities, if you link your JMG account or consent to data sharing. This may encompass demographic and employment information or fraud detection data, which we may integrate with other information to personalize your experience.
   5. Agent-Provided Information: Our Agents may provide PII about you, including name, contact information, financial details, and transaction-related data, to facilitate real estate services or referrals. By submitting this information to Agents, you expressly consent to JMG’s storage and usage of it as outlined in this Privacy Policy.
2. Tracking Technologies: We may utilize tracking technologies, such as cookies and web beacons, to collect information about your online activities over time and across third-party websites. This data helps us debug technical issues, analyze user trends, and guide potential enhancements to our web and mobile platforms.
3. Data Minimization and Purpose Limitation: We collect only the information necessary to provide and improve our Services, as described in this Policy. We will not use your PII for purposes incompatible with those disclosed herein without your consent.

3. Use and Sharing of Information

1. Purpose and Scope: We use your information, including PII, to comply with applicable laws and regulations while enhancing the quality and efficacy of our Services, and as otherwise described at the point of collection or with your express consent.
2. Service Provision and Enhancement: We use your PII to deliver, maintain, and refine our Services, including brokerage and referral activities. We customize content, listings, or services to align with your preferences and enhance the overall user experience. We reserve the right to utilize your information as described at the point of collection or for any other purpose with your express consent.
3. Communications: We may engage you in interactive Service features and provide promotional information, subject to your preferences and applicable laws. If you consent to receive marketing communications from us, your information may be used to personalize and tailor those communications to your interests.
4. Communication and Transaction Facilitation: We may contact you regarding transactions, account management, or promotional activities. We use your information to facilitate requests, process payments, and enforce contractual agreements to which you are a party.
5. Policy and Service Updates: We will inform you of any material modifications to our Services or substantive changes to this Privacy Policy as necessitated by law or business practices.
6. Legal Compliance and Regulatory Adherence: We use your information to comply with all applicable legal requirements, including the Real Estate Settlement Procedures Act (RESPA), and to support referrals to Referral Partners, guaranteeing compliance with professional standards and applicable laws. This includes, but is not limited to, sharing information with relevant authorities or partners when required by law.
7. Research and Development: Your information may support research and development initiatives aimed at introducing new services or enhancing existing offerings.
8. Affiliates: We share PII with our Affiliates to enhance or deliver Services, including sharing your name, contact information, financial data, transaction information, and other necessary details in compliance with laws like RESPA.
9. Legal and Safety Purposes: Your PII may be disclosed to comply with legal processes, enforce our terms, address fraud, security, or technical issues, and protect the rights and safety of our company and its users, including information exchange with other entities for fraud prevention and compliance.
10. Business Transfers: In the event of mergers, acquisitions, or asset sales, your PII could be transferred as part of business assets, and you consent to such transfers.
11. Restrictions on Use:
    1. We will not sell your PII to third parties under any circumstances.
    2. We will not use your PII for creating profiles or conducting automated decision-making processes that may lead to legal or otherwise significant effects on you.
12. Respect for Privacy Choices: We respect web browser “Do Not Track” signals, and you may opt out of our tracking practices by contacting us at techteam@jasonmitchellgroup.com or by calling us at (833) 471-3337.
13. Data Retention Policy: We retain PII only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. We will securely dispose of PII that is no longer needed for these purposes.
14. Data Transfer Safeguards: If we transfer PII to third-party service providers or affiliates in other countries, we will ensure that appropriate safeguards are in place to protect the information, such as standard contractual clauses approved by the European Commission or other applicable data transfer mechanisms.
15. Tracking Practices: We may utilize tracking technologies, such as cookies and web beacons, to collect information about your online activities over time and across third-party websites. This data helps us debug technical issues, analyze user trends, and guide potential enhancements to our web and mobile platforms.

4. Google User Data

When you provide Google data, such as Gmail information, via our Services, JMG ensures its usage complies with the Google API Services User Data Policy, including the Limited Use requirements:

1. Email Functionality: We use Gmail data solely to provide email client functionality, such as composing, sending, and reading emails.
2. Data Sharing: We do not transfer Gmail data to third parties except when necessary for service provision, legal compliance, or business transfer scenarios.
3. Advertising: We do not use Gmail data for advertising purposes.
4. Human Access: Human access to Gmail data is restricted unless you provide consent, or it is essential for security, compliance, or anonymized internal operations.
5. Gmail Data Usage: We will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails. We will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
6. Human Data Access: We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations, and even then only when the data have been aggregated and anonymized. Your Google Data is subject to the terms in the Google Privacy Policy.
7. Third-Party Tracking Control: We do not control these third parties’ cookies, pixels, or tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. If you wish to delete your linked account with a platform such as Facebook, you can make a request by emailing us at techteam@jasonmitchellgroup.com and requesting the deletion of your account
8. Adherence to Policy: JMG’s use of data received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

5. Data Security

1. Data Security Measures: JMG employs industry-standard administrative, technical, and physical safeguards, including encryption protocols, firewalls, intrusion detection systems, and access controls, to protect the confidentiality, integrity, and availability of your PII.
2. User Responsibilities: You are responsible for maintaining the confidentiality and security of your account credentials, including selecting strong passwords, signing off after each use, and limiting access to your computer and browser.
3. Security Limitations: Despite JMG’s security measures, unauthorized access, hardware or software failures, and other external factors may compromise the security of your information. You acknowledge and accept these inherent limitations.
4. Liability Disclaimer: JMG will not be held legally, financially, or otherwise liable for security breaches, data leaks, or other incidents arising from:
   1. Your use of third-party services, external service providers, Agents, or Affiliates.
   2. Unauthorized access, cyberattacks, or other security incidents attributable to your failure to secure your account or maintain the confidentiality of your credentials.
5. Proactive Security Measures: JMG advises vigilance and proactive security measures on your part to minimize risks associated with data security. You are encouraged to adopt best practices to safeguard your account and personal information.
6. Regular Security Assessments: We will conduct regular security assessments and penetration testing to identify and remediate potential vulnerabilities in our systems and applications.

6. User Rights and Choices

1. Access, Modification, and Deletion: You are entitled to access and modify certain PII associated with your JMG account. You may also request the deletion of your data or the permanent termination of your account by submitting a written request to techteam@jasonmitchellgroup.com. Upon updating your information, JMG may retain archival copies for internal record-keeping and compliance purposes.
2. Limitations and Exceptions: JMG reserves the right to deny or fulfill requests, in whole or in part, based on its legal rights and obligations. We may retain certain information to comply with legal, regulatory, or operational requirements, as permitted by applicable law. We will respond to all requests within the timeframes required by applicable law.
3. State-Specific Rights: Residents of California (CCPA/CPRA), Connecticut, Colorado, New Jersey, Texas, and Virginia are afforded specific rights regarding their personal information. These include:
   1. Right to Know: Request disclosure of the categories and specific pieces of PII collected, used, or shared.
   2. Right to Delete: Request deletion of PII, subject to legal or operational exceptions.
   3. Right to Correct: Request correction of inaccurate or incomplete PII.
   4. Right to Opt-Out: Opt-out of the sharing or sale of PII to third parties.
   5. Right to Non-Discrimination: Exercise these rights without facing discrimination.
      
      

The following table summarizes these rights:

JMG is committed to following procedures on right to know, right to delete, right to opt-out, right to correct, and non-discrimination. For additional details, visit https://thejasonmitchellgroup.com/privacy.

1. Right to Opt-Out of Sale and Sharing of PII: JMG acknowledges that you have a right to opt-out of having your personal information sold to or shared with third parties.
2. Opt-Out of Targeted Advertising: As a consumer, you have the right to opt-out of targeted advertising. When you opt out, third party advertising companies will not receive your personal information that may be used in order to send you targeted advertisements.
3. Submitting Requests: Residents of the aforementioned states may submit verified consumer requests through the following channels:
   1. Email: By contacting JMG at techteam@jasonmitchellgroup.com.
   2. Phone: By calling JMG’s toll-free number at (833) 471-3337.
4. Appeals Process: If a request is denied, residents may appeal the decision by contacting JMG through the same channels outlined above. JMG will review the appeal and provide a response in accordance with applicable legal requirements.
5. Authorized Agents: You may designate an Authorized Agent to submit requests on their behalf. To do so, the following steps must be completed:
   1. Provide the Authorized Agent with written permission to act on your behalf.
   2. Verify your identity directly with JMG.
   3. Submit the required documentation, including a signed affidavit (available via JMG’s webform), or email proof of authorization and identification to techteam@jasonmitchellgroup.com. Failure to comply with these requirements may result in the denial of the request.

7. Protection of Children’s Privacy

1. COPPA Compliance: We are committed to complying with the Children’s Online Privacy Protection Act (COPPA) and other relevant laws designed to safeguard the privacy and security of children.
2. Prohibition on Collection of Minor Data: JMG does not knowingly collect, use, share, or sell the personal information of individuals under the age of 16. JMG’s services are not intended for use by individuals under the age of 16, and JMG does not target its services to this demographic.
3. Parental or Guardian Notification: If JMG becomes aware that it has inadvertently collected personal information from a minor under the age of 16, JMG will take immediate steps to delete such information from its systems and notify the minor’s parent/guardian

If you believe your child’s personal information has been collected by JMG, please contact our team at techteam@jasonmitchellgroup.com to request the removal of the data.

8. Direct Mail

1. JMG’s Policy on Direct Mail: JMG does not engage in the practice of sending direct mail advertisements to individuals. However, independent Agents affiliated with JMG may utilize third-party services, such as USPS Every Door Direct Mail (EDDM), to distribute mailers to households within specific zip codes.
2. Nature of Agent Mailers: These mailers are not addressed to specific individuals and are distributed on a non-targeted, geographic basis. As such, they are not subject to opt-out requests under JMG’s privacy policy or applicable direct mail regulations.
3. Opt-Out Requests: If you wish to opt out of receiving mailers from a specific Agent, you must contact the Agent directly. To assist, you may submit an opt-out request by emailing techsupport@jasonmitchellgroup.com, and we will forward your request to the relevant Agent or provide contact details for the Agent upon request to streamline the process. JMG is not responsible for managing or facilitating opt-out requests related to mailers distributed by its Agents, but we aim to streamline this process for your convenience.

9. Policy Updates and Notifications

1. Periodic Review and Updates: JMG is committed to maintaining the accuracy and relevance of its Privacy Policy. To ensure compliance with evolving legal standards and operational practices, JMG conducts a comprehensive review of its Privacy Policy at least annually. Updates may also be made periodically to reflect changes in how JMG collects, uses, or shares personal information.
2. Notice of Material Changes: In the event of material changes to this Privacy Policy, JMG will determine the most appropriate method of notification, commensurate with the significance of the update. Notification methods may include but are not limited to, prominent posting on JMG’s website, email communications, or other direct outreach to consumers.
3. Consumer Awareness: JMG encourages consumers to periodically review the Privacy Policy to stay informed about how their personal information is being handled. Continued use of JMG’s services following the posting of updates constitutes acceptance of the revised Privacy Policy.

10. Contact Information

For questions or concerns regarding privacy, contact us at:

• Email: techteam@jasonmitchellgroup.com and copy legal@jasonmitchellgroup.com
• Phone: (833) 471-3337
• Mail: Jason Mitchell Group, LLC, 3080 N Civic Center Plaza, Suite 100, Scottsdale, AZ 85251

Additional Compliance Measures:

1. Data Breach Response Plan: We have implemented a comprehensive data breach response plan that includes procedures for identifying, containing, and mitigating data breaches, as well as notifying affected individuals and regulatory authorities as required by applicable laws.
2. Vendor Management Program: We have established a vendor management program to ensure that our third-party service providers adhere to our data security and privacy standards. We conduct due diligence on our vendors and monitor their compliance with our requirements.
3. Employee Training: We provide regular training to our employees on data security and privacy best practices, including the proper handling of PII and the importance of complying with this Privacy Policy.
4. Regular Monitoring and Testing: We regularly monitor our systems and networks for security vulnerabilities and conduct penetration testing to identify and address potential weaknesses.

By accessing or using the Site or Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Policy, you must not use our Site or Services.