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By providing your contact information to Foster Real Estate Services, LLC, DBA as Paul Wesley Real Estate , your personal information will be processed in accordance with Foster Real Estate Services, LLC, DBA as Paul Wesley Real Estate 's Privacy Policy. By checking the box(es) below, you expressly consent to receive marketing or promotional real estate communication from Foster Real Estate Services, LLC, DBA as Paul Wesley Real Estate in the manner selected by you. For SMS text messages, message frequency varies. Message and data rates may apply. Consent is not a condition of purchase of any goods or services. You may opt out of receiving further communications from Foster Real Estate Services, LLC, DBA as Paul Wesley Real Estate at any time. To opt out of receiving SMS text messages, reply STOP to unsubscribe. SMS text messaging is subject to our Terms of Use.

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Privacy Policy

Paul Wesley Real Estate

Privacy Policy


Effective Date: March 10, 2026 Last Updated: March 10, 2026

1. Introduction

Paul Wesley Real Estate, LLC ("Paul Wesley Real Estate," "we," "our," or "us") is a luxury residential real estate brokerage headquartered in McLean, Virginia, licensed to operate in Virginia, Maryland, and the District of Columbia. We serve buyers, sellers, and investors throughout the greater Washington, D.C. metropolitan area.

This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our website (the "Site"), contact us about buying or selling real estate, engage our agents, use any of our services, or otherwise interact with us. It also explains your rights regarding that information and how to exercise them.

Please read this policy carefully. By using our Site or services you acknowledge that you have read and understood the practices described here. If you do not agree, please do not use our Site or services.


Technology Note: Our Site and digital services are powered by Luxury Presence, Inc. and other technology partners who process personal information on our behalf as service providers. This is the Privacy Policy of Paul Wesley Real Estate, LLC. It is not the privacy policy of Luxury Presence, Inc. or any other technology vendor.


2. Scope of This Policy

This Privacy Policy applies to personal information we collect through:

  • Our website and any associated pages or subdomains
  • Email, telephone, text message, and written correspondence between you and us
  • Our social media pages on Facebook, Instagram, LinkedIn, and similar platforms
  • In-person interactions in connection with real estate services in Virginia, Maryland, and D.C.
  • Transaction documents: listing agreements, buyer representation agreements, purchase contracts, disclosure forms, and related real estate records
  • Electronic documents executed through SkySlope or other transaction management systems

This Policy does not apply to information collected by third parties whose websites you may navigate to from our Site, nor does it apply to our handling of agent or employee records, which are governed by separate policies.


3. Information We Collect

3.1 Information You Provide Directly

When you interact with us — through our website, in person, by phone, or in writing — you may provide:

  • Identity and contact information: name, postal address, email address, and telephone number
  • Real estate preferences: property type, price range, desired neighborhoods, home search criteria, lifestyle priorities, and financing status
  • Property information: details about property you own or are considering selling, including address, condition, listing history, and improvements
  • Transaction information: contract terms, offer and counteroffer details, inspection contingencies, closing dates, and related transaction records
  • Electronic signature data: when you sign listing agreements, buyer agreements, purchase contracts, or disclosure documents through SkySlope, your signature, device information, and timestamp are captured and retained as part of the transaction record
  • Communications: messages, feedback, property inquiries, and other correspondence you send to us or to our agents
  • Marketing preferences: consents and opt-ins for email, SMS, and telephone communications

3.2  Information Collected Automatically

When you visit our Site, we and our technology partners automatically collect:

  • Device and browser data: IP address, browser type and version, operating system, screen resolution, and device identifiers
  • Usage data: pages viewed, time spent on pages, navigation paths, property search queries, and links clicked
  • Location data: general geographic location inferred from your IP address; precise location data is collected only with your express consent through your device settings
  • Advertising interaction data: whether you have clicked on or interacted with our advertisements on Google or Meta/Facebook platforms
  • Cookies and similar technologies: as further described in Section 6

3.3  Information from Third-Party Sources

We may receive information about you from:

  • Public property records: ownership records, tax assessments, deed history, and other publicly available real estate data maintained by Virginia, Maryland, and D.C. county and government agencies
  • Multiple Listing Services (MLS): listing data, showing history, days on market, and related cooperative transaction records
  • External lead platforms: if you inquire about a property through a third-party portal (such as Zillow, Realtor.com, Homes.com, or similar services), information you provide to that platform may be forwarded to us and entered into our client relationship management system. Those platforms' privacy policies govern their own data collection practices
  • Referral sources: other agents, brokers, and past clients who refer prospective clients to us
  • Social media platforms: when you interact with our pages on Facebook, Instagram, LinkedIn, or other platforms, in accordance with those platforms' privacy policies
  • Analytics and advertising partners: Google and Meta may provide aggregated or pseudonymous data about website and advertising performance, as described in Section 6

4. How We Use Your Information

We use the information we collect for the following purposes:

  • Providing real estate services: representing you in the purchase or sale of real property; preparing, presenting, and negotiating offers; coordinating inspections, appraisals, and closings; and managing the full transaction lifecycle from initial contact through settlement
  • Client communications: responding to inquiries, sending property recommendations and updates, providing comparative market analyses, and communicating about active transactions via phone, email, and text message in accordance with your communication preferences and applicable law
  • Marketing: sending property alerts, market reports, community news, and other information that may be of interest to you, subject always to your opt-out rights under Section 7
  • Lead management: organizing, tracking, and following up on client inquiries within our Follow Up Boss CRM system to ensure timely and consistent service
  • Site operation and improvement: analyzing usage patterns, troubleshooting technical issues, measuring the effectiveness of our advertising campaigns, personalizing your experience, and continuously improving our Site and services
  • Transaction management: processing documents, coordinating with cooperating agents, title companies, lenders, and settlement attorneys, and maintaining required real estate transaction records in SkySlope
  • Legal and regulatory compliance: fulfilling our obligations under Virginia, Maryland, D.C., and federal real estate licensing laws; responding to lawful legal process; and maintaining required records for the periods mandated by our licensing jurisdictions
  • Fraud prevention and safety: protecting our clients, agents, and business from wire fraud, identity fraud, and other harmful activities, as further described in Section 9

5. How We Share Your Information

We do not sell your personal information to third parties, data brokers, or marketers. We share your information only in the following circumstances.

Technology Service Providers

We work with technology vendors to operate our business. Each vendor processes your data only on our behalf, under written agreements that require them to protect your information and use it solely for the purposes we specify. Our current technology platform includes:

  • Luxury Presence: website hosting, property search, lead capture forms, and home valuation tools
  • Follow Up Boss: client relationship management, lead routing, and internal communication
  • SkySlope: transaction management, document storage, and electronic signatures
  • Google (Analytics and Ads): website analytics and advertising performance measurement
  • Meta (Facebook Pixel): advertising performance measurement and audience targeting on Facebook and Instagram
Individual Agent Email Marketing Tools

Paul Wesley Real Estate agents are independent contractors who may, in connection with their real estate services, use their own email marketing platforms (such as Mailchimp or Constant Contact) to communicate with clients and prospects. When agents use such tools in connection with Paul Wesley Real Estate services, they are required to handle your information consistently with this Privacy Policy and to honor your opt-out requests. If you have questions about communications from a specific agent, please contact us at the address in Section 15.

Real Estate Transaction Participants

In connection with a real estate transaction, we share relevant information with cooperating agents and brokerages, title and settlement companies, settlement attorneys, lenders, home inspectors, appraisers, and other parties whose involvement is necessary to complete the transaction. We share only the information required to fulfill our fiduciary and agency obligations.

Multiple Listing Services and Real Estate Boards

To list properties for sale and access cooperative property data, we participate in regional Multiple Listing Services. MLS rules govern the submission, use, and distribution of listing data within the cooperative system.

No Affiliated Business Arrangements

Paul Wesley Real Estate does not have ownership interests in, or formal referral fee arrangements with, any title company, settlement attorney, mortgage lender, or insurance provider. When we refer you to service providers, we do so solely on the basis of merit and your needs, without any financial consideration to us.

Legal and Regulatory Requirements

We may disclose your information when required by applicable law, court order, subpoena, regulatory requirement, or valid legal process in Virginia, Maryland, the District of Columbia, or at the federal level. We may also disclose information to protect the rights, property, or safety of Paul Wesley Real Estate, our agents, our clients, or the public.

Business Transfers

If Paul Wesley Real Estate is involved in a merger, acquisition, restructuring, or sale of assets, personal information held by us may be among the assets considered for transfer. We will notify you of any material change in ownership or data practices that affects your personal information.

Agent Departure and Data Ownership

When an independent contractor agent leaves Paul Wesley Real Estate, the brokerage retains all transaction records, disclosure documents, and data generated through brokerage systems and channels (including leads captured through our website, Follow Up Boss, and MLS routing). Client contact information that an agent cultivated independently and personally may accompany that agent. If you have questions about how your information is handled following an agent transition, please contact us directly.


6. Cookies and Tracking Technologies

6.1  Types of Technologies We Use

Our Site uses the following categories of tracking technologies:

  • Cookies: small text files stored on your device that help our Site remember your preferences, maintain session state, recognize returning visitors, and enable certain features including saved searches and property favorites
  • Web beacons and pixel tags: transparent images embedded in web pages and marketing emails that allow us to measure whether content has been viewed or links have been clicked
  • Local storage: browser-based data storage that persists across sessions to support Site functionality

6.2  Google Analytics and Google Ads

We use Google Analytics to understand how visitors use our Site, which pages are most visited, and where visitors come from. Google Analytics uses cookies and may collect your IP address, browser type, device information, and browsing behavior on our Site. We may also use Google Ads to run advertising campaigns and measure their effectiveness.

Google's data practices are governed by Google's Privacy Policy, available at policies.google.com/privacy. To opt out of Google Analytics data collection across all websites, you may install the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout. To manage Google Ads personalization, visit adssettings.google.com.

6.3  Meta Pixel (Facebook and Instagram)

We use the Meta Pixel on our Site. The Meta Pixel is a piece of code provided by Meta Platforms, Inc. that allows us to measure the effectiveness of our advertising on Facebook and Instagram, to understand what actions visitors take on our Site, and to show our advertisements to people who have previously visited our Site or to similar audiences.

The Meta Pixel may collect your IP address, browser type, pages visited, and information about actions taken on our Site, and may associate this information with your Facebook or Instagram account if you are logged in to those platforms. Meta's data practices are governed by Meta's Privacy Policy, available at facebook.com/privacy/policy. To manage Meta's use of your data for advertising purposes, visit your Facebook Ad Preferences at facebook.com/adpreferences or your Instagram settings.

We do not use the Meta Pixel to share your name, contact information, or real estate transaction details with Meta. If you believe any such information has been shared inadvertently, please contact us immediately at the address in Section 15.

6.4  Your Cookie Choices

Most web browsers allow you to control cookies through browser settings. You may configure your browser to refuse all cookies, to alert you when cookies are being sent, or to delete cookies already stored on your device. Disabling cookies may affect certain Site features, including saved searches and personalized property recommendations.

Paul Wesley Real Estate does not currently respond to browser-based Do Not Track signals. If this practice changes, we will update this policy accordingly.


7. Communications: Email, SMS, and Phone

7.1  Consent to Contact

By providing your contact information and consenting through our Site, in writing, or verbally, you agree that Paul Wesley Real Estate, our affiliated independent contractor agents, and our service providers may contact you by phone, email, and text message regarding real estate services. This may include messages sent using automated systems, automated dialers, or prerecorded voices, as permitted by the Telephone Consumer Protection Act (TCPA) and applicable Virginia, Maryland, and D.C. regulations.

Message and data rates may apply. Message frequency will vary based on your relationship with us and the activity of your transaction or search.

7.2  Opt-Out Rights

You may opt out of marketing communications at any time using the following methods:

  • Email: click the Unsubscribe link in any marketing email we send. Please allow up to ten (10) business days for processing.
  • SMS / text message: reply STOP to any text message from us to be removed from our texting list. Reply HELP for assistance.
  • Phone calls: contact us in writing at the address in Section 15 to request placement on our internal Do Not Call list.

If you opt out of marketing communications, we may still contact you regarding active transactions, legal obligations, security notices, or administrative matters related to services you have requested. Opting out of brokerage communications does not automatically opt you out of communications from individual agents using their own platforms; please contact those agents directly or notify us and we will coordinate the request.

7.3  Do Not Call Policy and TCPA Compliance

Paul Wesley Real Estate complies with the Telephone Consumer Protection Act (TCPA), the FCC's implementing regulations, and applicable state telemarketing laws in Virginia, Maryland, and D.C. We honor requests made to the National Do Not Call Registry (donotcall.gov).

To request placement on our internal Do Not Call list, submit your request in writing to the address in Section 15, including your full telephone number. We will document your request within seven (7) business days and remove your number from active calling and texting programs within thirty (30) days. Your Do Not Call preference will remain in effect for five (5) years, or longer if required by applicable law. Please notify us if your telephone number changes.

Please note that applicable law permits a business to contact its own existing clients even if their number appears on the National Registry. If you are a current or active client of Paul Wesley Real Estate, we may still contact you for transaction-related purposes unless you specifically request that we not do so.

7.4  CAN-SPAM Compliance

All commercial email communications from Paul Wesley Real Estate comply with the CAN-SPAM Act of 2003. Specifically, we do not use false or misleading header information or deceptive subject lines; we identify messages as commercial communications where required; we include our physical mailing address in each commercial email; and we honor unsubscribe requests promptly. If you believe you have received a commercial email from us that does not comply with these standards, please notify us immediately at the contact in Section 15.


8. Data Security

We implement reasonable and appropriate technical, organizational, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Our technology platform employs industry-standard safeguards including encrypted data transmission (TLS/SSL), access controls, multi-factor authentication on administrative systems, and regular security reviews conducted by our technology partners.

No security measures are perfect or impenetrable, and no method of data transmission over the Internet is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are also responsible for maintaining the confidentiality of any account credentials and for notifying us promptly if you suspect unauthorized access to your information.

In the event of a data security incident that compromises personal information in our possession, we will notify affected individuals and applicable regulatory authorities in accordance with the Virginia Consumer Data Protection Act, the Maryland Personal Information Protection Act, the D.C. Security Breach Notification Act (D.C. Code § 28-3851 et seq.), and any other applicable breach notification laws. We will provide notice in the most expedient time possible and without unreasonable delay.


9. Wire Fraud and Anti-Fraud Warning

IMPORTANT NOTICE REGARDING WIRE FRAUD: Real estate wire fraud is one of the fastest-growing financial crimes in the United States. Criminals regularly intercept real estate communications and send fraudulent wiring instructions that appear to come from legitimate parties.

Paul Wesley Real Estate will NEVER send you electronic communications directing you to wire funds or to provide nonpublic financial information such as bank account numbers, routing numbers, or credit or debit card numbers. Any such request — even one that appears to come from us, from your agent, from a title company, or from a settlement attorney — should be treated as fraudulent until independently verified.

NEVER TRANSMIT WIRE TRANSFER INSTRUCTIONS, BANK ACCOUNT NUMBERS, ROUTING NUMBERS, OR FINANCIAL CREDENTIALS BY EMAIL OR OTHER UNSECURED ELECTRONIC COMMUNICATION.

Before wiring any funds in connection with a real estate transaction, always call your agent or our office using a telephone number you have independently obtained and verified — not a number provided in a suspicious email. If you receive a suspicious communication purporting to be from Paul Wesley Real Estate or any party to your transaction, do not respond to it and contact us immediately at the address in Section 15.


10. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including providing real estate services, complying with our legal and regulatory obligations, resolving disputes, and enforcing our agreements.

Real estate transaction records — including listing agreements, purchase contracts, agency disclosure forms, executed electronic documents in SkySlope, and closing documentation — are retained in accordance with applicable real estate licensing requirements:

  • Virginia: Virginia Code § 54.1-2133 and Board of Real Estate regulations require that brokers retain transaction records for a minimum of three (3) years from the date of closing or termination of the transaction
  • Maryland: Maryland Real Estate Brokers Act and COMAR regulations similarly require retention of transaction records for a minimum of three (3) years
  • District of Columbia: D.C. real estate licensing regulations require brokers to retain records for three (3) years

Certain records may be retained for longer periods where required by law, where necessary to protect our legal rights, or where consistent with our legitimate business purposes. Marketing contact records are retained for as long as you remain an active contact or until you request deletion, subject to the limitations described in Section 12. When personal information is no longer required, we take reasonable steps to delete or securely de-identify it.


11. Children's Privacy

Our Site and real estate services are intended for adults. We do not knowingly collect personal information from children under the age of 18. If we learn that we have collected personal information from a child under 18 without verified parental or guardian consent, we will delete that information promptly. If you believe we may have inadvertently collected information from a child under 18, please contact us at the address in Section 15.


12. Your Privacy Rights

12.1  Rights Available to All Individuals

Regardless of your location, you may contact us at any time to:

  • Access and review the personal information we hold about you
  • Request correction of inaccurate or out-of-date information
  • Opt out of marketing communications as described in Section 7
  • Ask questions about our data collection or sharing practices

12.2  Virginia Residents — Virginia Consumer Data Protection Act (VCDPA)

Under the Virginia Consumer Data Protection Act (Va. Code § 59.1-575 et seq.), Virginia residents have the following rights with respect to their personal data:

  • Right to know: confirm whether we process your personal data and access a copy of it
  • Right to correct: request correction of inaccuracies in your personal data, taking into account the nature of the data and the purposes for which it is processed
  • Right to delete: request deletion of personal data provided by or obtained about you, subject to our legal retention obligations
  • Right to data portability: obtain a copy of your personal data in a portable, machine-readable format that can be transmitted to another controller
  • Right to opt out: opt out of the processing of personal data for purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects

Paul Wesley Real Estate does not sell personal data as defined under the VCDPA. We may use Google Analytics and the Meta Pixel for targeted advertising purposes on our Site; to opt out of those specific uses, see Section 6.2 and Section 6.3. We will acknowledge receipt of a verified VCDPA request within ten (10) business days and respond within forty-five (45) days. Where reasonably necessary, we may extend that response period by an additional forty-five (45) days with written notice to you.

12.3  Maryland Residents — Maryland Online Data Privacy Act (MODPA)

The Maryland Online Data Privacy Act (MODPA), effective October 1, 2025, provides Maryland residents with rights substantially equivalent to those described above under the VCDPA, including the rights to know, correct, delete, and obtain a portable copy of personal data, and to opt out of targeted advertising, the sale of personal data, and certain profiling activities.

Paul Wesley Real Estate does not sell personal data as defined under MODPA. We will respond to verified MODPA requests within forty-five (45) days of receipt, with a possible extension of forty-five (45) additional days with notice.

12.4  District of Columbia Residents

The District of Columbia does not currently have a standalone comprehensive consumer data privacy statute equivalent to the VCDPA or MODPA. D.C. residents are protected under the D.C. Consumer Protection Procedures Act (D.C. Code § 28-3901 et seq.) and applicable federal law. D.C. residents may exercise the access, correction, and opt-out rights described in Section 12.1. Should D.C. enact comprehensive consumer data privacy legislation, we will update this policy accordingly.

12.5  California Residents — CCPA / CPRA

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, California residents have the following rights:

  • Right to know what personal information we collect, use, disclose, and share
  • Right to delete personal information we have collected, subject to legal retention obligations
  • Right to correct inaccurate personal information
  • Right to opt out of the sale or sharing of personal information
  • Right to limit use of sensitive personal information
  • Right to non-discrimination for exercising your CCPA rights

Paul Wesley Real Estate does not sell or share personal information as those terms are defined under the CCPA/CPRA and has not done so in the twelve (12) months preceding the effective date of this policy. We do not collect sensitive personal information as defined under CCPA/CPRA. To submit a CCPA rights request, contact us at the address in Section 15. We will respond to verified requests within forty-five (45) calendar days.

12.6  Other State Residents

Residents of Colorado, Connecticut, Nevada, Texas, Utah, and other states with consumer data privacy laws may have rights similar to those described above. To exercise any available rights under applicable state law, please contact us at the address in Section 15.

12.7  International Residents and Future International Operations

Paul Wesley Real Estate does not currently operate a structured international real estate program. Our services are intended for residents of the United States and are not directed to individuals located outside of the U.S. If you are located outside the United States and choose to provide personal information to us, please be aware that your information will be transferred to and processed in the United States, where data protection standards may differ from those in your country of residence.

Should Paul Wesley Real Estate establish a structured international referral program or systematically market to buyers or sellers in the European Union, European Economic Area, United Kingdom, or other jurisdictions with comprehensive data protection laws, we will update this policy with jurisdiction-specific provisions — including, where applicable, GDPR-compliant disclosures, lawful basis for processing, and appropriate data transfer mechanisms — before that program launches.

12.8  How to Submit a Privacy Request

To exercise any of the rights described in this Section, or to ask questions about our privacy practices, please contact us:

  • Email: [email protected]
  • Mail: Paul Wesley Real Estate, LLC, Attn: Privacy, 1451 Dolley Madison Blvd, McLean, VA 22101

We will acknowledge receipt of your request within ten (10) business days. We may need to verify your identity before processing certain requests; any information you provide for verification purposes will be used solely for that purpose. We will not discriminate against you for exercising your privacy rights. We will not be able to fulfill requests to delete information that we are required to retain under Virginia, Maryland, or D.C. real estate licensing law.


13. Third-Party Websites and Services

Our Site may contain links to third-party websites, including property search portals, mortgage calculators, neighborhood information resources, local government sites, and the websites of service providers we recommend. We do not own or operate those third-party sites, and this Privacy Policy does not apply to information they collect. We encourage you to review the privacy policies of any third-party websites you visit.

The presence of a link to a third-party website on our Site does not constitute an endorsement of that site, its content, or its privacy or data practices.


14. Fair Housing and Non-Discrimination

Paul Wesley Real Estate and all affiliated independent contractor agents are committed to full compliance with all applicable fair housing and non-discrimination laws, including:

  • The federal Fair Housing Act (42 U.S.C. § 3601 et seq.), prohibiting discrimination based on race, color, national origin, religion, sex, familial status, and disability
  • The Virginia Fair Housing Law (Va. Code § 36-96.1 et seq.), which incorporates and in some respects expands upon the federal protections
  • The Maryland Fair Housing Act, which prohibits discrimination based on race, color, religion, sex, familial status, national origin, disability, marital status, sexual orientation, gender identity, and source of income
  • The D.C. Human Rights Act (D.C. Code § 2-1401.01 et seq.), which provides some of the broadest fair housing protections in the nation, including protections based on race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, familial status, family responsibilities, disability, matriculation, political affiliation, source of income, place of residence or business, and status as a victim of an intrafamily offense

We do not use personal information we collect to engage in any form of illegal discriminatory housing practice. We do not collect or use data in any way intended to steer, discriminate against, or limit the housing choices of any protected class.


15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, technology platform, legal requirements, or business operations. When we make material changes, we will post the updated policy on our Site and update the Effective Date at the top of this document. For significant changes, we may also provide notice by email or through a prominent notice on our Site.

We encourage you to review this policy periodically. Your continued use of our Site or services after any update constitutes acceptance of the revised policy. Where required by applicable law — including Virginia, Maryland, or D.C. law — we will provide advance notice of or seek your consent to material changes before they take effect.


16. Contact Us

For questions, concerns, opt-out requests, or privacy rights requests relating to this Privacy Policy or our data practices, please contact us:

Paul Wesley Real Estate, LLC

Attn: Privacy
1451 Dolley Madison Blvd
McLean, Virginia 22101
Email: [email protected]
Main Phone: N/A
Website: paulwesley.com


All information provided through our Site is deemed reliable but not guaranteed and should be independently reviewed and verified. Paul Wesley Real Estate, LLC is a licensed real estate brokerage in the Commonwealth of Virginia, the State of Maryland, and the District of Columbia. Paul Wesley Real Estate and its affiliated agents support the Fair Housing Act, the Equal Opportunity Act, and all applicable state and local fair housing laws and regulations.

DRAFT — ATTORNEY REVIEW REQUIRED BEFORE PUBLICATION. Items requiring confirmation before going live: (1) effective date and last-updated date; (2) main office phone number; (3) legal review of agent data ownership provision (Section 5); (4) confirm Meta Pixel and Google Ads are active and no additional ad platforms are in use at launch; (5) confirm no lead-gen platforms beyond those listed in Section 3.3 are active at launch.

PRIVACY POLICY AND TERMS OF USE

Last Updated: March 12, 2026

Introduction

This website (the "Site") offers information, products, and services related to real estate (the "Services") that we, Paul Wesley Real Estate, provides. We operate this website and may use third-party contractors to support the delivery of the Services and the Site ("Service Providers").

If you are a visitor to this Site, this Privacy Policy and Terms of Use applies to you and describes the policies and practices regarding the collection, use, and disclosure of your personal information in connection with your use of the Site. We act as the controller of your personal data, and our Service Providers assist us in providing the Services solely in their capacities as service providers and data processors.

This Privacy Policy and Terms of Use does not apply to any websites, applications, or other online services that do not link to this Policy, including other services provided by us or by our Service Providers. If you have questions about our use of your personal information, please contact us using the information in Section 12 below.

  1. Personal Information We Collect

    We collect information from you in various ways when you access or use the Site or otherwise interact with the Services. This information may include:

    Information You Provide to Us

    Contact information that you provide, such as your first and last name, email address, home address, and phone number; feedback or correspondence, such as information you provide when you contact us with questions, feedback, or other correspondence; marketing information, such as your preferences and/or consents for receiving communications about our activities, events, and publications, and details about how you engage with such communications; and other information which you may provide voluntarily or that is necessary in connection with your interactions with us through the Site or Services.

    Information We Obtain from Third Parties

    Social media information: We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with these pages, the platform providers' privacy policies will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy and Terms of Use.

    Data enrichment sources: We may obtain additional information about you from third-party data providers, including property records and public records databases, demographic and behavioral data providers, social media profile information (where publicly available), and other commercially available data sources. This information helps us provide more relevant services and communications.

    Other sources: We may obtain your personal information from other third parties, such as third-party analytics services, marketing partners, publicly-available sources, and data providers.

    CRM and Communication Data

    If you communicate with us via email, text message, or other electronic means, or if we use customer relationship management ("CRM") tools to manage our interactions with you, we may collect and process: email message content, headers, metadata, and attachments; text message content and metadata; communication timestamps, read receipts, and delivery status; contact information and communication history; and notes and records relating to our interactions with you.

    Our CRM services may synchronize with email accounts to facilitate communication management. When email synchronization is enabled, information from emails exchanged with you may be processed and stored, including email content, sender and recipient information, timestamps, and attachments. This data is used to provide better service, maintain accurate records, and facilitate follow-up communications.

    Automatic Data Collection

    We and our Service Providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications, and other online services, such as: device data (including your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area); and online activity data (such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them).

    We use the following tools for automatic data collection: cookies (text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser); local storage technologies (like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data); and web beacons (also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked).

  2. How We (and Our Service Providers) May Use Your Personal Information

    We may use your personal information for the following purposes:

    To provide and operate our Services and our Site: We use your information to provide, operate, and improve our Services and Site; communicate with you about our Services and business including by sending announcements, updates, security alerts, and support and administrative messages; and provide support and respond to requests, questions, and feedback.

    To manage our relationship with you: We use CRM tools and services to maintain records of our communications, track your preferences and interests, and provide personalized service. This may include analyzing your interactions with us to better understand your needs and preferences.

    To send you follow-up communications: If you have opted into receiving follow-up communications, we (or our Service Providers) may from time to time send you follow-up communications as permitted by law, including through phone, email, and SMS text messages, some of which may use artificial or prerecorded voices. You may opt out of receiving such communications as set forth in Section 6 below.

    To send you marketing and promotional communications: If you have opted in to receive marketing and promotional communications, we (or our Service Providers) may from time-to-time send you direct marketing communications as permitted by law, including through phone, email, and SMS text messages, some of which may use artificial or prerecorded voices. Other than as set forth in Section 4 below, your information will not be shared with third parties for marketing or promotional purposes. You may opt out of receiving such communications as set forth in Section 6 below.

    To comply with law: As we or our Service Providers believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

    For compliance, fraud prevention, and safety: To protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims); enforce the terms and conditions that govern our Services; and protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

    To create anonymous data: We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, conduct research, and promote our business.

  3. Use of Artificial Intelligence

    We use artificial intelligence ("AI") and machine learning technologies to provide and improve our Services. This section describes how AI is used in connection with the Site and Services.

    AI-Generated Content

    We may use AI technologies to generate, assist with, or enhance content displayed on the Site or provided through our Services, including: property descriptions and listing information; blog posts, articles, and other written content; social media posts and marketing materials; email communications and newsletters; and advertising copy and promotional content.

    AI-generated content is created using large language models and other machine learning systems. While we review AI-generated content for accuracy and appropriateness, such content may contain errors, omissions, or inaccuracies. You should not rely solely on AI-generated content for important decisions, including real estate transactions, without independent verification.

    AI-Assisted Communications

    We may use AI to assist with communications, including: drafting and suggesting responses to inquiries; analyzing communication patterns to improve service; providing automated responses to common questions; and prioritizing and categorizing incoming communications.

    When AI assists with communications, a human may review and approve messages before they are sent, though some automated responses may be sent without individual human review.

    AI-Based Analysis and Recommendations

    We may use AI to analyze data and provide recommendations, including: identifying potential opportunities based on your stated preferences and behavior; suggesting properties that may match your criteria; analyzing market trends and conditions; and optimizing the timing and content of communications.

    These AI-based analyses and recommendations are provided for informational purposes and should not be considered professional advice. Important decisions should be made in consultation with qualified professionals.

    Your Rights Regarding AI

    You have the right to: request information about whether AI was used to generate specific content; request human review of significant decisions that were made with AI assistance; opt out of certain AI-powered features where technically feasible; and provide feedback on AI-generated content or recommendations.

    To exercise these rights or ask questions about our use of AI, please contact us using the information in Section 12 below.

  4. How We Share Your Personal Information

    We do not "sell" any personal information (as defined under applicable laws), but we may share your personal information as described below and as described elsewhere in this Privacy Policy and Terms of Use. We may share your personal information with:

    Internal Team, Partners, and Affiliates: Our employees and contractors, partners, and affiliates: Including to facilitate your interactions with us.

    Our Service Providers: Companies and individuals that provide services on our behalf or to help us provide the Services, the Site, or our business (such as hosting, information technology, CRM services, email delivery, AI and machine learning services, and website analytics services).

    Professional advisors: We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us or our Service Providers.

    For compliance, fraud prevention, and safety: We or our Service Providers may share your personal information for the compliance, fraud prevention, and safety purposes described above.

    Business transfers: We (or our Service Providers) may sell, transfer, or otherwise share some or all of our (or our Service Providers') business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy and Terms of Use.

    Other than as set forth herein, data will not be shared with third parties for marketing or promotional purposes. We will never disclose any personal information such as phone numbers and SMS consent with any third parties for marketing purposes.

  5. Advertising and Tracking Technologies

    We may use advertising and tracking technologies to deliver relevant advertising and measure the effectiveness of our marketing efforts.

    Third-Party Advertising Platforms

    We may share certain information with third-party advertising platforms, including Meta (Facebook/Instagram), Google, and other advertising networks, to: deliver targeted advertisements to you based on your interests and interactions with our Site; measure the effectiveness of our advertising campaigns; create audiences of similar users for advertising purposes ("lookalike audiences"); and track conversions and attribute advertising performance.

    When you interact with our Site, third-party advertising platforms may collect information through cookies, pixels, and similar technologies. This information may include your device identifiers, browsing behavior, and interactions with our advertisements.

    Tracking Pixels and Conversion Events

    We use tracking pixels (also known as web beacons or clear GIFs) on our Site to: track when you view or interact with our content; measure the effectiveness of our email campaigns; attribute conversions to specific advertising campaigns; and analyze user behavior on our Site.

    These tracking technologies may transmit information to third-party platforms, including information about the pages you visit, actions you take on our Site, and information about your device.

    Interest-Based Advertising

    We participate in interest-based advertising, which means that you may see our advertisements on third-party websites and platforms based on your browsing behavior and inferred interests. Third-party advertising platforms use cookies and similar technologies to collect information about your online activities across different websites and services to provide you with more relevant advertisements.

  6. Privacy Choices and Opt-Outs

    You have the following choices regarding our collection and use of your personal information:

    Online Tracking Opt-Out

    There are a number of ways to opt out of having your online activity and device data collected through our Services: blocking cookies in your browser (most browsers let you remove or reject cookies, including cookies used for interest-based advertising; to do this, follow the instructions in your browser settings; for more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org); blocking advertising ID use in your mobile settings (your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes); and using privacy plug-ins or browsers (you can block our Services from setting cookies used for third-party analytics or interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin).

    Platform Opt-Outs

    The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising: Google (https://adssettings.google.com/), Facebook (http://www.facebook.com/about/ads), and Twitter (https://twitter.com/settings/account/personalization).

    Advertising Industry Opt-Out Tools

    You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: Digital Advertising Alliance (http://optout.aboutads.info/) and Network Advertising Initiative (http://optout.networkadvertising.org/).

    Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

    Do Not Track

    Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

    SMS Communications Opt-Out

    To opt out of receiving SMS communications, reply STOP to any SMS communication sent to you.

    Email Communications Opt-Out

    You may unsubscribe from email updates sent by us at any time by following the unsubscribe link in the email.

    Privacy Rights

    You have the right to submit requests about your personal information, depending on your location and the nature of your interactions with the Site and our Services. These rights may include: information about how we have collected and used your personal information (we have made this information available to you without having to request it by including it in this Privacy Policy and Terms of Use); access to a copy of the personal information that we have collected about you (where applicable, we will provide the information in a portable, machine-readable, readily usable format); correction of personal information that is inaccurate or out of date; deletion of personal information that we no longer need to provide our services or for other lawful purposes; and additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, you may withdraw your consent.

    If you wish to exercise your rights, please contact us using the information in Section 12 below.

  7. Data Retention

    We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements, and to provide you with the Services.

    The retention period for personal information depends on the context and our relationship with you: contact information and communication records are generally retained for the duration of our relationship with you and for a reasonable period thereafter to allow for follow-up communications and to comply with legal requirements; CRM data, including email synchronization data, is retained for as long as you maintain an active relationship with us, unless longer retention is required by law; transactional records may be retained to comply with legal and regulatory requirements; and marketing preferences are retained until you update them or opt out.

    When personal information is no longer necessary for the purposes for which it was collected, we will securely delete or anonymize it. In some cases, we may retain certain information in anonymized or aggregated form for analytical purposes.

  8. Third Party Services

    The Site and Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

  9. Security

    We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. We take appropriate technical and organizational measures that provide a level of security appropriate to the risk of processing your personal data. We follow generally accepted industry standards to protect the personal data and information submitted to us, both during transmission and in storage. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect personal data, we cannot guarantee its absolute security.

  10. Children

    Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child's parent or guardian as required by law, we will delete it.

  11. SMS Text Messaging Terms of Use

    (i) Use of SMS Text Messaging
    Paul Wesley Real Estate uses SMS Text Messaging to confirm appointments, send reminders, and notify clients of schedule updates or important changes. We also use SMS Text Messaging marketing and promotional purposes, including providing you with new listing alerts, price reduction notifications, invitations to upcoming open houses, and periodic real estate market updates tailored to your interests.

    (ii) Unsubscribing from SMS Text Messaging
    You can cancel the SMS service at any time. Just text "STOP". After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again.

    (III) Assistance
    If you are experiencing issues with the messaging program, you can reply with the keyword "HELP" for more assistance, or you can get help directly at [email protected]

    (IV) Carrier Liability
    Carriers are not liable for delayed or undelivered messages.

    (V) Frequency and Data Rates
    Message and data rates may apply for any messages sent to you from us and to us from you. Message frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

    (VI) Other Privacy Questions
    If you have any questions regarding privacy, please read this Privacy Policy and Terms of Use.

  12. How to Contact Us

    You may contact us through our Service Provider.

    Paul Wesley Real Estate
    C/O Luxury Presence Inc.
    ATTN: Legal Department
    3135 3232 E Cesar Chavez Street
    Suite 1-300
    Austin, TX 78702

    Or via [email protected]

  13. Changes to this Privacy Policy and Terms of Use

    We reserve the right to modify this Privacy Policy and Terms of Use at any time. If we make material changes to this Privacy Policy and Terms of Use, we will notify you by updating the date of this Privacy Policy and Terms of Use and posting it on this website.

  14. Notice of Collection and Additional Rights for California Residents

    If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA") permits you to request information, no more than once per calendar year, regarding the disclosure of your Personal Data by us to third parties, including for the third parties' direct marketing purposes. Furthermore, California residents have the following rights with respect to Personal Data we may have collected about them:

    Categories of Personal Information Collected

    In the preceding 12 months, we may have collected the following categories of personal information: identifiers (such as name, email address, phone number, and IP address); commercial information (such as property preferences and transaction history); internet or electronic network activity (such as browsing history and interactions with our Site); geolocation data (such as city and state derived from IP address); professional or employment-related information (if provided); inferences drawn from the above (such as preferences and characteristics); and sensitive personal information (only if voluntarily provided, such as account credentials).

    (i) Requests to Know
    You have the right to request that we disclose to you: the categories of Personal Data we have collected about you; the categories of Personal Data about you we have sold or disclosed for a business purpose; the categories of sources from which we have collected Personal Data about you; the business or commercial purposes for selling or collecting Personal Data about you; the categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold; the specific pieces of Personal Data collected; and how long your Personal Data is retained.

    You may submit a request to know to the address or email address indicated in Section 12. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

    (ii) Requests to Delete or Correct
    You have the right to request that we delete any Personal Data about you that we have collected, or correct Personal Data that we have about you that is inaccurate. Upon receiving a verified request to delete personal data, we will do so unless otherwise authorized by law.

    (iii) Authorized Agents
    You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

    (iv) Methods for Submitting Consumer Requests and Our Response to Requests
    You may submit a request to know and requests to delete Personal Data about you via email at [email protected] or at the mailing address provided in Section 12.

    Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) business days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 calendar days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    (v) The Right to Non-Discrimination
    You have the right not to be discriminated against for the exercise of your California privacy rights described above.

    (vi) Selling and Sharing of Personal Data
    We may use your Personal Data for the purposes described in Section 2 of this Policy, and may share your Personal Data as further described in Section 4 of this Policy. California law places certain obligations on businesses that "sell" Personal Data to third parties or "share" Personal Data with third parties for "cross-context behavioral advertising" as those terms are defined under the CCPA.

    We may "share" certain personal information (such as device identifiers and browsing activity) with advertising partners for cross-context behavioral advertising purposes as described in Section 5. You have the right to opt out of this sharing. To opt out, you may contact us using the information in Section 12.

    We do not "sell" Personal Data as that term is defined under the CCPA.

    (vii) Sensitive Personal Data
    Some Personal Data may be considered sensitive personal information under certain privacy laws, including the CCPA. Sensitive personal information may include, for example, government-issued identification number, information relating to a person's race or ethnic origin, political opinions or religious beliefs, physical or mental health or condition, sexual orientation, or trade union membership. It may include information about an individual's criminal offenses or convictions, as well as any other information deemed sensitive under applicable data protection laws.

    The CCPA provides consumers with the "right to limit" the use of their sensitive personal information to certain business purposes. We do not request sensitive personal information in connection with the use of the Site, except for account credentials which are used only to provide and secure your account.

    (viii) How We Respond to Do Not Track Signals
    We do not track Site users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer's online activities over time and across third-party websites or online services. However, we do honor Global Privacy Control (GPC) signals as valid opt-out requests under the CCPA.