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Privacy Policy for CRM – System for Brokers

Effective date: July 22, 2026

Embrace Digital operates the CRM – System for Brokers mobile application (“App”, “Service”, “we”, “us”, or “our”).

This Privacy Policy explains what information we collect, how we use and protect it, when it may be shared, and what rights users have regarding their information.

By using the App, you acknowledge the practices described in this Privacy Policy.

1. Purpose of the App

CRM – System for Brokers is a business-oriented customer relationship management application intended for real estate brokers, agents, administrators, and agency owners.

The App may allow authorized users to:

  • create and manage business accounts;
  • maintain a shared database of real estate records;
  • add locations and coordinates to a map;
  • assign records to agents;
  • manage team members and roles;
  • store notes, property details, tasks, and other business information;
  • view records belonging to an authorized workspace.

The App is not intended to operate as a public real estate marketplace.

2. Information We Collect

Depending on how the App is used, we may collect and process the following categories of information.

2.1 Account information

When a user creates or accesses an account, we may collect:

  • name or display name;
  • email address;
  • authentication identifier;
  • profile image, when provided through Google Sign-In;
  • organization or workspace information;
  • account role, such as Owner, Administrator, or Agent;
  • account creation and update timestamps.

Passwords are processed through Firebase Authentication. We do not store plain-text passwords.

2.2 Business and CRM information

Users may enter information into the App, including:

  • property or location titles;
  • property descriptions;
  • addresses;
  • geographical coordinates;
  • client or contact information;
  • telephone numbers;
  • notes and comments;
  • property status and category;
  • assigned agent information;
  • tasks and activity records;
  • uploaded images or documents, when these features are available.

Users and organizations are responsible for ensuring that they have a lawful basis and appropriate authorization to enter personal information about clients, employees, property owners, or other individuals.

2.3 Location information

The App may request access to the device’s location to:

  • show the user’s current position on the map;
  • help create a new map record;
  • select or confirm property coordinates;
  • navigate the map to a relevant location.

Precise location is accessed only when the user grants Android location permission and uses a location-related feature.

The App does not intentionally collect continuous background location unless a future feature clearly requests separate permission and provides an appropriate disclosure.

Users may disable location permission at any time through the device settings. Some map-related features may not function correctly without location access.

2.4 Map and coordinate information

The App uses Google Maps Platform to display maps, satellite imagery, map labels, markers, and geographical coordinates.

Google may process technical and usage information when map content is loaded, in accordance with Google’s applicable terms and privacy practices.

2.5 Device and technical information

Our service providers may automatically process limited technical information, including:

  • device model;
  • operating system and application version;
  • language and regional settings;
  • IP address;
  • application instance identifiers;
  • Firebase installation identifiers;
  • crash information;
  • diagnostic and performance information;
  • authentication and security logs.

This information may be used to operate the App, prevent abuse, investigate errors, and improve security and reliability.

3. How We Use Information

We may use collected information to:

  • create and authenticate user accounts;
  • provide access to authorized workspaces;
  • enforce account roles and permissions;
  • display and manage real estate records;
  • display records and markers on a map;
  • synchronize data between authorized team members;
  • assign records and tasks to agents;
  • maintain account and activity history;
  • provide customer support;
  • detect unauthorized access, fraud, abuse, or security incidents;
  • maintain, troubleshoot, and improve the App;
  • comply with legal obligations and enforce our agreements.

We do not use CRM information submitted by organizations for unrelated advertising purposes.

4. Legal Basis for Processing

Where applicable, we process personal information based on one or more of the following grounds:

  • performance of a contract or provision of the requested Service;
  • the user’s consent;
  • our legitimate interests in operating and securing the App;
  • compliance with legal obligations;
  • protection of the rights, safety, and security of users and other persons.

Organizations using the App may act as independent data controllers for information they enter about their clients, employees, agents, and business contacts.

5. Third-Party Service Providers

We use third-party services to operate the App.

Google Firebase

The App may use Firebase services, including:

  • Firebase Authentication;
  • Cloud Firestore;
  • Firebase Storage;
  • Firebase Cloud Messaging;
  • Firebase Analytics, when enabled;
  • other Firebase security, diagnostics, or infrastructure services.

Firebase may process account identifiers, technical identifiers, stored application data, device information, diagnostic data, and other information required to provide these services.

Google Maps Platform

The App uses Google Maps Platform to provide:

  • map display;
  • satellite or hybrid map imagery;
  • map markers;
  • coordinates and location-based functionality.

Use of Google services is also subject to Google’s Privacy Policy and applicable Google service terms.

Google Sign-In

When a user chooses Google Sign-In, Google may provide us with information such as the user’s name, email address, profile image, and account identifier.

We use this information only to authenticate the user and create or maintain the App account.

Firebase provides documentation concerning its privacy, security, data handling, and Google Play disclosure requirements.

6. Sharing of Information

We do not sell or rent personal information.

Information may be shared only in the following circumstances:

Service providers

We may share or allow processing by service providers such as Google Firebase and Google Maps Platform when necessary to operate the App.

Authorized workspace members

Information entered into a shared organization or workspace may be visible to other authorized users of that workspace, depending on their role and permissions.

For example:

  • Owners may have access to all workspace records;
  • Administrators may manage team and business records;
  • Agents may access records allowed by the organization’s permission settings.

Legal requirements

We may disclose information when reasonably necessary to:

  • comply with applicable law, regulation, court order, or lawful government request;
  • protect users, the public, or our legal rights;
  • investigate fraud, abuse, or security threats;
  • enforce our agreements and policies.

Business transfer

If the App or its operating business is involved in a merger, acquisition, restructuring, or sale of assets, information may be transferred as part of that transaction, subject to applicable law.

7. Data Storage and International Processing

App information may be stored and processed using Google Firebase infrastructure.

Depending on the selected infrastructure region and the user’s location, information may be processed in countries other than the user’s country of residence.

Where required, we take reasonable measures to ensure that personal information receives appropriate protection.

8. Data Security

We use reasonable technical and organizational safeguards intended to protect information, including:

  • authenticated account access;
  • role-based access controls;
  • Firebase Security Rules;
  • restricted Google Maps API credentials;
  • encrypted network transmission;
  • access restrictions for authorized workspace members;
  • monitoring and investigation of suspicious activity;
  • limited administrative access.

Firebase states that its data processing security measures include controls designed to support confidentiality, integrity, availability, and encryption of personal data.

However, no electronic storage or transmission method is completely secure. We cannot guarantee absolute security.

Users are responsible for:

  • keeping their passwords and devices secure;
  • not sharing account credentials;
  • immediately reporting suspected unauthorized access;
  • entering only information they are authorized to process.

9. Data Retention

We retain personal information only for as long as reasonably necessary to:

  • provide the App and requested features;
  • maintain an active account or workspace;
  • comply with legal, accounting, or contractual requirements;
  • resolve disputes;
  • investigate misuse or security incidents;
  • enforce our agreements.

Workspace information may remain available while the relevant organization maintains an active account.

After deletion, some information may remain temporarily in backups, logs, fraud-prevention systems, or records required by law.

10. Account and Data Deletion

Users may request deletion of their account and associated personal information by contacting us at:

embrace.tech01@gmail.com

The request should include the email address associated with the account.

We may need to verify the requester’s identity before processing the request.

When an account is part of an organization or shared workspace:

  • personal profile information may be deleted or anonymized;
  • business records created for the organization may remain under the organization’s control;
  • ownership of business records may be transferred to another authorized workspace member;
  • information required for security, legal compliance, or dispute resolution may be retained.

Account deletion requests will be processed within a reasonable period, subject to applicable legal and technical requirements.

Firebase also provides mechanisms for clearing or exporting information associated with user identifiers, although implementation remains the application developer’s responsibility.

11. User Rights

Depending on applicable law and the user’s location, users may have the right to:

  • request access to personal information;
  • request correction of inaccurate information;
  • request deletion of personal information;
  • withdraw consent;
  • object to or restrict certain processing;
  • request a portable copy of personal information;
  • submit a complaint to a competent data protection authority.

Requests may be sent to:

embrace.tech01@gmail.com

We may request reasonable verification before fulfilling a request.

12. Organization and Administrator Responsibilities

Organizations, owners, and administrators using the App are responsible for:

  • managing team access;
  • assigning appropriate roles;
  • removing access when an employee or agent leaves;
  • ensuring that data entered into the App was obtained lawfully;
  • informing their clients, staff, and contacts about applicable data processing;
  • responding to requests involving organization-controlled CRM information;
  • avoiding the storage of unnecessary or prohibited sensitive information.

Embrace Digital is not responsible for personal information entered unlawfully or without authorization by an organization or its users.

13. Sensitive Information

Users should not enter unnecessary highly sensitive information into the App, including:

  • passwords;
  • payment card numbers;
  • government identification numbers;
  • medical information;
  • biometric information;
  • information concerning children;
  • information that the user is not authorized to process.

14. Children’s Privacy

The App is intended for professional and business users.

It is not directed to children under the age of 18, and we do not knowingly collect personal information directly from children.

If we learn that a child has provided personal information without appropriate authorization, we will take reasonable steps to delete it.

15. Permissions

The App may request the following Android permissions:

Internet access

Required to authenticate users, synchronize CRM information, access Firebase services, and load Google Maps.

Location permission

Used only for location-related map functionality after the user grants permission.

Notifications

May be used to deliver task reminders, workspace updates, account alerts, or other operational notifications.

Camera or media access

May be requested when a user chooses to capture or upload an image or document.

Permissions may be managed through Android device settings.

16. Changes to This Privacy Policy

We may update this Privacy Policy when:

  • App functionality changes;
  • new services are introduced;
  • legal requirements change;
  • data-processing practices change.

The updated version will be published at the same public URL with a revised effective date.

Material changes may also be communicated inside the App or through another appropriate method.

17. Contact Us

For questions, privacy requests, account deletion requests, or complaints, contact:

Developer: Embrace Digital
Application: CRM – System for Brokers
Email: embrace.tech01@gmail.com
Country: Azerbaijan