Who We Are

This Privacy Policy explains how The Creative Close LLC (“we,” “us,” “our”) collects, uses, discloses, and safeguards
personal information in connection with the website thecreativeclose.com (the “Site”) and our real-estate services,
including direct purchase options (cash or creative finance) and traditional brokerage services via
Eric Lamb, REALTOR® operating under Greenridge Realty, Inc. when acting as an agent.

Data Controller: The Creative Close LLC, 10135 South Holland Rd, Fenwick, MI 48834, United States.
Contact: privacy@thecreativeclose.com (Attn: Eric Lamb)

Scope

This Policy covers personal information collected online through the Site and our forms, emails, calls, and texts related to the Site.
It does not replace privacy terms in any transaction-specific agreements (e.g., listing agreements, purchase and sale agreements),
which govern if there is a conflict.

Personal Information We Collect

We may collect the following categories of personal information:

• Identifiers & Contact Data: name, email, phone number, address, city, state, ZIP.
• Property & Financial Info You Provide: property address, condition, photos, desired price,
  mortgage details you choose to share (e.g., balance, rate, PITI, arrears), HOA info, liens, occupancy status.
• Communications & Inquiries: messages, call recordings/voicemails (if applicable), support requests,
  scheduling details (e.g., Calendly), notes from conversations.
• Commercial Information: records of offers, services considered or obtained, transaction history.
• Internet / Technical Data: IP address, device/browser info, pages viewed, referring URLs,
  timestamps, cookies, pixels, and similar technologies (see Analytics, Cookies & Advertising).
• Geolocation (coarse): city/region inferred from IP (not precise GPS).
• Inferences: preferences or likelihood of services of interest (based on your interactions).
• Sensitive data: We do not seek sensitive identifiers (e.g., SSN) via the Site. If a transaction later requires
  sensitive data, it is handled through secure third-party title/escrow or legal processes, not via website forms.

Sources of Personal Information

• Directly from you via forms, calls, texts, emails, and meetings.
• Automatically through cookies, pixels, and similar tools when you use the Site.
• Third parties such as title/escrow, lenders/servicers, lead vendors, public records (e.g., county/MLS), analytics and
  advertising providers, and professional advisors (e.g., attorneys, accountants) where permitted by law.

How We Use Personal Information

• Responding to inquiries; evaluating your property and situation; presenting options (cash/creative/listing).
• Due diligence, offer preparation, transaction administration, and compliance with real-estate and brokerage rules.
• Operating, securing, improving, and personalizing the Site and our services.
• Marketing and advertising (including retargeting), with your choices respected.
• Communicating with you (calls, texts, emails) consistent with applicable consent laws (TCPA).
• Detecting, preventing, and responding to fraud, misuse, and legal/regulatory requests.

Legal Bases (GDPR/UK GDPR)

Where required, we rely on one or more of the following legal bases:

• Consent (e.g., marketing cookies, texting/emailing you after form submission).
• Contract (to take steps at your request before entering into an agreement, or to perform an agreement).
• Legitimate interests (e.g., Site security, service improvement, limited direct marketing).
• Legal obligations (e.g., real-estate recordkeeping, tax, and regulatory requirements).

How We Share Personal Information

We may disclose personal information to:

• Service providers & processors (hosting/WordPress, analytics, advertising platforms, email/SMS and form systems,
  scheduling, title/escrow, attorneys, loan servicers, IT/security) under contracts limiting their use.
• Brokerage & affiliated entities as needed when acting as a licensed agent and for compliance.
• Professional advisors (lawyers, accountants) and authorities to comply with law or protect rights.
• Business transfers (e.g., merger, sale, financing, or acquisition of assets).

Sale/Sharing: We do not sell personal information for money. We may “share” certain internet/technical data
with advertising partners for cross-context behavioral advertising as defined by CPRA. You can opt out—see
Your Privacy Rights and our Cookie Policy.

Analytics, Cookies & Advertising

We use cookies and similar technologies (e.g., pixels, device identifiers) to operate the Site, measure performance (e.g., Google Analytics 4),
and deliver/measure ads (e.g., Google Ads, Meta). Where required, non-essential cookies load only with your consent.

• See our Cookie Policy for details on types of cookies, partners, and how to manage preferences.
• Manage Cookies (or use your browser settings to block/delete cookies).
• We currently do not respond to “Do Not Track” signals due to lack of industry standard.

Data Retention

• Leads & inquiries: typically 24 months from last interaction, unless longer is needed for compliance or to pursue/defend claims.
• Transaction records: at least 7 years (or longer) to meet real-estate, tax, and regulatory obligations.
• We may anonymize or aggregate data for analytics and keep it without time limit.

Security

We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information.
No method of transmission or storage is 100% secure.

Your Privacy Rights

U.S. (including California): Depending on your state, you may have rights to access/know, correct, delete, and
opt out of sale/sharing, as well as to receive equal service for exercising rights.

EU/UK: You may have rights to access, rectification, erasure, restriction, portability, and objection; and the right to withdraw consent.

Marketing communications: You can opt out of marketing emails via unsubscribe links and reply STOP to end marketing texts (message/data rates may apply).

How to exercise: email privacy@thecreativeclose.com.
We will verify your request and respond within the time required by law. Authorized agents may submit requests where permitted.
For CPRA, you can opt out of “sharing” for cross-context ads by adjusting your cookie preferences via our
Cookie Policy or by emailing us.

Do Not Sell or Share My Personal Information: Adjust cookies in the Cookie Policy
or email us at privacy@thecreativeclose.com.

California Notice at Collection

We collect the following categories (as defined by CPRA): Identifiers; Contact and Property info; Commercial info; Internet/Technical data; Geolocation (coarse);
Communications; Inferences. See Personal Information We Collect and How We Use for purposes.
We retain data as described in Data Retention. We do not sell personal information for money;
we may “share” certain Internet/Technical data for cross-context behavioral advertising—adjust preferences in our
Cookie Policy or email privacy@thecreativeclose.com.

Children’s Privacy

The Site is intended for adults. We do not knowingly collect personal information from children under 13 (U.S.) or under 16 (EU/UK).
If you believe a child has provided personal information, contact us to request deletion.

International Data Transfers

We are based in the United States. If you access the Site from outside the U.S., your information may be transferred to and processed in the U.S.
Where required, we use appropriate safeguards (e.g., Standard Contractual Clauses) with our processors.

Changes to This Policy

We may update this Policy from time to time. The “Last updated” date reflects the most recent version. Material changes will be posted on this page.

How to Contact Us

Email: privacy@thecreativeclose.com

Mail: The Creative Close LLC, 10135 South Holland Rd, Fenwick, MI 48834, United States (Attn: Eric Lamb)