Privacy Policy

1. Introduction and Scope

Blue Pebble Group, LLC ("Blue Pebble Group," "Company," "we," "our," or "us"), together with our wholly-owned subsidiaries—Blue Pebble Homes, LLC dba Blue Pebble Homes (real estate brokerage), Vanna Lending, LLC dba Blue Pebble Loans (mortgage brokerage), and Zeropoint Lending, LLC (mortgage lender)—(collectively, the "Blue Pebble Entities" or "Affiliated Companies") is committed to protecting the privacy of individuals who interact with our services.

This Privacy Policy ("Policy") describes how the Blue Pebble Entities collect, use, store, share, transfer, and protect your personal information when you interact with our websites (including www.bluepebblehomes.com, www.bluepebbleloans.com, and any related domains), applications, artificial intelligence systems (including our AI assistant "Avery"), lead generation programs, marketing campaigns, mobile communications, email communications, telephone communications, in-person interactions, and all related services (collectively, the "Services").

BY ACCESSING OR USING ANY OF OUR SERVICES, SUBMITTING ANY INFORMATION THROUGH OUR WEBSITES OR FORMS, COMMUNICATING WITH US BY ANY MEANS, OR OTHERWISE PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS POLICY, DO NOT USE OUR SERVICES OR PROVIDE YOUR INFORMATION TO US.

2. Definitions

For purposes of this Policy, the following terms shall have the meanings set forth below:

"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. This includes, but is not limited to: names, addresses, email addresses, telephone numbers, Social Security numbers, financial information, property information, transaction history, device identifiers, IP addresses, browsing history, geolocation data, and any other information that can be used to identify you.

"Lead Information" means any Personal Information obtained through lead generation activities, including but not limited to information submitted through web forms, purchased from third-party lead providers, obtained through advertising campaigns, received through referral arrangements, or otherwise acquired for the purpose of marketing real estate, mortgage, or related services.

"Affiliated Companies" or "Blue Pebble Entities" means Blue Pebble Group, LLC and all of its current and future subsidiaries, affiliates, parent companies, and entities under common ownership or control, including but not limited to Blue Pebble Homes, LLC, Vanna Lending, LLC, and Zeropoint Lending, LLC.

"Processing" means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction.

3. Information We Collect

3.1 Information You Provide Directly

We collect Personal Information that you voluntarily provide to us, including but not limited to:

• Contact information such as name, mailing address, email address, and telephone number
• Financial information such as income, assets, debts, credit history, bank account information, and employment information
• Property information such as property addresses, ownership history, property preferences, and transaction details
• Identification information such as Social Security number, driver's license, and other government-issued identification (where legally required)
• Communications content including messages, inquiries, and feedback

3.2 Information Collected Automatically

When you access our Services, we automatically collect certain information, including but not limited to:

• Device information such as IP address, browser type and version, operating system, device identifiers, and hardware model
• Usage data such as pages visited, links clicked, forms submitted, time spent on pages, referring URLs, and search queries
• Interaction logs with Avery and other AI systems, including timestamps, message content, and conversation history
• Location data including approximate geographic location derived from IP address or device settings

3.3 Information from Third Parties

We obtain Personal Information from various third-party sources, including but not limited to:

• Public records such as property ownership records, mortgage records, tax records, court records, and other publicly available information
• Credit reporting agencies such as Equifax, Experian, and TransUnion (with your authorization)
• Lead generation partners and marketing partners
• Social media platforms
• Data aggregators and data brokers
• Referral sources including real estate agents, mortgage brokers, and other service providers

4. How We Use Your Information

We use the Personal Information we collect for the following purposes:

• To provide real estate brokerage, mortgage lending, mortgage brokerage, property management, and related services
• To respond to your inquiries, requests, and communications
• To schedule appointments and connect you with licensed professionals
• To process transactions and facilitate closings
• To verify your identity and prevent fraud
• To underwrite and process loan applications
• To personalize your experience with our Services
• To send marketing and promotional communications (subject to your opt-out rights)
• To improve our Services, develop new features, and conduct research
• To comply with legal and regulatory requirements
• To train and improve our AI systems, including Avery

5. Intra-Group Data Sharing and Transfers

When you provide Personal Information to any Blue Pebble Entity—whether through lead forms, website submissions, Avery interactions, telephone calls, emails, text messages, in-person communications, or any other means—you consent to the following:

• Unrestricted Internal Transfers: Your Personal Information may be freely transferred, shared, copied, and used among Blue Pebble Group, LLC and all of its current and future subsidiaries, affiliates, and entities under common ownership or control.
• Perpetual License: By providing your Personal Information to any Blue Pebble Entity, you grant all Blue Pebble Entities a perpetual, irrevocable, royalty-free, worldwide license to use, store, copy, modify, analyze, and process your Personal Information for any lawful business purpose.
• Centralized Data Management: The Blue Pebble Entities maintain centralized databases and systems that may store and process Personal Information collected by any Affiliated Company.
• Future Entities: This consent extends to any subsidiaries, affiliates, or related entities that Blue Pebble Group, LLC may acquire, form, or become affiliated with in the future.
• No Sale to Unaffiliated Third Parties: We do not sell your Personal Information to unaffiliated third parties for their own marketing purposes. Internal transfers among the Blue Pebble Entities are not considered sales.

6. Disclosure to Third Parties

In addition to sharing among the Blue Pebble Entities, we may disclose your Personal Information to the following categories of third parties:

• Service Providers: Third-party vendors who perform services on our behalf, including CRM providers, email and SMS marketing platforms, payment processors, cloud hosting providers, analytics providers, identity verification services, title companies, appraisers, inspectors, and other settlement service providers.
• Advertising Partners: Digital advertising platforms and networks, including Meta (Facebook/Instagram), Google Ads, and other programmatic advertising partners, for purposes of targeted advertising, retargeting, lookalike audience creation, and campaign optimization.
• Business Partners: Non-affiliated providers to whom we may refer you at your request or with your consent, such as insurance providers, home warranty companies, moving services, and other real estate-related service providers.
• Regulators and Legal Authorities: Government agencies, regulators, law enforcement, and other parties when required by law, subpoena, court order, or government request, or when we believe disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others.
• Business Transfers: In connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy proceeding, your Personal Information may be transferred to the acquiring or surviving entity.

7. Lead Information and Lead Generation Programs

If you provide your information through our lead generation programs, advertising campaigns, website forms, or third-party lead sources, the following additional terms apply:

• Shared Rights: All Blue Pebble Entities shall have equal and full rights to contact, market to, nurture, and engage with you for real estate, mortgage, and related services.
• Non-Exclusivity: Your Lead Information is not exclusive to any single Blue Pebble Entity or agent. Multiple representatives from different Blue Pebble Entities may contact you regarding your inquiry.
• Lead Pool Programs: If your information is obtained through a lead pool or similar program, your information may be distributed to participating agents and may be subject to additional terms and conditions.
• Data Retention: Lead Information is retained for a minimum of four (4) years following your last engagement with any Blue Pebble Entity for compliance purposes, and may be retained indefinitely thereafter.

8. AI-Specific Disclosures (Avery)

When you interact with Avery or any other AI system operated by the Blue Pebble Entities, the following additional terms apply:

• Recording and Storage: All conversations with Avery are recorded, stored, and may be retained indefinitely. This includes the full content of your messages, timestamps, and any associated metadata.
• Use of Conversation Data: Conversation data may be used for quality assurance, compliance monitoring, marketing, lead follow-up, affiliate promotion, service improvement, AI training, and any other lawful business purpose.
• AI Limitations: Avery's responses are automatically generated by artificial intelligence and may be incomplete, inaccurate, outdated, or incorrect. You should verify any information provided by Avery with a licensed human professional before acting on it.
• No Professional Advice: Avery is not a licensed real estate broker, mortgage loan originator, attorney, or financial advisor. Nothing communicated by Avery should be considered legal, financial, real estate, or mortgage advice.

9. Communications Consent

BY PROVIDING YOUR CONTACT INFORMATION, YOU EXPRESSLY CONSENT TO RECEIVE COMMUNICATIONS FROM THE BLUE PEBBLE ENTITIES BY THE FOLLOWING MEANS:

• Telephone Calls: You consent to receive telephone calls, including calls made using automated telephone dialing systems and/or prerecorded or artificial voice messages, at any telephone number you provide, including mobile telephone numbers. You understand that providing consent is not a condition of purchasing any goods or services.
• Text Messages (SMS/MMS): You consent to receive text messages, including messages sent using automated systems, at any mobile telephone number you provide. Message and data rates may apply. Message frequency varies. Reply STOP to any message to opt out of text messages. Reply HELP for assistance.
• Email: You consent to receive emails, including marketing and promotional emails, at any email address you provide. You may unsubscribe from marketing emails by following the instructions in the email.
• Other Communications: You consent to receive communications through any other channel, including but not limited to direct mail, social media messaging, and push notifications.

10. Data Retention

We retain Personal Information for a minimum of four (4) years following your last engagement with any Blue Pebble Entity for compliance, legal, regulatory, and audit purposes. After this minimum retention period, we may retain your Personal Information indefinitely in our discretion for analytics, marketing, business continuity, and other lawful purposes. Even after you request deletion of your information, we may retain certain information as required by law or for legitimate business purposes, including to comply with legal obligations, resolve disputes, enforce our agreements, and maintain business records.

11. Cookies, Tracking Technologies, and Online Advertising

We use cookies, pixels, web beacons, and similar tracking technologies to collect information about your interactions with our Services. These technologies may be used for the following purposes:

• Essential Functionality: To enable core website functionality, maintain sessions, and ensure security.
• Analytics: To analyze usage patterns, measure performance, and improve our Services. We use Google Analytics and similar analytics tools.
• Advertising: To deliver targeted advertising, measure advertising effectiveness, and build audiences for advertising purposes. We use Meta Pixel (Facebook/Instagram), Google Ads, and other advertising technologies.
• Retargeting: To show you advertisements for our Services on third-party websites and platforms based on your prior interactions with our Services.

Most web browsers allow you to control cookies through their settings. However, disabling cookies may limit your ability to use certain features of our Services.

12. Your Privacy Rights

Depending on your location, you may have certain rights regarding your Personal Information under applicable privacy laws, including the California Consumer Privacy Act (CCPA), the Colorado Privacy Act (CPA), and other state privacy laws. These rights may include:

• Right to Know: The right to request information about the categories and specific pieces of Personal Information we have collected about you.
• Right to Delete: The right to request deletion of your Personal Information, subject to certain exceptions.
• Right to Correct: The right to request correction of inaccurate Personal Information.
• Right to Opt Out of Sale/Sharing: The right to opt out of the "sale" or "sharing" of your Personal Information as those terms are defined under applicable law. Note that internal transfers among the Blue Pebble Entities are not considered sales.
• Right to Non-Discrimination: The right not to be discriminated against for exercising your privacy rights.

To exercise your rights, please contact us using the information provided in Section 17 or visit our Do Not Sell or Share My Personal Information page. We may require you to verify your identity before processing your request.

13. Do Not Sell or Share My Personal Information

We do not sell your Personal Information to unaffiliated third parties for monetary consideration. However, certain data sharing activities with advertising partners may constitute "sharing" under California law. To opt out of such sharing for cross-context behavioral advertising purposes, please visit www.bluepebblehomes.com/do-not-sell or contact us at the address provided in Section 17.

14. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your Personal Information against unauthorized access, use, alteration, and destruction. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee the absolute security of your information, and you provide your information at your own risk.

15. Children's Privacy

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect Personal Information from children under 18. If we learn that we have collected Personal Information from a child under 18, we will take steps to delete that information promptly.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on our website with a revised effective date. Your continued use of our Services after any changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically.

17. Contact Information

For questions, concerns, requests regarding this Privacy Policy, our privacy practices, or to submit a data deletion request, please contact us at:

18. Governing Law

This Privacy Policy is governed by the laws of the State of Colorado, without regard to its conflict of laws principles.

19. Affiliate Disclosures

You are never required to use any affiliated service offered by the Blue Pebble Entities. However, you may receive pricing advantages, discounts, or other benefits if you choose to work with multiple affiliates. Please review our disclosures for more information:

• Affiliated Business Arrangement Disclosure
• Anti-Steering Disclosure
• Blue Pebble Loans Email Disclosure