Your Client Data Stays Yours. Period.
How AgentPavilion collects, processes, protects, and governs real estate business information, portal webhook events, and inbound consumer inquiries across our managed operating platform.
Comprehensive Data Protection & Privacy Governance
This Privacy Policy governs all portal webhook ingestions, speed-to-lead communication workflows, and website visitor data across the AgentPavilion platform, effective July 2026.
Absolute Realtor Data Ownership & Zero-Reselling Guarantee
Independent realtors, brokerages, and producing teams retain exclusive 100% proprietary ownership of all client dossiers, consumer inquiries, contact telephone numbers, email addresses, CRM tags, and showing notes ingested into or generated through AgentPavilion. AgentPavilion operates strictly as a Data Processor under US privacy law. We do not sell, license, rent, monetize, aggregate, or cross-market your client or prospect data to third-party marketing companies, lead generation aggregators, lenders, or competitor real estate agents under any circumstances.
Categories of Information Ingested & Processed
We collect and process three primary categories of information: (a) Subscriber Account Information: Licensed agent/broker name, brokerage affiliation, license jurisdiction, business email, billing details, and API tokens for connected CRMs; (b) Inbound Lead Webhooks & Portal Inquiries: Consumer contact details (first/last name, phone number, email) and property search metadata (listing address, MLS identifier, asking price, tour request dates) submitted via Zillow Premier Agent, Realtor.com, Homes.com, or your AgentPavilion website tour forms; (c) Operational Delivery Records: Speed-to-lead SMS transmission timestamps, carrier delivery receipts, buyer response text, showing calendar confirmations, and agent disposition tags.
TCPA, 10-DLC & CTIA Messaging Compliance
AgentPavilion complies rigorously with the Telephone Consumer Protection Act (TCPA), the Federal Communications Commission (FCC) one-to-one consent rulings, and carrier A2P 10-DLC campaign standards. Automated SMS touches are triggered exclusively in direct response to verified consumer inquiries requesting property showings or market valuation data. All SMS messages clearly identify the licensed agent and brokerage, and explicitly inform recipients: 'Reply STOP to cancel, HELP for help. Msg & data rates may apply.' All opt-out requests (STOP, END, CANCEL, UNSUBSCRIBE, QUIT) are immediately processed via real-time carrier webhooks, permanently preventing automated outbound communication to that number unless affirmative consent is re-initiated by the consumer.
Purpose & Scope of Data Processing
We process information exclusively to execute your speed-to-lead workflows: (a) Delivering sub-60s SMS and email responses to verify buyer timeline and coordinate showing availability; (b) Bi-directionally syncing conversation history, lead stages, and showing dossiers into your system of record (Follow Up Boss, kvCORE, Lofty); (c) Providing executive operational reporting on team response speed, touch conversion, and 90-day lead reactivation; (d) Facilitating client showings and human agent handoffs.
AI Processing & Risk-Based Review Boundaries
AgentPavilion utilizes natural language processing models strictly within deterministic, sandboxed guardrails. Client and inquiry data processed through our response engine is never utilized to train public foundational AI models or shared with unauthorized third parties. Automated drafting strictly enforces Fair Housing filters to ensure responses remain purely focused on verified MLS property facts, showing logistics, and agent consultation—preventing demographic commentary, neighborhood stereotyping, or unauthorized commitments.
Data Security, Cryptographic Isolation & Storage
We maintain industry-standard administrative, physical, and technical safeguards. All data in transit is encrypted using modern TLS 1.3 cryptographic protocols; all data at rest is encrypted using AES-256 standard encryption. Database architectures implement strict multi-tenant tenant isolation and row-level access boundaries to ensure complete data segregation between different brokerages and agent accounts. Access to production systems is restricted to authorized personnel via role-based access control and multi-factor authentication.
Third-Party Service Providers & Sub-Processors
We partner with trusted infrastructure sub-processors under strict data processing agreements requiring compliance with applicable privacy regulations. Sub-processors include cloud hosting providers (AWS, Cloudflare), carrier messaging infrastructure (Twilio), transactional email gateways, and authorized CRM partners via official OAuth/API integrations. Sub-processors are granted access strictly to the minimum data necessary to perform their respective routing or hosting services.
Consumer Privacy Rights (CCPA / CPRA & State Laws)
Pursuant to the California Consumer Privacy Act as amended (CCPA/CPRA) and applicable state privacy statutes, consumers have the right to request: (a) Disclosure of categories and specific pieces of personal information collected; (b) Correction of inaccurate personal data; (c) Complete deletion of their personal information ('Right to be Forgotten'); and (d) Opt-out of any processing deemed a 'sale' or 'sharing' (which AgentPavilion does not engage in). Inquiries may be submitted to privacy@agentpavilion.com or directly to the subscriber real estate agent who serves as the primary Data Controller.
Data Retention & Account De-Provisioning
We retain lead activity records and communication logs for the duration of the subscriber's active account to maintain 90-day recovery ledgers and historical pipeline reporting. Upon subscription cancellation or written notice, subscribers may request a full export of their lead database in CSV/JSON format within 30 calendar days. Following the export grace period, all proprietary subscriber client records and CRM caches are permanently scrubbed from our active production databases in accordance with our data sanitization policy.
Contacting Our Data Governance Team
If you have questions regarding this Privacy Policy, wish to exercise data privacy rights, or require a signed Data Processing Addendum (DPA) for your brokerage, please contact our Data Protection Office at: AgentPavilion Data Governance, Attn: Privacy Officer, Email: privacy@agentpavilion.com, Physical: Florida, USA.
