CRE Central Legal

Privacy Policy

This Privacy Policy explains how The Cauble Group, LLC d/b/a CRE Central ("CRE Central," "Company," "we," "us," or "our") collects, uses, discloses, and protects information when you use the CRE Pro software, crecentral.com and related websites, our courses, the CRE Accelerator program, and our community spaces (the "Services"), or otherwise interact with us. By using the Services, you acknowledge this Privacy Policy. Terms such as "Deal Data" have the meanings given in the CRE Pro Software Terms of Service.

1. Information We Collect

Information you provide to us

• Account and profile information: name, email address, phone number, company, community profile details, and login credentials. If you use the free Deal Analyzer, this includes the email address you provide to receive an access code.
• Payment and subscription information: plan selected, billing history, and payment details. Payments are processed by third-party payment processors. We receive transaction confirmations and limited card details (such as card type and last four digits) but do not store full card numbers.
• Deal Data: the information you input into or upload to the software, including deal parameters, financial assumptions, buy box criteria, addresses, purchase prices, rent rolls, operating statements, offering memoranda, broker flyers, due diligence documents, notes, and generated documents such as letters of intent. Deal Data may include information about third parties, such as tenant names in rent rolls or broker contact details. You are responsible for having the right to provide that information (see Section 10).
• AI prompts: questions and instructions you submit to AI features, and the responses generated.
• Communications: messages you send us, support requests, survey responses, testimonials, and posts or comments you make in community spaces.
• Event and program information: registrations, attendance, and participation in courses, calls, and in-person events.
• Consent records: opt-in records and timestamps for email and text messaging, and records of your acceptance of our terms.

Information we collect automatically

• Usage data: features used, tools opened, pages viewed, links clicked, session duration, and interactions with content and emails (such as opens and clicks).
• Device and log data: IP address, browser type, operating system, device identifiers, referring pages, and timestamps.
• Cookies and similar technologies: we and our providers use cookies, pixels, and local storage to keep you signed in, remember preferences, measure usage, and support marketing. See Section 9.
• Call and meeting recordings: some live sessions, office hours, coaching calls, and webinars are recorded, and automated note-taking or transcription tools may be used. We provide notice where recording occurs.

Information from other sources

• Service providers and platforms we use to run the business (community platform, payment processor, scheduling, email, CRM, and analytics providers) share information with us about your activity on those platforms.
• Publicly available business information, and information from partners or referrals, where permitted by law.

2. How We Use Information

We use information to:

• Provide, operate, and maintain the Services, including running your analyses, generating AI responses, storing your Deal Data, and syncing your account across our platforms.
• Process payments, manage subscriptions and renewals, and send transactional messages (receipts, renewal reminders, past-due notices, service announcements, and requests to accept updated terms).
• Provide member support and respond to requests.
• Personalize your experience and recommend relevant content, tools, and programs.
• Send marketing communications about our products, courses, events, and offers. You can opt out at any time (Section 7).
• Monitor, analyze, and improve the Services, including debugging, developing new features, and understanding aggregate usage patterns.
• Protect the Services and our members: verify accounts, enforce our Terms of Service, Acceptable Use Policy, and Terms of Enrollment, and detect and prevent fraud, abuse, and security incidents.
• Comply with legal obligations and defend legal claims.

Deal Data commitments. We do not sell your Deal Data. We do not use the contents of your Deal Data to market to you or to the third parties named in it. Company is also a licensed real estate brokerage, and Company, its principals, and its affiliates do not use your Deal Data or buy box criteria to source, pursue, compete for, or trade on your deals. We do not use your Deal Data to train AI models. Our AI model provider (currently Anthropic) processes prompts, relevant Deal Data, and uploaded documents only to generate responses for you, under commercial terms that prohibit it from using that information to train its models. It deletes that information from its systems within 30 days, except where longer retention is required by law or to investigate misuse.

3. How We Disclose Information

We disclose information in the following circumstances:

• Service providers: companies that perform services for us, including community and course hosting (Mighty Networks), web pages and CRM (GoHighLevel), software hosting (Vercel), payment processing (Stripe and Mighty Networks), AI model providers (currently Anthropic), database and file storage (Supabase), scheduling, email (including Google Workspace) and email delivery, analytics, transcription, and customer support tooling. They are permitted to use information only to perform services for us.
• Within our corporate family: among The Cauble Group, LLC brands and affiliates for the purposes described in this Policy, except that we do not share Deal Data for use in any brokerage, investment, or other business activity of Company or its affiliates.
• Professional advisors: lawyers, accountants, auditors, and insurers as needed.
• Legal and safety: to comply with law, subpoenas, or legal process; to enforce our agreements; or to protect the rights, property, or safety of CRE Central, our members, or others.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, information may be transferred as part of the transaction, subject to this Policy or successor terms with notice.
• With your direction or consent: for example, testimonials you approve, or information you choose to share publicly in community spaces.

Community spaces are visible to other members. Anything you post there, including deal discussions, can be seen by other members and should not include information you need to keep confidential.

We do not sell personal information for money. Depending on how "sale" and "sharing" are defined under certain state laws, the use of advertising and analytics cookies may qualify. Where required, we honor the opt-out mechanisms described in Sections 8 and 9.

4. Text Messaging (SMS)

If you opt in to receive text messages from us, our text messaging program is described in our SMS Program Terms. You can opt out at any time by replying STOP, and reply HELP for help. Message and data rates may apply.

The Cauble Group, LLC. DBA CRE Central ("we," "us," or "our") DOES NOT share customer opt-in information, including phone numbers and consent records, with any affiliates or third parties for marketing, promotional, or any other purposes unrelated to providing our direct services. All text messaging originator opt-in data is kept strictly confidential.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. Data Retention

We retain information for as long as needed to provide the Services and for legitimate business purposes:

• Account and Deal Data: for the life of your account. If your paid access ends, your saved deals are retained for 90 days. After account closure, Deal Data is retained for 90 days to allow reactivation and export, after which it may be deleted or de-identified, except where longer retention is required by law or needed for disputes.
• Billing records: as required by tax and accounting law.
• Consent and acceptance records: for at least three years, or one year after your subscription or enrollment ends if longer, and otherwise for as long as needed to demonstrate consent and acceptance.
• Community posts: may persist after account closure. You may delete your posts or request removal.
• Backups and logs: retained for limited periods and then deleted or overwritten.

6. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information, including encryption in transit and at rest, access controls, and vendor due diligence. No system is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your credentials confidential and for not uploading sensitive information such as Social Security numbers, bank account numbers, or consumer credit reports. If we learn of a security incident affecting your personal information, we will notify you and regulators as required by law.

7. Your Choices

• Marketing opt-out: use the unsubscribe link in any marketing email, reply STOP to text messages, or contact us. Transactional messages will continue while you have an account.
• Account information: you can review and update profile information in your account settings.
• Cookies: see Section 9 for controls.
• Privacy rights: see Section 8.

8. Your State Privacy Rights

Depending on where you live, including Tennessee and other states with comprehensive consumer privacy laws, and to the extent those laws apply, you may have the right to:

• Know and access the personal information we hold about you;
• Correct inaccurate personal information;
• Delete personal information we hold about you;
• Obtain a copy of your personal information in a portable format; and
• Opt out of targeted advertising, the sale or sharing of personal information, and profiling in furtherance of decisions that produce legal or similarly significant effects.

How to exercise your rights. Email [email protected] with your request. We will verify your identity, typically by confirming control of your account email, and respond within 45 days, which we may extend by an additional 45 days where permitted by law. You may authorize an agent to act for you where the law allows. We may ask the agent for proof of authorization.

Opting out of targeted advertising. You can opt out through our cookie controls where offered, by using the Global Privacy Control signal (see Section 9), or by emailing us.

Appeals. If we decline your request, you may appeal by replying to our decision. We will respond to your appeal within the time required by law and inform you of the outcome. If you are unsatisfied, you may contact your state Attorney General.

Sensitive information. We do not intentionally collect sensitive personal information and ask that you not upload it (see Section 6).

No discrimination. We will not deny you the Services or charge different prices for exercising privacy rights, except as permitted by law (for example, features that inherently require your data).

9. Cookies and Analytics

We use:

• Strictly necessary cookies: sign-in, security, and core functionality. These cannot be disabled.
• Functional cookies: preferences and settings.
• Analytics cookies: to understand usage and improve the Services.
• Marketing cookies and pixels: to measure campaigns and reach interested audiences.

You can control cookies through your browser settings, our cookie banner or preference center where offered, and opt-out tools offered by analytics and advertising providers. Where required by law, we honor the Global Privacy Control browser signal as an opt-out of targeted advertising for the browser sending it.

10. Third-Party Information in Deal Data

Rent rolls, offering memoranda, and due diligence materials often contain personal information about tenants, guarantors, sellers, and brokers. For that information, we act as a processor or service provider on your behalf: we store and process it to provide the Services to you and do not use it for our own marketing. You represent that you have a lawful basis and any necessary permissions to upload it, and you are responsible for responding to requests from those individuals. If a third party contacts us directly about information in your Deal Data, we may refer them to you or take action required by law.

11. Children

The Services are for adults and are not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us personal information, contact us and we will delete it.

12. Users Outside the United States

We are based in the United States and process information there. If you access the Services from outside the U.S., you understand that your information will be transferred to and processed in the U.S., where privacy laws may differ from those in your jurisdiction.

13. Do Not Track

Except for the Global Privacy Control as described in Section 9, we do not respond to browser Do Not Track signals, as no consistent industry standard exists.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or through the Services before the changes take effect. The "Effective Date" at the top shows the latest revision.

15. Contact Us

Privacy questions or requests: The Cauble Group, LLC d/b/a CRE Central, 1100 Douglas Avenue, Nashville, TN 37206, [email protected], (615) 854-7188.

Related documents: Terms of Service, Software Disclaimer, Acceptable Use Policy, Terms of Enrollment, and all legal documents.