Introduction

ClearPort Capital (operated by Rocca Capital Group, Inc.) is committed to protecting your privacy. This policy explains how we collect, use, share, and safeguard your information when you interact with our services, including when we contact real estate property owners via phone calls and SMS messages nationwide.

By engaging with ClearPort Capital — whether through our website, by receiving or responding to our calls or messages, or by providing us with your information — you acknowledge this Privacy Policy. If you disagree with any part of this policy, please let us know and we will cease communications with you.

Information We Collect

We collect information from multiple sources in connection with our real estate outreach and communications services.

Information You Provide to Us

• Contact information: Name, email address, phone number, mailing address
• Property information: Property addresses, ownership details, property type, and related real estate data
• Communication preferences: Opt-in/opt-out preferences, preferred contact methods
• Correspondence: Messages, emails, or information you share with us during calls or via text

Information Collected Automatically

• Call data: Voice recordings (when enabled and disclosed), call transcripts, caller phone numbers, call duration, timestamps
• SMS data: Message content, delivery status, opt-in/opt-out responses
• Website data: IP address, browser type, device information, pages visited, usage patterns
• Analytics data: How you interact with our website and communications

Information from Public and Third-Party Sources

• Public records: Property ownership records, tax assessor data, county records
• Data providers: Real estate data aggregators, property databases, skip-tracing services
• Commercially available data: Phone numbers, mailing addresses, and other contact information associated with property ownership

SMS Consent and Mobile Privacy

When you opt in to receive SMS messages from ClearPort Capital, we collect your mobile phone number and consent preferences. This section explains how we handle your SMS-related data.

How We Collect SMS Consent

We obtain your consent to send SMS messages through:

• Website forms: When you provide your phone number and opt in to receive text messages
• Text-to-join: When you text a keyword to our phone number
• Verbal consent: When you verbally agree to receive SMS notifications during a phone call
• Written agreements: When you sign or acknowledge a form authorizing text communications

Limited Sharing for Service Delivery

We share your mobile phone number only with the following service providers, solely to deliver SMS messages on our behalf:

• Twilio: Our SMS and telephony infrastructure provider that transmits messages and facilitates calls. Twilio is contractually prohibited from using your data for any purpose other than service delivery.

Managing Your SMS Preferences

You can opt out of SMS messages at any time by replying STOP to any message, emailing jrocca@clearportcapital.com, or requesting removal during any phone call.

How We Use Your Information

We use your data for the following purposes:

• Real estate outreach: Contacting property owners regarding potential opportunities, acquisitions, and services
• Inbound call handling: Answering and managing incoming calls from property owners and interested parties
• Outbound calling campaigns: Reaching out to property owners nationwide via phone to discuss real estate opportunities
• SMS communications: Sending follow-up messages, appointment confirmations, and relevant updates
• Service delivery: Processing inquiries, scheduling appointments, and managing transactions
• Compliance: Maintaining Do Not Call lists, consent records, and regulatory compliance documentation
• Analytics: Understanding campaign effectiveness using anonymized, aggregated data
• Legal obligations: Responding to legal requests and enforcing our Terms of Service

AI Data Processing

ClearPort Capital utilizes AI-powered calling technology to facilitate both inbound and outbound calls with property owners. Our AI voice assistant processes conversations in real time to provide responsive, professional interactions.

Technology Providers

• 24/7 CallDesk: Our AI-powered voice assistant platform that handles inbound and outbound call management, conversation handling, and transcription
• Twilio: Telephony infrastructure that facilitates call routing, SMS delivery, and voice communications

How AI Processes Your Data

When a call is placed or received, voice audio may be processed through speech-to-text conversion, AI language models generate appropriate responses, and conversations may be transcribed and stored for quality assurance and compliance purposes.

Data Sharing and Third-Party Processors

We do not sell your personal information. We share data only with trusted service providers necessary to operate our communications and real estate services.

Service Providers

• 24/7 CallDesk: AI voice assistant platform — receives call audio and conversation data
• Twilio: Telephony and SMS infrastructure — receives phone numbers, call data, and message content
• Data providers: Real estate and property data services — provide property ownership and contact information

Other Sharing Scenarios

• With your consent: When you explicitly agree to share your information
• For legal compliance: When required by law, court order, subpoena, or government request
• In business transfers: If Rocca Capital Group, Inc. is acquired or merges with another entity
• To protect rights and safety: To enforce our Terms, protect against fraud, or ensure safety

Data Security

We implement industry-standard security measures to protect your data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: Data encrypted in transit (TLS) and at rest
• Access controls: Role-based permissions and least-privilege access for all team members
• Vendor oversight: Security reviews of all third-party service providers
• Incident response: Documented procedures for security incidents and data breaches

While we implement strong security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security. If you become aware of any security concern, please contact us at jrocca@clearportcapital.com.

Data Retention

• Contact and property data: Retained as long as necessary for ongoing business operations and outreach
• Call recordings: Retained for 90 days by default, unless a longer period is required for compliance or legal purposes
• Call transcripts: Same retention period as call recordings
• SMS records: Retained for the duration required by TCPA and applicable regulations
• Opt-out and Do Not Call records: Retained indefinitely to ensure ongoing compliance
• Anonymized analytics: Retained indefinitely (contains no personally identifiable information)

When data is no longer needed, it is securely deleted from our production systems. Upon request, we will delete your personal data within 30 days, subject to legal retention obligations.

Your Privacy Rights

You have the following rights regarding your personal data:

• Right to access: Request a copy of the personal data we hold about you
• Right to correction: Request correction of inaccurate or incomplete data
• Right to deletion: Request deletion of your personal data (subject to legal obligations)
• Right to opt out: Opt out of calls, SMS messages, and marketing communications at any time
• Right to be placed on our Do Not Call list: Request to be added to our internal Do Not Call list at any time

To exercise any of these rights, contact us at jrocca@clearportcapital.com. We will respond within 30 days.

CCPA Compliance (California Residents)

For California residents, we comply with the California Consumer Privacy Act (CCPA).

Your CCPA Rights

• Right to know: Request disclosure of what personal information we have collected, used, or disclosed in the past 12 months
• Right to deletion: Request deletion of your personal information (subject to exceptions)
• Right to opt-out of “sales”: We do NOT sell your personal information
• Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights

Categories of Information We Collect

• Identifiers: Name, email, phone number, mailing address, IP address
• Property information: Property addresses, ownership records, property characteristics
• Internet/network activity: Website usage data, device information
• Audio data: Call recordings, voice data (when recording is enabled and disclosed)
• Geolocation data: General location derived from IP address

To make a CCPA request, email jrocca@clearportcapital.com with the subject line “CCPA Request.” We will verify your identity and respond within 45 days.

TCPA and Calling Compliance

ClearPort Capital complies with the Telephone Consumer Protection Act (TCPA) and all applicable federal and state telemarketing regulations. Our calling and texting practices include:

• Maintaining and honoring the National Do Not Call Registry
• Maintaining an internal Do Not Call list and processing removal requests promptly
• Calling only during permitted hours (8 AM – 9 PM recipient’s local time)
• Providing clear identification at the beginning of each call
• Offering opt-out mechanisms in all SMS messages
• Retaining consent records as required by law

If you wish to be placed on our Do Not Call list, please contact us at jrocca@clearportcapital.com or inform any representative during a call.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience and analyze usage patterns.

• Essential cookies: Required for the website to function (cannot be disabled)
• Analytics cookies: Help us understand how visitors interact with our website
• Preference cookies: Remember your settings and preferences

You can control cookies through your browser settings. Disabling essential cookies may affect website functionality.

Children’s Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us at jrocca@clearportcapital.com and we will delete such information immediately.

Do Not Call Policy

ClearPort Capital maintains a company-specific Do Not Call list. If you request to be placed on this list, we will cease all outbound calling to your number within 30 days and retain your number on our suppression list indefinitely to prevent future contact. To be added to our Do Not Call list:

• Say “Do Not Call” or “Remove me” during any phone call
• Reply STOP to any SMS message
• Email jrocca@clearportcapital.com with the subject “Do Not Call”

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the “Last updated” date at the top of this page. Your continued engagement with our services after changes become effective constitutes acceptance of the updated Privacy Policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: jrocca@clearportcapital.com
• Company: Rocca Capital Group, Inc.
• Location: Los Angeles, California

We aim to respond to all privacy-related requests within 30 days.