Agreement to Terms

By interacting with ClearPort Capital — including receiving or responding to our phone calls, SMS messages, visiting our website, or otherwise engaging with our services — you agree to be bound by these Terms of Service (“Terms”). These Terms govern the relationship between you and Rocca Capital Group, Inc. (“ClearPort Capital,” “we,” “us,” or “our”). If you disagree with any part of these Terms, please inform us and we will cease communications with you.

Description of Services

ClearPort Capital provides real estate outreach and acquisition services targeting property owners nationwide. Our services include:

• AI-powered inbound call handling for property owner inquiries
• Outbound calling campaigns to real estate property owners
• SMS and text message communications for follow-ups and scheduling
• Call recording and transcription (with appropriate disclosure and consent)
• Property evaluation and acquisition facilitation
• Appointment scheduling and coordination

AI Technology Disclosure

ClearPort Capital utilizes AI-powered calling technology to facilitate professional, efficient communications with property owners. We believe in full transparency about our use of this technology.

Technology We Use

• 24/7 CallDesk: AI-powered voice assistant platform for managing inbound and outbound calls, including real-time conversation handling and transcription
• Twilio: Telephony and SMS infrastructure for call routing, voice communications, and text message delivery

How AI Processes Calls

When a call is placed or received through our system:

1. Voice audio is processed through speech-to-text technology
2. AI language models generate contextually appropriate responses
3. Responses are converted back to speech in real time
4. Conversations may be transcribed and stored for quality and compliance

AI Training Data Policy

We do NOT use your call recordings, transcripts, or personal data to train AI models. Your conversations remain private and are used solely for service delivery, quality assurance, and compliance purposes.

Third-Party Service Providers

We partner with trusted third-party companies to operate our services. Each provider receives only the data necessary to perform their specific function:

• 24/7 CallDesk: AI voice assistant — processes call audio and conversation data
• Twilio: Telephony and SMS — routes calls, delivers text messages, provides phone infrastructure

For complete details on data sharing, see our Privacy Policy.

Acceptable Use Policy

When engaging with ClearPort Capital’s services, you agree not to:

• Provide false or misleading information about property ownership or identity
• Harass, abuse, threaten, or act inappropriately toward our representatives or AI systems
• Attempt to gain unauthorized access to our systems, data, or technology
• Use information obtained from our calls or communications for fraudulent purposes
• Record calls without proper consent where required by applicable law
• Interfere with or disrupt our services, systems, or communications infrastructure

Call Recording Compliance

ClearPort Capital may record and transcribe phone calls for quality assurance, training, compliance, and record-keeping purposes.

Our Commitments

• All parties will be notified at the beginning of any recorded call
• You may request that recording be stopped at any time during a call
• Recordings are stored securely and retained per our data retention policy
• Access to recordings is limited to authorized personnel only

Call Recording Jurisdiction Guide

Because ClearPort Capital contacts property owners nationwide, we comply with the most restrictive applicable recording laws. Below is a reference for key states:

TCPA Compliance

ClearPort Capital complies with the Telephone Consumer Protection Act (TCPA) and all applicable federal and state telemarketing regulations when conducting outbound calling campaigns to property owners.

Our TCPA Practices

• Do Not Call Registry: We scrub our call lists against the National Do Not Call Registry before conducting outbound campaigns
• Internal Do Not Call list: We maintain and honor our own Do Not Call list and process removal requests promptly
• Calling hours: Outbound calls are placed only during permitted hours (8 AM – 9 PM recipient’s local time)
• Caller identification: We identify ourselves and ClearPort Capital at the beginning of each outbound call
• Consent records: We maintain records of consent and opt-outs as required by law
• Opt-out mechanisms: Clear opt-out instructions are provided in all SMS messages and upon request during calls

SMS Terms and Conditions

By opting in to receive SMS messages from ClearPort Capital, you agree to receive text messages related to our real estate services. Message and data rates may apply. Reply STOP to cancel at any time.

Types of SMS Messages

• Follow-up messages: After a phone conversation about your property
• Appointment confirmations: Scheduling and rescheduling notifications
• Property inquiries: Initial outreach regarding real estate opportunities
• Transactional updates: Status updates on ongoing discussions or transactions

Opt-Out Instructions

You can opt out of receiving SMS messages at any time by:

• Replying STOP to any message from ClearPort Capital
• Emailing jrocca@clearportcapital.com with the subject “SMS Opt-Out”
• Requesting removal during any phone call

After opting out, you will receive a one-time confirmation message. You will no longer receive SMS messages from us unless you opt in again.

Help and Support

For help with SMS messaging, reply HELP to any message or email jrocca@clearportcapital.com.

Message Frequency and Rates

• Message frequency: Varies based on outreach activity and your level of engagement
• Message and data rates: Standard carrier messaging and data rates may apply
• Carrier compatibility: SMS services are available on most major US carriers

Carrier Liability Disclaimer

Carriers (AT&T, Verizon, T-Mobile, etc.) are not liable for delayed or undelivered messages. Message delivery is subject to carrier network availability.

Do Not Call Compliance

ClearPort Capital maintains a robust Do Not Call compliance program in accordance with the TCPA and FTC Telemarketing Sales Rule.

• We scrub all call lists against the National Do Not Call Registry prior to outbound campaigns
• We maintain an internal company-specific Do Not Call list
• Requests to be added to our Do Not Call list are processed within 30 days
• Numbers on our Do Not Call list are retained indefinitely to prevent future contact

To be added to our Do Not Call list, say “Do Not Call” or “Remove me” during any call, reply STOP to any SMS, or email jrocca@clearportcapital.com with the subject “Do Not Call.”

Intellectual Property Rights

Our Rights

ClearPort Capital (Rocca Capital Group, Inc.) retains all rights, title, and interest in our brand, trademarks, logos, website content, marketing materials, technology, and proprietary business processes.

Your Rights

You retain ownership of any personal information, property details, and other data you provide to us. We use this information solely to provide our services and as described in our Privacy Policy.

Data Protection and Privacy

Our collection, use, and protection of your data is governed by our Privacy Policy. Please review it to understand how we handle your information.

While we implement industry-standard security measures, no method of transmission over the internet or electronic storage is 100% secure. You engage with our services at your own risk.

Disclaimers and Limitations

OUR SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. WE DISCLAIM ALL WARRANTIES INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CLEARPORT CAPITAL (ROCCA CAPITAL GROUP, INC.) SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS OR REVENUES, WHETHER INCURRED DIRECTLY OR INDIRECTLY.

ClearPort Capital does not guarantee the accuracy of property valuations, market assessments, or any opinions provided during calls. All information shared during calls is for general informational purposes and does not constitute legal, financial, or real estate advice. Consult with qualified professionals before making real estate decisions.

Indemnification

You agree to indemnify, defend, and hold harmless ClearPort Capital (Rocca Capital Group, Inc.), its officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses (including reasonable attorney fees) arising from:

• Your provision of false or misleading information
• Your violation of these Terms
• Your violation of any laws or third-party rights
• Disputes arising from real estate transactions facilitated through our services
• Your recording of calls without proper consent in applicable jurisdictions

Termination

Either party may terminate this relationship at any time. You may request that we stop all communications by contacting us at jrocca@clearportcapital.com or by requesting removal during any phone call.

Upon termination of communications, we will cease all outbound contact, add your number(s) to our Do Not Call list, and retain your opt-out records indefinitely to prevent future contact. Any data subject to legal retention requirements will be maintained as required by law.

Dispute Resolution

Any disputes arising from these Terms or our services shall be resolved through:

1. Good faith negotiation: Contact us at jrocca@clearportcapital.com to discuss the issue
2. Binding arbitration: If negotiation fails, disputes will be resolved through binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules
3. Governing law: These Terms are governed by the laws of the State of California, without regard to conflict of law principles
4. Class action waiver: You agree to resolve disputes individually, not as part of a class action or consolidated proceeding

Changes to Terms

We reserve the right to modify these Terms at any time. We will update the “Last updated” date at the top of this page to reflect changes. Your continued engagement with our services after changes become effective constitutes acceptance of the updated Terms.

General Provisions

• Entire Agreement: These Terms, together with our Privacy Policy, constitute the entire agreement between you and ClearPort Capital regarding our services
• Severability: If any provision is found unenforceable, the remaining provisions remain in full force
• Waiver: Our failure to enforce any right does not constitute a waiver of that right
• Assignment: We may assign these Terms without restriction. You may not assign your rights under these Terms
• Force Majeure: Neither party shall be liable for failure or delay due to causes beyond reasonable control

Contact Information

For questions, concerns, or requests regarding these Terms of Service, please contact us:

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

We aim to respond to all inquiries within 48 hours on business days.