What we collect, why, who sees it, and how to get it back. This is the whole notice; nothing is hidden in a separate document.
This Privacy Notice for Sorrentino L.L.C. (doing business as FOLLOWap) ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@followap.co.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See section 1.
Do we process any sensitive personal information? No. We do not process information such as racial or ethnic origins, sexual orientation, or religious beliefs.
Do we collect any information from third parties? No. We do not buy or pull information about you from data brokers, social media, or public records.
How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so. See section 2.
With whom do we share personal information? Only with the service providers that run the product for us, listed by category in section 3. We do not sell or share personal information for advertising.
How do we keep your information safe? Through organizational and technical measures described in section 6. No electronic transmission or storage can be guaranteed 100% secure.
What do we do with your Google account if you connect Gmail? Only send the emails you write or approve and press Send on. We never read, search or store your inbox. See section 15.
What are your rights? Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of your personal information. See section 8 and section 10.
How do you exercise your rights? Email support@followap.co. We will consider and act upon any request in accordance with applicable data protection laws.
In short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive information. We do not process sensitive information.
Logos and headshots. If you add them, we keep one logo and one headshot per account, to sign the private client pages you send. When you upload one, we resize it to at most 1600 pixels, compress it, and remove its location and other EXIF data before we store it; the file from your phone is not kept. A new upload replaces the old one, which we delete from storage at once, and Remove deletes it. We keep no other images: photos of homes and award badges are not uploaded or stored. Your logo and headshot are kept in a private storage bucket with our hosting provider and are shown only through FOLLOWap, to you and to the people you send a list's private link.
Payment data. Subscription payments are processed by Stripe. Card numbers are entered on Stripe's hosted checkout and never pass through or are stored on FOLLOWap's systems. We retain only the billing name, email address, plan and payment status needed to manage your subscription. You may find Stripe's privacy notice here: https://stripe.com/privacy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In short: Some information, such as your Internet Protocol (IP) address and browser characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include your IP address, browser type and version, operating system, referring URLs, and information about how and when you use our Services. This information is needed to maintain the security and operation of our Services. It is not used for advertising, and we run no analytics or tracking scripts.
The information we collect includes:
In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In short: We share information only with the service providers that run the product for us, and in the specific situations described below.
Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The categories of third parties we may share personal information with are as follows:
We may also need to share your personal information in the following situation:
We do not share personal information with advertisers, data brokers, or business partners for their own marketing.
In short: One cookie, to keep you logged in. No third-party tracking.
The FOLLOWap app sets a single cookie that keeps you signed in to your account. It is strictly necessary for the service to work, expires after 14 days, and is not used to track you across other websites. The marketing website at followap.co sets no cookies of its own.
We do not use web beacons, pixels, analytics scripts, or advertising trackers, and we do not permit third parties to place them on our Services.
If you arrive from one of our advertisements, the campaign details carried in the link and the address of the site that referred you are kept in your browser's session storage and are submitted with the early access form if you choose to submit it, so we can tell which advertisement reached you. Nothing is sent if you do not submit the form, and session storage is cleared when you close the tab. This is first-party only: no cookie is set and no third party receives it.
If you set your browser to reject cookies, you will not be able to stay logged in to the app.
In short: For as long as you have an account, plus 30 days.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than one (1) month past the termination of your account. During that month your data remains available for you to export.
Logos and headshots are kept while your account is open, until you replace or remove them, which deletes them at once. If you close your account, we delete them within 30 days: we keep them three weeks in case you reopen it, then delete them from storage.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These include encryption in transit, encryption of client contact details before they are stored, hashed passwords, database-level isolation between accounts, and logging of security events. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@followap.co.
In short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the details in section 13. This will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details in section 13. You will then be removed from the marketing lists. However, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or email us.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases after the 30-day export window described in section 5. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at support@followap.co.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. Since we do not track you across websites in any case, a DNT signal makes no practical difference to how we treat your data.
In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. We honor these requests from residents of any state.
The table below shows the categories of personal information we have collected in the past twelve (12) months. The examples are illustrative; for a full inventory see section 1.
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications | YES |
| J. Education information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| L. Sensitive personal information | NO |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys, and facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or, for Categories A, B, D, F and I, for as long as the user has an account with us, plus 30 days after the account is closed, during which the user may export their data before it is permanently deleted.
See section 1. We do not obtain personal information about you from third-party sources.
See section 2 and section 3. We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to service providers for a business or commercial purpose in the preceding twelve (12) months: Category A (Identifiers), Category B (Personal information as defined in the California Customer Records law), Category D (Commercial information), Category F (Internet or other electronic network activity information), and Category I (Professional or employment-related information). The categories of third parties to whom we disclosed personal information can be found in section 3.
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
Depending upon the state where you live, you may also have the following rights:
To exercise these rights, email us at support@followap.co.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at support@followap.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not disclose personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details in section 13.
FOLLOWap is used by licensed real estate agents to stay in contact with their own past clients. To do this, agents upload contact information about those clients, such as names, home addresses, phone numbers, email addresses, and notes about past transactions. We refer to this as "Client Data."
We did not collect Client Data from the individuals it describes. We process it only on behalf of the agent who uploaded it, only for the purpose of helping that agent contact their own clients, and only on that agent's instructions. In the terminology of the California Consumer Privacy Act, we act as a service provider to the agent, and the agent is the business responsible for that data.
We do not sell or share Client Data, use it for advertising, combine it across agents, or contact anyone in it ourselves. Every message drafted by FOLLOWap is reviewed and sent by the agent from their own device; FOLLOWap never sends anything automatically.
Client Data is encrypted before it is stored, is accessible only to the agent who uploaded it and any team member that agent explicitly authorizes, and is never removed by us except when the agent removes it, the agent's account is closed, or we receive a verified legal request.
If you believe a real estate agent has your information in FOLLOWap and you wish to access, correct, or delete it, contact that agent first, as they control the data. You may also contact us at support@followap.co. We will verify your request, act on it in accordance with applicable law, and inform the relevant agent.
In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact us by email at support@followap.co.
Sorrentino L.L.C.
United States
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email support@followap.co. Account holders can also export their full data at any time from inside the app.
In short: If you connect Gmail, FOLLOWap can send the emails you write or approve, from your own address, when you press Send. It cannot read your inbox, and it never does.
FOLLOWap lets a real estate agent send an email to a client from their own Gmail address instead of from ours. This is optional. It starts only when you choose Connect Gmail in FOLLOWap's setup and agree on Google's own permission screen.
With your permission, FOLLOWap receives two things from your Google account, and nothing else:
That permission lets FOLLOWap send. It does not let FOLLOWap open, read, search or download anything in your mailbox. FOLLOWap never reads, searches or stores your inbox, your other emails, your contacts or your calendar.
FOLLOWap sends only an email that you wrote, or that FOLLOWap drafted and you approved, and only when you press Send. It never sends anything on its own, on a schedule, or in bulk.
The sign-in tokens Google gives us for your account are encrypted before they are stored, and they are never shown to anyone, written to a log, or included in an error report. When you press Disconnect in FOLLOWap, we ask Google to cancel the permission and we delete the tokens. You can also remove FOLLOWap's access at any time yourself, in your Google account's security settings, under third-party apps with account access.
Information we receive from your Google account:
FOLLOWap's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
FOLLOWap's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements. Google user data is never used to develop, improve or train generalized or foundational AI or machine learning models, and is never sent to any AI service. Voice requests are transcribed by an open-source speech model hosted on FOLLOWap's own servers; audio is never sent to the model's maker.
Questions about this section can go to support@followap.co.