California Resident Privacy Notice

Last Updated: September 2026

California Resident Privacy Notice

1. About this notice

This California Resident Privacy Notice (“California Privacy Notice”) supplements the information and disclosures contained in our Privacy Policy. It is delivered on behalf of Scryer, Inc. d/b/a Reonomy (“Reonomy”) and governs the personal information we collect from California residents (“you”) on any website on which a link to this California Privacy Notice appears and any personal information we collect in connection with delivering services to you or communicating with you, which may include providing you with other product offerings (collectively, the “Services”).

We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”).  Please take the time to read and understand this California Privacy Notice.

2. Scope

It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA. Our California Applicants, Employees, Contractor Privacy Notice contains disclosures for job applicants, employees and contractors.

3. Personal Information Collection

For the purposes of this Notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time.

Personal Information does not include information that is:

• Lawfully made available from government records.

• Deidentified or aggregated.

• Otherwise excluded from the scope of the CCPA.

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve months since this notice was last updated, as well as the categories of third parties with whom we shared Personal Information. Not all categories may apply to your Personal Information.

The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

A. Information we collect from users

When you engage with the Services (i.e., visit the website, enroll for a free trial or purchase a subscription), we collect information (a) from you and (b) from automated technologies.

Information you provide

The types of information you may provide, depending on whether you enter into a binding agreement with Reonomy for access and use of the Services pursuant to a free trial or a full registered account, may include:

• Personal information, including information necessary to register your account.

  • Your name, postal address, phone number, and email address.

  • Account credentials, such as username and password. Account credentials are “sensitive personal information” under the CCPA. See the “Right to Limit Use of Sensitive Personal Information” section below.

  • Organizational information necessary to register an account, such as company name and job title;

  • Payment information, such as a credit or debit card or other billing information

• Feedback, such as comments, survey response, inquiries, feedback and other information, including questions submitted to our support team.

• Information of third parties, such as information of others you may provide to us, such as the email address of someone you invite to collaborate or a third party referral.

Information collected from your use of the Services

We collect information automatically when you browse our websites or use the Services, including:

• Usage information, including monitoring the activity of the Services and features you use, content you access, and any actions taken in connection with your information and content in the Services.

• Log Information, such as log file information from your computer or mobile device each time you access the Services, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information.

• Device Information, such as information about the device (e.g., computer, mobile device, etc.) used to access the Services, your IP address, the time and date, and other statistics.

• Google Account Authentication. Google’s authentication method called OAuth 2.0 is an open standard authorization protocol that allows third parties to obtain your user data without access to your passwords. By enabling OAuth 2.0, you permit third party applications and services, such as Google, to provide your third party account information, such as user ID, name, location, and IP address to Reonomy, solely for identification purposes during login. If stored, we will store such account information in a database hosted in Amazon Web Services. Reonomy will not need to know or store your passwords for third party applications and services. OAuth 2.0 allows a User to revoke Reonomy’s access at any time in Google settings. If a User revokes Reonomy’s access, our Service does not have access to any of the user data anymore. If OAuth 2.0 is not supported, we will require your account username and password in order to provide the Service.

Information from cookies and similar technologies

We use certain technologies to automatically collect information about how you interact with the Services, which may include:

• Cookies, provided by Reonomy and our service providers, are a small text file containing a string of alphanumeric characters and uniquely identify your device. For more information regarding cookies, see our Cookie Policy at Cookie Policy | Altus Group.

• Web beacons, also known as clear gifs, pixels, images and scripts, may be enabled by Reonomy and our service providers.

B. Information collection for the services

Information from third parties and other sources

We may obtain certain personal information about you from third parties, which may include information from publicly-available and private data suppliers, from which we procure to validate or supplement our information in order to provide the Services, such as:

• Personal identifiers: including your name, postal address, phone number, and email address;

• Commercial information: including commercial real estate sales, tax and debt information; and

• Professional or employment-related information: including job title and your affiliated organizations.

Sources of information:

• Data brokers, suppliers, and compilers

• Public records, directories, filings, publications and other publicly available sources

• Consumer-facing companies, applications, and services

• Business-facing companies

• Surveys and subscription

• Company Websites

4. Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below. Depending on your level of interaction with us and the Services, we may use your information to:

• Provide, operate, maintain and improve the Services;

• Enable you to access and use the Services, including downloading and collaborating with content;

• Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Reonomy and our business partners;

• Provide and deliver the services and features you request, process and complete transactions and send you related information, including purchase confirmations and invoices;

• Respond to your comments, questions, and requests, and provide customer service and support;

• Monitor and analyze trends, usage, and activities in connection with the Service and for sales, marketing or advertising purposes;

• Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;

• Connecting third party services: Facilitating the connection of third-party services or applications, such as social networks.

• Link or combine with other information we receive from third parties to help understand your needs and provide you with better service

• Personalizing your experience on our services such as presenting tailored content.

• De-identifying and aggregating information collected through our services and using it for any lawful purpose.

• Responding to trust and safety issues that may arise.

• To comply with our legal obligations, resolve disputes, and enforce our agreements.

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

• Debugging to identify and repair errors that impair existing intended functionality.

• Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

• Enabling transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

• Notified purpose: For other purposes for which we provide specific notice at the time the information is collected.

5. Collection of Personal Information

In the preceding twelve months, we have collected Personal Information from the following categories of sources:

1. You/your devices: You or your devices directly.

2. Users: Other users of our services.

3. Affiliates

4. Advertising networks

5. Internet Service Providers

6. Analytics Providers

7. Government entities

8. OS/Platform provider: Operating systems and platforms

9. Social networks

10. Resellers: Consumer data brokers

11. Business partners

12. Public: Publicly accessible sources

6. Disclosure of Personal Information

A. Categories of third parties with whom we share information

Depending on your interaction with the Service, we disclose and sell information collected about you as described above in this Notice. The below chart describes how and with whom we share or disclose personal information, and whether we have sold particular information (based on broad definitions of “sale” under applicable law).

Information collected from users

Information collected for the platform

B.  General disclosure of information

We may also share your Personal Information with the following categories of third parties:

• Our Affiliates. Other companies owned by or under common ownership as Reonomy, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns may receive your information.

• Service Providers. We share information with third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving targeted advertisements, content or service fulfillment, billing and payments processing, or providing analytics services.

• Compliance with Law. We may share your information in order to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use or other applicable agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Reonomy, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

• Organizational Communication. We may share your information with members of your organization such as your employer if you are accessing the Service in your capacity as an employee, independent contractor, or agent of one of our enterprise customers or otherwise using an email address provided by your employer who is one of our enterprise customers.

• Business Transfer. We may share your information in the event of a business transfer such as a merger, sale of company assets or shares, purchase of another entity’s assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

7. Children's Privacy

We do not directly or knowingly collect or sell personal data about children or minors under the age of 18. If we learn we have collected or obtained personal data of someone under 18 as a “business”, we will delete that information from our database. We do not sell or share the personal information of consumers we know to be under 16 years of age. If we learn that we have sold or shared the personal information of a consumer under 16 without the affirmative authorization required by the CCPA, we will stop that sale or sharing and delete the information.

8. How long we retain personal information

We retain each category of personal information only for as long as reasonably necessary and proportionate for the purposes disclosed at collection. The table below sets out the criteria we use to determine the periods/ our intended retention periods by category. When the applicable period expires, we securely dispose of or anonymize the information. Where we are able to identify a specific retention period for a category, we state that period; where we are not, we state the criteria we use to determine how long we retain that category.

9. Privacy rights regarding personal information

If you are a California resident, you may exercise the following rights which are described below. You may only make a verifiable consumer request to know (access) twice within a 12-month period. That limit does not apply to requests to delete, to correct, to opt out of the sale or sharing of your personal information, or to limit the use of sensitive personal information.

Right To Know and Access

You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the 12-month period before your request and, for Personal Information we collected on or after January 1, 2022, for the period before those 12 months unless doing so would be impossible or would involve disproportionate effort. Where you request the specific pieces of Personal Information we hold about you, we will provide it in a portable and, to the extent technically feasible, readily useable format that allows you to transmit it to another entity without hindrance.

If we are unable to verify your identity, we will inform you that we cannot verify your identity and we will not disclose any specific pieces of personal information to you. We will confirm receipt of your request within 10 business days and will respond within 45 calendar days of receipt. If we need more time, we may extend that period once by up to an additional 45 calendar days, and we will notify you of the extension and the reason for it before the first 45-day period ends.

Right to Correct

California residents have the right to request corrections to inaccuracies in your personal information. For this type of request, we encourage you to first submit an access request. If you identify anything in the response to the access request that is inaccurate, you have the right to request that Reonomy correct the inaccuracies. Upon receipt of a valid correction request, Reonomy will correct (or, at the consumer’s election, delete) the information identified as inaccurate in our systems.

Right to Delete

Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. Please note that this is different from your right to “opt out” of us selling or sharing your personal information, which is described below. 

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, contractors, and any third parties to whom we have sold or shared your personal information to delete) your personal information from our records, unless an exception applies. Exceptions include, personal information is required to: a) to perform a contract, or further the existing business relationship, b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, c) debug to identify and repair errors that impair existing intended functionality, d) exercise free speech, e) for scientific or historical research, f) to comply with legal obligations, g) comply with law enforcement requests pursuant to lawful process.

Right to Opt Out

The CCPA grants you the right to direct us not to sell or share your Personal Information. Under the CCPA, “sharing” includes disclosing your Personal Information to third parties for cross-context behavioral advertising, whether or not money is exchanged.

In the preceding twelve (12) months, we have disclosed Internet or other electronic network activity information, including information collected through cookies and similar technologies, to advertising networks, data analytics providers, internet service providers, operating systems and platforms, and other service providers. Certain of these disclosures may constitute a “sale” or “sharing” of Personal Information under the CCPA. We may also disclose Personal Information to service providers and business partners as described in this Notice.

To exercise your right to opt out of the sale or sharing of your Personal Information, please click the “Do Not Sell or Share My Personal Information” link available on our website: Privacy Web Form.  You can also submit a request using one of the methods described in the Submit Requests section below.

We also honor browser-based opt-out preference signals, such as Global Privacy Control ("GPC"), as a valid request to opt out of the sale or sharing of Personal Information associated with the browser transmitting the signal. If you use multiple browsers or devices, you may need to enable the signal on each browser or device.

Right to Limit Use of Sensitive Personal Information

The CCPA gives California residents the right, in certain circumstances, to direct a business to limit its use and disclosure of sensitive personal information to what is necessary to provide the requested services and to a limited set of other permitted operational purposes. The sensitive personal information we collect is account credentials (such as username and password). We use and disclose account credentials only to perform the services you request, to verify and maintain the quality and safety of the Services, to prevent, detect and investigate security incidents, and to resist malicious, deceptive, fraudulent or illegal conduct. We do not use or disclose sensitive personal information to infer characteristics about you, for cross-context behavioral advertising, or for any other purpose beyond those permitted under the CCPA regulations. Because of that, we are not required to offer, and do not offer, a separate right to limit the use and disclosure of sensitive personal information, and we do not post a “Limit the Use of My Sensitive Personal Information” link. If our practices change, we will update this Notice and make the right to limit and the required link available before the new use begins.

Right to Non-Discrimination for Exercise of Your Consumer Rights

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light

We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

10. Submit requests

To exercise any of your rights under the CCPA:

• please complete this form; or

• call us at +1 (888) 914-9661 and when prompted for the PIN, enter 927 832; or

• email us at privacyoffice@altusgroup.com

For requests to know, delete, or correct, we will ask you to provide the information reasonably necessary for us to verify that you are the consumer about whom we collected personal information, and we will use the least amount of information needed to do so. We will ask for a copy of government-issued identification only where we cannot verify you by other means, and we will delete any information you provide solely for verification as soon as practicable after we finish processing your request. We do not require you to verify your identity in order to opt out of the sale or sharing of your personal information.  We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. The information you provide will only be used to process your request.

You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records or other applicable law.

If your request requires us to delete, restrict or not sell certain information, please be advised that this may inhibit some functionality of the Services.

11. Authorized Agents

An agent may also be appointed to submit requests on your behalf to exercise the rights outlined above. Where necessary, we will take measures to verify your identity as the consumer, confirm your agent’s identity, and ensure your agent is authorized to act for you by requesting a signed written authorization or a copy of a power of attorney. We may be unable to provide you or your agent with personal information if we cannot verify your identity, your agent’s identity, your agent’s authority to make the request, or confirm that the personal information pertains to you.

CALIFORNIA REQUEST TOTALS FOR JANUARY 1, 2025 TO DECEMBER 31, 2025

The table below represents our California request metrics for the previous calendar year (2025). The information provided reflects requests from California consumers only. During the previous calendar year, Reonomy facilitated the following requests from California residents who submitted requests via our online portal, by phone or mail:

*Requests may have been denied if we were unable to verify your identity, you were not a California resident, the request called for information exempt from disclosure, or other grounds. If you have any questions about our privacy rights process, please contact us at privacyoffice@altusgroup.com

DO NOT TRACK

While we do not respond to ‘Do Not Track’ browser signals, we do honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of personal information.

CONTACT US

If you have any questions or concerns regarding our privacy policies and practices, or about your rights and choices related to the use of your information, please feel free to contact us at:

• Address:  5 Pennsylvania Plaza, Suite 15S, New York NY 10001, United States

• Phone: (416) 641-9500 

• Fax: (416) 641-9501

• E-mail: privacyoffice@altusgroup.com