Privacy Notice

This notice describes how Otto handles personal information today. It is in effect while it undergoes attorney review; if that review changes it, we will publish the updated version here.

This Privacy Notice describes how Modern Agents, LLC, a California limited liability company ("Modern Agents," "we," "us") collects, uses, and discloses personal information in connection with Otto, our AI-powered transaction coordination service, including the Otto email and messaging interfaces, hosted web pages at ottotc.com and its subdomains, and related features (the "Service").

The Service is a business tool for real estate professionals. This notice covers both our customers (the agents and teams who use Otto) and the other people whose information appears in transaction documents and communications (such as buyers, sellers, and other agents). If you are not an Otto customer, Section 6 explains how your information reaches us and what we do with it.

1. Information we collect

Account and professional information. When you sign up or are onboarded, we collect information such as your name, email address, phone number, real estate license number, brokerage and team affiliation, and sign-in identifiers managed by our identity provider.

Transaction information. The core of the Service is processing the documents and messages of your transactions. This includes:

• documents you or transaction participants send (for example, purchase agreements, disclosures, amendments), which routinely contain personal information about the people in the transaction: names, mailing addresses, contact details, financial terms (such as price, deposit, and loan amounts), and signatures;
• the emails and messages sent to and from Otto in connection with your transactions; and
• data the Service generates from the above, such as extracted dates and terms, timelines, checklist status, and confidence scores.

Records of what the Service does. We keep an append-only audit log of the actions the Service takes (for example, what was extracted, what was sent, what was escalated to a human), including the reasons for those actions.

Usage and technical information. When you use our hosted pages we collect standard technical information such as IP address, browser and device information, and page-access logs, including access to tokenized links we send you.

2. Where information comes from

We collect information directly from you; from the people in your transactions who correspond with Otto or whose information appears in transaction documents; from the transaction management system ("TMS") and other services you connect and direct Otto to use; and from the operation of the Service itself (generated extractions, timelines, and audit records).

3. How we use information

We use personal information to:

• provide the Service: read and classify documents, extract dates and terms, build and maintain timelines and checklists, send communications you direct or authorize, upload documents and data to the TMS you connect, and track deadlines;
• provide human review and support: members of the Modern Agents team may review transactions, documents, and communications to handle items Otto escalates, respond to your requests, and keep the Service accurate and safe;
• secure and audit the Service: authenticate users, enforce access isolation, detect and prevent abuse, and maintain the audit log;
• improve the Service: analyze de-identified or aggregated data (data that no longer identifies you, your clients, or any transaction participant) to operate, evaluate, and improve the Service, including its AI components. We do not attempt to re-identify de-identified data, and we do not use identifiable customer content to train generalized AI models without consent; and
• comply with law: meet our legal, regulatory, and record-keeping obligations and enforce our agreements.

AI processing. The Service uses artificial intelligence, including large language models operated by third-party providers, to read documents and generate output. Content processed this way (for example, document page images and message text) is submitted to those providers under contracts that restrict their use of it; they do not use it to train their generalized models.

4. How we disclose information

We disclose personal information only as described here:

• Service providers. Companies that process information for us to run the Service: cloud hosting and storage (Amazon Web Services), email and message delivery (Postmark), identity and sign-in management, and AI model providers (Anthropic). They are bound by contracts limiting their use of the information to providing services to us.
• Services you connect. The TMS platforms and other services you connect and direct Otto to use (for example, ReZen) receive the documents and data you have Otto file there. Their handling of that information is governed by their own terms and privacy policies.
• At your direction. Recipients of the communications you direct or authorize Otto to send (for example, participants in your transactions).
• Your team or brokerage. Where a feature you use is shared with your team or brokerage (for example, team-level views), the information that feature displays is visible to them.
• Legal and safety. When we believe disclosure is required by law or legal process, or necessary to protect the rights, safety, or property of our users, the public, or Modern Agents.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, in which case the successor remains bound by commitments at least as protective as this notice or you will be notified of changes.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

5. Transaction isolation

The Service is designed so that each user's transaction workspace is isolated. If another participant in your transaction also uses Otto, each of you has a separate, walled-off experience: Otto does not disclose your transaction information to the other side, other than communications you direct or authorize Otto to send.

6. If you are not an Otto customer

If you are a buyer, seller, agent, or other participant in a transaction and you are not an Otto customer, your information reaches us because a real estate professional you are transacting with uses Otto to coordinate that transaction. We use your information only to provide the Service for that transaction as described in this notice: we do not sell it, we do not use it for advertising, and we do not build profiles of you for any other purpose. If you have questions or requests about your information, you can contact us (Section 12) or the professional handling your transaction; where a request concerns the transaction itself, we may refer it to that professional, who controls the engagement.

7. Cookies and tracking

Our hosted pages use cookies and similar technologies only as needed to run the Service: signing you in, keeping your session, and securing tokenized links. We do not use third-party advertising cookies or cross-site tracking.

8. Security

We protect personal information with measures including encryption in transit and at rest, field-level encryption of sensitive identifiers (such as email addresses, phone numbers, and license numbers), access controls with audited administrative access, per-transaction-side isolation, and an append-only audit log. No system is perfectly secure; we cannot guarantee the security of information, and you should protect your own account credentials.

9. Retention

We retain personal information for as long as needed to provide the Service, maintain the integrity of transaction records and the audit log, comply with legal and regulatory obligations, resolve disputes, and enforce agreements. When you close your account, we make your content available for export for the period stated in the Terms of Use, after which we delete or de-identify it, except for records we are required or permitted to keep for the purposes above. De-identified and aggregated data may be retained and used as described in Section 3.

10. Your choices and rights

• Access, correction, export, deletion. You may request access to, correction of, a copy of, or deletion of your personal information by contacting us (Section 12). Deletion is subject to the retention needs in Section 9 (for example, audit-log integrity and legal record-keeping).
• Email. Service and transactional messages are part of how the Service operates; you can stop them by disabling the related feature or closing your account. Any marketing email includes an unsubscribe option.
• Text messages. If text messaging is offered and you have opted in, you can opt out at any time by replying STOP.
• California residents. California law may give you rights to know, access, correct, delete, and port personal information, to limit certain uses, and to be free from discrimination for exercising those rights. We do not sell or share personal information as those terms are defined in California law, so there is nothing to opt out of. To exercise rights, contact us (Section 12); we will verify your identity and respond as the law requires, and you may use an authorized agent.

11. Children

The Service is not directed to children, and we do not knowingly collect personal information from anyone under 18 except as it may incidentally appear in transaction documents submitted by professionals. If you believe a child's information has been submitted in error, contact us and we will address it.

12. Contact

Questions or requests about privacy? Reply to any message from Otto and a member of the team will follow up.

13. Changes to this notice

We may update this notice. If a change is material, we will notify you (for example, by email or through the Service) before it takes effect. The version shown below always reflects the current text.