Biometric Data Policy – Real Remax Group

Biometric Data Policy

Voice Vector Retention and Destruction Policy

Last Updated: August 24, 2026

1. Purpose and Scope

This policy establishes the collection, use, disclosure, retention, and destruction practices for biometric identifiers collected by Real REMAX Group Inc., Real Broker, LLC, The Real Brokerage Inc., and their affiliated brokerage entities (collectively, “Company” or “RRG“) in connection with the RRG Operator Assisted Routing (“ROAR“) feature available through RRG’s reZEN platform.

This policy applies to licensed real estate agents who affiliate with RRG’s US or Canadian brokerage entities (each, an “Agent”) and who elect to enroll in ROAR. It does not apply to consumers, home buyers, home sellers, clients of affiliated agents, or other third parties.

2. Biometric Identifier Covered by This Policy

RRG collects voice vectors from enrolled Agents in connection with ROAR. A voice vector is a mathematical representation of an individual’s voice characteristics (also referred to as a voice print or voiceprint), derived from a recorded voice sample. Voice vectors are biometric identifiers and “sensitive personal information” under certain applicable laws.

RRG does not collect any other category of biometric identifier under this policy.

3. Purpose of Collection and Use

RRG collects and uses Agent voice vectors solely for the purpose of automated speaker identification within ROAR call transcripts and summaries. When an Agent places or receives a call through the ROAR feature, the Agent’s voice vector is used to identify the Agent by name in the resulting transcript and call summary, enabling brokers and other authorized platform users to review call records with accurate speaker attribution.

Voice vectors are not used for any other purpose. Without limitation, voice vectors are not used for fraud detection, voice-based authentication into any RRG system other than ROAR speaker identification, or any commercial purpose beyond the transcript identification function described above.

4. Consent

RRG relies on each Agent’s express consent to collect, use, and process the Agent’s voice vector. Consent is obtained at the time of ROAR enrollment. Enrollment in ROAR is voluntary; declining or withdrawing biometric consent does not affect an Agent’s affiliation with RRG or access to non-ROAR features of the reZEN platform.

5. Retention Schedule

RRG retains an Agent’s voice vector only for the duration of the Agent’s active affiliation with the Company under the Residential Independent Contractor Agreement (“ICA”). An Agent’s affiliation is considered active from the date of the Agent’s enrollment in ROAR until the date the Agent’s ICA terminates or expires for any reason, including voluntary resignation, non-renewal, or termination by the Company.

Regardless of whether an Agent’s affiliation remains active, RRG will not retain any Agent’s voice vector beyond three years from the date of the Agent’s last interaction with the ROAR feature. For purposes of this three-year cap, “last interaction” means the date on which the Agent last placed or received a ROAR call. Passive account existence or continued affiliation without active ROAR use does not extend the retention period. This three-year hard cap is independent of and does not extend the affiliation-based retention period described above; the applicable retention limit is whichever period ends first.

6. Destruction Guidelines

RRG will permanently and irreversibly destroy an Agent’s voice vector upon the earliest of the following events:

Termination or expiration of the Agent’s ICA. Destruction will be completed no later than 30 days following the effective date of termination or expiration.
Receipt of a valid written consent-withdrawal request from the Agent, as described in Section 9. Destruction will be completed no later than 30 days following RRG’s receipt and verification of the request.
Expiration of the three-year hard retention cap described in Section 5, measured from the date of the Agent’s last interaction with the ROAR feature.

Destruction is accomplished by permanent deletion of the voice vector record and all associated embedding data from RRG’s database hosted on Amazon Web Services (AWS) – US region.

7. Processing Infrastructure

Voice analysis and embedding are performed using industry-standard, commercially available or open-source, AI models running on RRG’s cloud infrastructure. Voice prints are stored in the United States.

Call transcripts generated by ROAR are processed for summarization using third-party large language model providers (e.g., Google Gemini and Groq). These providers receive call transcripts but do not receive voice vectors or other biometric data.

RRG does not sell, lease, trade, or otherwise profit from Agent voice vectors.

8. Disclosure Practices

RRG does not disclose Agent voice vectors to any third party except in the following circumstances:

As required by applicable law, court order, regulatory demand, or valid legal process; or
With the Agent’s prior written consent.

RRG does not disclose voice vectors to other agents, brokers, consumers, or any party not involved in operating the ROAR feature.

9. Agent Rights

Enrolled Agents have the following rights with respect to their voice vectors:

Consent Withdrawal. An Agent may withdraw consent for voice vector collection and processing at any time by submitting a written request to privacy@therealbrokerage.com. Withdrawal of consent will result in the Agent’s disenrollment from ROAR and the permanent destruction of the Agent’s voice vector in accordance with Section 6 within 30 days. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

Access and Correction. An Agent may request (i) confirmation that RRG holds a voice vector associated with the Agent’s account, (ii) access to the personal information held about the Agent, including information about the source of the data and the categories of persons having access to it, and (iii) correction of inaccurate or incomplete information by contacting privacy@therealbrokerage.com.

Right to Limit (CCPA and Other State Law). Agents in states that recognize a right to limit the use or disclosure of sensitive personal information, including California under the CCPA, may exercise that right by contacting privacy@therealbrokerage.com. RRG will treat a timely and verified right-to-limit request from an enrolled Agent as a consent-withdrawal request under this policy.

RRG will not deny ROAR enrollment, charge differential fees, or otherwise discriminate against any Agent for exercising the rights described in this Section.

10. Security

RRG maintains administrative, technical, and physical security measures appropriate to the sensitivity of biometric data. These safeguards include role-based access controls limiting voice vector access to authorized personnel on a need-to-know basis, encryption of data in transit and at rest, and audit logging of processing events. Voice vector data is stored in the United States on AWS-US infrastructure and is not transferred outside the United States in connection with voice processing.

11. Updates to This Policy

RRG may update this policy from time to time to reflect changes in its practices, applicable law, or the ROAR feature. Material changes will be communicated to enrolled Agents through the reZEN platform at least 30 days before taking effect, except where a shorter notice period is required by law or necessary to address an urgent compliance or security issue. The current version of this policy is available at realremaxgroup.com/pages/biometric-data-policy and through the reZEN platform.

12. Contact Information

Questions regarding this policy or Agent biometric data rights may be directed to:

Email: privacy@therealbrokerage.com

Telephone: (305) 306-9553 (United States) or (604) 200-7046 (Canada)