This Privacy Policy describes how Conejo Valley Real Estate, Inc., a California corporation doing business as 121 Enterprise ("we," "our," or "us"), collects, uses, stores, and shares information when you access or use the 121 Enterprise platform (the "Service"). Please read this Policy carefully. By creating an account or using the Service, you agree to the practices described herein.
Conejo Valley Real Estate, Inc. is a California corporation operating the 121 Enterprise SaaS platform. 121 Enterprise enables licensed real estate agents and their authorized team members to create, manage, and publish advertising campaigns to Meta (Facebook and Instagram), Google Ads, and connected customer relationship management systems such as GoHighLevel. Our principal place of business is in the state of California. For privacy-related inquiries, contact us at info@seansanjose.com.
This Policy applies to:
We use Clerk, Inc. as our authentication provider. When you sign in via Google OAuth through Clerk, we receive and store your email address, display name, and profile picture URL. We do not receive or store your Google account password.
To connect the Service to your advertising and marketing accounts, you authorize 121 Enterprise to receive OAuth access tokens from Meta (Facebook/Instagram), Google Ads, and GoHighLevel. We store these tokens in encrypted form using AES-256-GCM encryption with server-side keys that are not stored in the database. The specific data we receive from each platform upon OAuth authorization includes:
OAuth tokens are deleted from our systems when you disconnect the relevant integration from your account settings. You may disconnect any integration at any time from the Integrations tab.
When you use the Service to build and manage ad campaigns, we store campaign drafts, ad creative (including copy, images, and video references), budget settings, targeting parameters, audience selections, and performance data pulled from Meta and Google. This data is retained for 90 days following the end of a campaign, after which it is deleted or anonymized. You may request earlier deletion by contacting us at info@seansanjose.com.
We maintain server-side logs of actions taken within the Service, including timestamps of logins, integration connections, campaign submissions, and other material in-app events. These logs are used for security monitoring, fraud prevention, debugging, and service improvement. Logs are retained for 90 days as a standard operational matter and are not shared with third parties except as described in Section 7.
When a Realtor runs Meta Lead Ads or uses GoHighLevel forms to capture prospective buyer and seller information, lead data — which may include a consumer's name, email address, phone number, and property interest — flows through the Service in the course of processing and displaying that information to the Realtor. We process this data solely to operate the Service for the Realtor's benefit and do not use it for our own marketing or analytics purposes. The Realtor, as data controller, is responsible for maintaining the appropriate legal basis for collecting this consumer information and for honoring any data subject rights requests from those consumers.
To publish and manage ad campaigns on Facebook and Instagram on your behalf, we transmit to Meta the following categories of data via the Meta Marketing API: ad creative content (text, imagery, video), targeting parameters, audience configurations, campaign budgets, bidding settings, and campaign scheduling information. Once an ad is published on Meta, the ad content is visible to the public audience you have selected. We do not control Meta's own collection, use, or storage of data in connection with ad delivery. Please review Meta's Data Policy at facebook.com/policy.
Real estate advertising on Meta is governed by Meta's Housing Special Ad Category, which restricts ad targeting based on certain protected characteristics — including age, gender, and ZIP code — to comply with the federal Fair Housing Act and applicable state and local fair housing laws. When you use 121 Enterprise to run real estate ads on Meta, your campaigns are designated under this Special Ad Category. We facilitate this designation by setting the appropriate campaign parameters when pushing campaigns to Meta. You remain responsible for ensuring your ad content and targeting intent comply with all applicable fair housing requirements.
We use the information we collect for the following purposes:
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal data under the following legal bases:
We share data with the following categories of third-party providers who process data on our behalf, each bound by contractual data processing obligations:
We do not sell your personal data to third parties for their own marketing purposes.
We take the security of your data seriously. OAuth tokens and API credentials are encrypted at rest using AES-256-GCM encryption. All data transmitted between your browser and our servers, and between our servers and third-party APIs, is protected using TLS (HTTPS). Access to production data is restricted to authorized personnel. Our infrastructure is hosted on Railway, which provides additional infrastructure-level security controls. Despite these measures, no system is perfectly secure. If you become aware of a security issue affecting your account, please contact us immediately at info@seansanjose.com.
Depending on your jurisdiction, you may have the following rights with respect to your personal data:
To exercise any of these rights, please email info@seansanjose.com with "Privacy Request" in the subject line, or visit our Data Deletion page. We will respond within 30 days. We may need to verify your identity before processing certain requests.
You have the right to request deletion of your 121 Enterprise account and all associated personal data. If you connected your Facebook account to 121 Enterprise and subsequently removed the application from your Facebook settings, our system automatically receives a deletion signal from Meta via a verified callback and initiates deletion of your Meta credentials. For all other deletion requests, please visit our Data Deletion page for step-by-step instructions. We confirm deletion requests within 7 business days and complete deletion within 30 days.
We are based in the United States, and your personal data may be processed on servers located in the United States. If you access the Service from outside the United States, please be aware that your data will be transferred to, stored, and processed in the US. We rely on appropriate safeguards — including, where applicable, Standard Contractual Clauses approved by the European Commission — for transfers of personal data from the EEA, UK, or Switzerland to the United States.
The Service is not directed to individuals under the age of 18, and we do not knowingly collect personal data from children. If we become aware that a user is under 18, we will terminate that account and delete associated data. If you believe a child has provided us with personal information, please contact us at info@seansanjose.com.
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. When we make material changes, we will notify you by email to the address associated with your account and update the Effective Date at the top of this Policy. Continued use of the Service after the effective date of any update constitutes acceptance of the revised Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact: