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Privacy Policy

Last updated October 28, 2026

Botway NY, LLC - NYS Licensed Real Estate Broker License #10491213948 | Broker of Record: Clinton A. Botway

Effective Date: April 9, 2026 | Last Updated: October 28, 2026

Policy Summary

Botway provides an AI-powered leasing and brokerage operating system. We collect and use information to operate the Services, automate workflows, protect the platform, and improve our products - including AI features. This policy explains what we collect, why we use it, who we share it with, and the choices you have. This Privacy Policy is intended to satisfy that privacy policies disclose collection, use, sharing, and retention/deletion practices.

Scope and Role

This Privacy Policy applies to Botway's websites, mobile applications, and related services that link to this Privacy Policy (collectively, the "Services"). Where Botway provides Services to property owners, operators, landlords, agents, or other business customers, those customers may control what information they upload or process through the Services; where appropriate, Botway processes that information to provide the Services to the customer.

Platform and Brokerage Positioning

Botway is a technology platform. Botway is not a party to lease or sale transactions between landlords/owners, tenants, buyers, sellers, brokers, or agents, except to the extent Botway separately enters into a signed written brokerage/agency agreement or is otherwise acting as a licensed agent in a specific transaction. Nothing in this Privacy Policy creates an agency relationship or modifies legal duties that may apply when a licensed agent is acting in a fiduciary capacity under New York law.

Botway does not provide legal, tax, or financial advice, and AI outputs are not professional advice (see "AI and automated decision-making" below).

Free Service and Liability Posture

Botway may offer the Services free of charge unless otherwise agreed in writing. The Services are provided "as is" and "as available," to the maximum extent permitted by law (see "Important legal notices" below).

Fair Housing Commitment

Botway NY, LLC is committed to full compliance with all applicable fair housing laws. Equal housing opportunity is not a compliance checkbox - it is the foundation of how we operate. Our full policy, the protected classes under federal, New York State, and New York City law, and the agencies that accept complaints are set out in our Fair Housing Policy.

Botway NY, LLC is an equal housing opportunity broker. All real estate services are provided without regard to race, color, religion, national origin, sex, disability, familial status, sexual orientation, gender identity or expression, lawful source of income, age, marital status, military status, or any other characteristic protected by applicable federal, state, or local law.

Information We Collect

We collect information in the categories below. The specific data collected depends on how you use the Services (for example, whether you create an account, manage properties, submit inquiries, request tours, or communicate through the platform).

Information You Provide or Create

  • Account and profile information - name, email, phone number, username/password, organization name, role/permissions
  • Property and listing information - addresses, unit attributes, pricing, availability, photos, descriptions, amenities, showing instructions
  • Leasing workflow information - inquiry messages, tour requests, application-related workflow status, communications routed through the Services
  • Customer support and communications - messages to support, emails, chat transcripts, call metadata where permitted, and attachments you choose to provide
  • Payments and subscription data (if applicable) - billing contact details and transaction metadata; payment card data is typically processed by payment processors

Information Collected Automatically

  • Device and usage data - IP address, device identifiers, app interactions, timestamps, referring pages, log files, crash/diagnostic data
  • Cookies and similar technologies - on web properties (see "Cookies and Tracking" below)

Information from Third Parties

  • Integrations and third-party connections - tour scheduling providers, property management systems, screening tools, analytics providers, and identity/fraud prevention vendors

Sensitive Data and Highly Regulated Data

Some workflows (for example, screening, identity verification, fraud prevention, or compliance) may involve sensitive or highly regulated information (e.g., government ID numbers). If collected, we use it only for disclosed operational, compliance, or security purposes and limit access.

Social Security Numbers in Leases

When you sign a lease through Botway, we may ask for your Social Security number or other taxpayer identification number.

  • Why we ask. Some leases print each tenant's and guarantor's number on the signature and guaranty pages. Your landlord also needs one IRS Form W-9 per lease to report interest earned on the security deposit.
  • Who sees it. In Botway, you see only your own number, and your landlord sees the numbers on their lease. Every time a landlord views one, we record it. Your number prints only on the final signed lease, which goes to the people who signed it. It never appears on a draft or a partly signed copy.
  • How we protect it. We encrypt every number before we store it, keep only the last four digits beside it, and never send it in email or put it in a link. If our encryption key is not set up, we refuse the number rather than store it unprotected. We follow New York's Social Security number protections (General Business Law Section 399-ddd) and the SHIELD Act.
  • What we never do. We never sell your number, use it for marketing, or share it with anyone outside your lease except as the law requires.
  • Rent stabilized renewals. A landlord may not require a rent stabilized tenant's Social Security number to renew a lease. On those renewals the number is optional.
  • How long we keep it. As long as the lease and its records must be kept, then we delete it under "Data Retention and Deletion" below.

How We Use Information

  • Provide and operate the Services - account administration; property and workflow management; tour coordination; communications
  • Automation and AI-assisted workflows - generating summaries, drafting responses, prioritizing leads, routing tasks, and producing operational insights
  • Product improvement, analytics, and research - to improve reliability, user experience, and model performance
  • Security, fraud prevention, and integrity - detecting abuse; protecting accounts; investigating incidents
  • Compliance and legal obligations - recordkeeping, responding to lawful requests, enforcing policies

AI and Automated Decision-Making

Botway includes AI features that may generate outputs based on user-provided data, platform activity, and integrated data sources.

AI Output Limitations (Critical Notice)

  • AI-generated outputs can be incomplete, inaccurate, outdated, or misleading.
  • AI outputs are provided for informational and operational support; they should not be relied upon as the sole basis for decisions with legal, financial, housing, or similarly significant impacts.
  • You are responsible for reviewing outputs and ensuring compliance with applicable laws (including fair housing requirements).

AI Improvement and Training

To the maximum extent permitted by law and contract, Botway may use information (including de-identified, aggregated, or otherwise transformed data) to improve the Services and AI models, develop new features, and enhance safety and performance.

If you are a business customer and your contract restricts use of customer content for training, the contract controls.

How We Share Information

Service Providers and Vendors

We share data with vendors that process information on our behalf (hosting, analytics, communications, customer support, security, payment processing, etc.).

Integrations You Enable

If you connect Botway to integrations (e.g., tour scheduling, property management software, screening tools), we share data needed to provide the integration.

With Your Organization and Transaction Counterparties

If you use Botway as part of a property management or leasing workflow, information may be shared among authorized users in your organization, and with counterparties needed to facilitate leasing/brokerage workflows (for example, landlords/owners, tenants/applicants, agents/brokers, co-brokers, and service partners).

We may disclose information to comply with law, respond to lawful requests, protect rights/safety, investigate fraud, and enforce policies.

Business Transfers

If we are involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction.

Aggregated and De-identified Data

We may create and use aggregated or de-identified data for analytics, benchmarking, and product improvement, and we may commercialize such data where legally permitted.

Cookies and Tracking

We use cookies and similar technologies on our websites to:

  • Keep you signed in and maintain sessions
  • Remember preferences
  • Measure and improve performance
  • Support security and fraud prevention

Depending on configuration, we may also use analytics and marketing technologies. If we engage in cross-context behavioral advertising as defined by applicable law, we provide opt-out mechanisms as described below (see "California Privacy Disclosures").

Your Choices and Privacy Rights

Account Information and Communications

You may update certain account information through your account settings. You may also opt out of marketing communications by using unsubscribe mechanisms or contacting us.

Access, Correction, Deletion, and Portability

Depending on your jurisdiction, you may have rights to request:

  • Access to personal information we hold about you
  • Correction of inaccurate information
  • Deletion of personal information (subject to exceptions)
  • Data portability in certain cases

How to Submit Requests

Submit privacy requests by emailing rowan@botway.ai. We may require reasonable verification to protect your account and data.

Account Deletion

If you created an account through the app, you can request deletion of your account and associated data (subject to retention exceptions) via the in-app deletion pathway (if enabled) and via a web deletion request mechanism.

Retention Exceptions

If we must retain certain data for legitimate purposes (security, fraud prevention, regulatory compliance, dispute resolution), we will do so and explain retention in this policy.

Data Retention and Deletion

We retain personal information only as long as reasonably necessary to:

  • Provide the Services
  • Maintain security and prevent fraud
  • Comply with legal obligations
  • Resolve disputes and enforce agreements

When personal information is no longer needed, we delete it or de-identify it, subject to technical and legal limitations.

Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information.

No method of transmission or storage is 100% secure.

Children's Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13.

If you believe a child has provided personal information, contact rowan@botway.ai.

California Privacy Disclosures

This section applies to California residents to the extent the CCPA/CPRA applies.

Your Rights

California provides rights to know, delete, correct, opt out of sale/sharing, limit use of sensitive personal information, and equal treatment (non-discrimination).

Do Not Sell or Share

If Botway "sells" or "shares" personal information as those terms are defined by California law, we will provide a clear and conspicuous mechanism titled "Do Not Sell or Share My Personal Information," consistent with California Civil Code section 1798.135.

Global Privacy Control (GPC)

Where legally required, we will treat user-enabled opt-out preference signals such as the Global Privacy Control as valid requests to opt out of sale/sharing.

Authorized Agents

You may use an authorized agent where permitted by law; we may require proof of authorization and identity verification.

No Warranties

To the maximum extent permitted by law, the Services are provided "AS IS" and "AS AVAILABLE," without warranties of any kind (express, implied, or statutory), including warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, or availability.

No Guarantee of Service

We do not guarantee uptime, uninterrupted operation, lead response success, leasing outcomes, pricing performance, or data accuracy.

Limitation of Liability

To the maximum extent permitted by law:

  • Botway will not be liable for indirect, incidental, consequential, special, exemplary, or punitive damages, or for lost profits, lost rent, vacancy losses, lost data, or business interruption.
  • Botway's total liability for all claims relating to the Services or this Privacy Policy will not exceed (a) the total fees paid by you to Botway for the Services in the twelve (12) months preceding the event giving rise to the claim, or (b) if no fees were paid, $0.

This limitation applies even if a remedy fails of its essential purpose, to the extent permitted by law.

Indemnification

You agree to indemnify and hold harmless Botway from claims arising out of:

  • Property listings or content you upload
  • Your communications with tenants/buyers/sellers
  • Alleged fair housing violations relating to your use of the Services
  • Misuse of the Services or violation of law

Jurisdiction

This Privacy Policy is governed by New York law (without regard to conflict of laws principles), and venue for disputes will be in New York County, New York, to the extent permitted by law.

Contact Information

Company: Botway NY, LLC - NYS Licensed Real Estate Broker License #: 10491213948 Broker of Record: Clinton A. Botway Phone: 646.362.7120 Email: rowan@botway.ai

Legal Disclaimer: This document is for informational purposes only and does not constitute legal advice. Fair housing law is complex and evolving. Consult a licensed New York attorney for guidance specific to your situation.