Privacy Policy

1. Who we are

Howards Limited, a company registered in New Zealand (company number 9407785) and trading as Howards ("Howards", "we", "us"), makes listing videos for real estate professionals. This Privacy Policy explains how we handle personal information in connection with our United States service at howards.ai/us and U.S. customer orders, including orders arranged by email (the "Service"). It covers website visitors, people requesting a video, customers, mailing-list subscribers, and people whose information is included in material supplied to us.

This policy governs information handled for the Service if it conflicts with our general or New Zealand privacy policy. It does not cover employment or recruitment information.

We determine how account, contact, transaction, and website information is used to operate our business. When we process personal information in listing material on a customer's behalf, our role depends on the applicable law and agreement. We will enter into an appropriate data-processing agreement where required. This policy does not replace that agreement or waive anyone's privacy rights.

2. Information we collect

Photos can reveal information about property owners, occupants, or other people. Do not send Photos of identifiable people, confidential documents, financial or identity information, or other unnecessary sensitive information. Remove unnecessary personal details before sending material. A property listing address is not a request to track your device's location.

Cookies and search reporting. We use essential website technologies for functionality and security and, where relevant, authentication and preferences. We use Google Search Console and Bing Webmaster Tools for search-performance and indexing reports. We do not use Google Analytics, advertising pixels, session-replay tools, or Klaviyo website-visitor tracking for the Service. We do not use website information for cross-context behavioral or targeted advertising.

You can manage cookies through your browser, although blocking essential technologies may affect functionality. Ordinary browser "Do Not Track" signals do not change our practices. Legally recognized opt-out signals, including Global Privacy Control, are addressed in section 9. Search engines and external websites have their own privacy practices when you use their services; our use of their webmaster tools is not permission for them to reuse your uploaded Photos or Videos.

3. How we use your information

We use information to respond to video requests, agree and fulfill orders, create and administer accounts where available, produce and review Videos, deliver files, provide corrections and support, process payments, and maintain business records. We also use information reasonably needed to operate and secure the Service, prevent fraud or misuse, troubleshoot problems, assess search performance, improve our production workflow, and comply with legal obligations.

Service-related quality review does not authorize unrelated reuse of customer material. We do not use your Photos or Videos to train AI models, and we do not authorize our AI providers to do so. Our U.S. production workflow is limited to paid API arrangements with no-training terms or controls. For OpenRouter, routing to providers that may train on customer data is disabled. Processing content to produce your Video is different from model training; a no-training commitment is not a promise of zero retention or no service-related safety review.

We will not use your Photos or Videos, including excerpts or stills, in Howards' own marketing. This includes our website, portfolio, social media, paid advertisements, and sales materials. We may deliver material to people you authorize or otherwise process it to provide your order, but ordering a Video does not give us promotional-use permission.

We do not use the Service to make decisions about eligibility for housing, employment, credit, insurance, or similar significant opportunities. We do not create biometric identifiers or use personal information to infer sensitive characteristics. We will provide additional notice or obtain consent before a materially different use where required by law.

4. Marketing emails

We send marketing emails only to people who expressly opt in, such as by selecting the separate "accept marketing" checkbox. Requesting a Video, buying a Video, communicating with us, or accepting our Terms does not automatically subscribe you. Refusing marketing does not affect your ability to order.

We use Klaviyo to manage and send the mailing list. Every marketing email identifies Howards and includes an unsubscribe option. You can also opt out by emailing contact@howards.ai. We honor opt-outs promptly and within the applicable legal deadline, without a fee or a requirement to sign in. We retain only the suppression information needed to respect your choice.

Necessary order, payment, security, and support messages are separate from marketing. Resend is used for website-related notifications, including internal notifications to our team when a Video is requested, and account or service emails where those features are enabled. An internal request notification is not an automatic confirmation email to the customer.

5. Who we share it with

Staff and contractors may access information where reasonably needed for their work, subject to confidentiality and security obligations. We disclose the information reasonably needed to the following types of providers:

We also use music sources, including ElevenLabs-generated music, where the applicable license permits the agreed customer uses. Music sourcing does not itself require sharing customer Photos or Videos; any personal information supplied to a production provider remains subject to the purposes and restrictions in this policy.

We require appropriate contractual protections from providers acting on our behalf, including restrictions on use, disclosure, retention, and security. Some providers, particularly payment providers, separately determine limited processing for their own legal, fraud-prevention, or payment-network obligations. Those activities are subject to their privacy notices and applicable law; they do not create a general permission to use your Photos or Videos for training or advertising.

We may disclose relevant information to comply with law or valid legal process, establish or defend legal claims, prevent fraud, protect safety, or evaluate or complete a business sale, financing, merger, or reorganization with appropriate safeguards. We may also disclose information at your direction. A business transfer does not remove the protections applicable to previously collected customer information.

We do not sell personal information, share it for cross-context behavioral advertising, or use it for targeted advertising. We do not knowingly sell or share children's personal information. Changes to providers must remain consistent with our commitments, and we will give additional notice or obtain consent where required.

6. Where your information is processed

Howards is based in New Zealand. Our providers may process information in the United States, New Zealand, and other countries where they operate. Information may therefore be processed outside your state and outside the United States, where legal protections may differ. We use safeguards required by applicable law for international transfers and require appropriate protection from providers acting on our behalf. Use of the Service is not a waiver of legal protections for overseas processing.

7. How long we keep it

We do not currently apply one fixed deletion period to all customer files. We review retained customer Photos, working files, and Videos quarterly to identify material that is no longer reasonably needed. A quarterly review is not an automatic three-month deletion rule and does not authorize unnecessary retention between reviews.

We handle verified deletion requests as they arrive, separately from quarterly reviews, within applicable legal deadlines. We delete eligible information from our systems and instruct relevant providers to carry out required deletion. Where an exception permits or requires retention, we limit continued use to that purpose and explain the exception as required.

Restricted backup copies may persist until the normal backup cycle overwrites them, subject to applicable deletion requirements. Providers may separately retain limited information required for their own legal or security obligations. We do not promise immediate deletion of every copy held by every provider.

Download availability is different from information retention. Download and keep your own copy of each delivered Video. The Service is not indefinite archival storage, and a perpetual usage license does not require us to retain a downloadable copy indefinitely.

8. Security

We use reasonable technical and organizational safeguards appropriate to the information, including encrypted connections, access controls, and restrictions on access to customer material. No service is completely secure, so we cannot guarantee absolute security. If an incident requires notification, we will notify affected individuals, customers, and authorities as applicable within the legally required time.

9. Your choices and rights

Email contact@howards.ai to request access to, a copy of, correction of, or deletion of personal information, update your details, ask about our practices, or unsubscribe from marketing. You do not need an account to contact us. A person whose information appears in a customer's listing material may contact us directly. Where we process information on a customer's behalf, we may coordinate with that customer while meeting our own obligations.

Depending on your location, the law's applicability, and relevant exceptions, you may have rights to confirm processing; obtain access and a portable copy; correct or delete information; know the categories of sources and recipients or more specific recipient information; opt out of sale, sharing, targeted advertising, or certain significant-decision profiling; limit certain uses of sensitive information; and appeal a refusal. Business use does not, by itself, remove rights that otherwise apply.

We use proportionate identity verification where needed for access, correction, or deletion and ask only for information reasonably necessary to verify and respond. An authorized agent may submit a request; we may verify their authority and, where legally permitted, your identity. We do not require identity verification for ordinary marketing opt-outs or valid browser opt-out signals. We respond within the applicable deadline, explain any permitted extension or refusal, and do not unlawfully discriminate or retaliate for exercising a privacy right.

Where an appeal right applies, email contact@howards.ai with "Privacy appeal" in the subject and identify your request and reason for appeal. We will review the decision and respond within the period required by the applicable law. You may also complain to your state attorney general or privacy regulator, or the New Zealand Office of the Privacy Commissioner, as applicable. You do not have to complete our internal process first.

California residents. Where the California Consumer Privacy Act applies, the categories described in section 2 include identifiers, customer-record information, commercial information, professional information, internet or network activity, approximate geolocation, and visual or similar information. Account credentials may be sensitive personal information. We use credentials and incidentally supplied sensitive information only for necessary service, security, and other legally permitted purposes, not to infer characteristics. Sections 2, 3, 5, and 7 describe sources, purposes, recipient categories, and retention. You may exercise applicable California rights through the contact channel above.

We honor legally applicable opt-out preference signals, including Global Privacy Control. Because we do not sell or share personal information or use targeted advertising for the Service, the signal does not need to stop a practice that is already disabled. It does not delete your account or unsubscribe you from email; use the separate choices above for those requests.

10. Children

The Service is intended for adults aged 18 or over using it for business, not for children. We do not knowingly collect personal information directly from children through accounts or orders. Do not upload children's images or personal information. If you believe a child has provided information or that a child's information was improperly included in submitted material, contact us so we can investigate and take appropriate steps, including deletion where required.

11. Changes to this policy

We may update this policy by posting a revised version for the Service with a new last-updated date. We will give advance notice of material changes to affected customers or account holders by email where we have their contact details, and provide other notice or obtain consent where required by law. A policy update does not itself authorize an incompatible use of previously collected information or permit promotional reuse of Photos or Videos covered by an existing no-promotional-use commitment.

12. Contact

Howards Limited
Attention: Privacy Officer
Christchurch, New Zealand
Email: contact@howards.ai

This policy takes effect when first published for the Service. The last-updated date identifies this version; it does not backdate consent or acceptance.