1. Introduction
This Privacy Policy describes how JXO, doing business as Origination Inc. ("Origination Inc.", "we", "us", or "our"), collects, uses, discloses, and protects information when you visit our website at originationinc.com, contact us, become a client, or interact with us through phone calls, emails, or text messages.
By using our website or services, or by providing your contact information to us, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use our services.
2. Information We Collect
Information You Provide Directly
- Contact information — name, business name, title, email address, phone number, and mailing address.
- Business information — brokerage details, market focus, client engagement history, and other information shared during sales conversations or onboarding.
- Communications — content of emails, text messages, call recordings (where permitted by law), and notes from meetings or calls.
Information from Public and Third-Party Sources
- Publicly available business contact information — including business names, business phone numbers, business email addresses, business websites, public directories, public records, and licensing databases.
- Third-party data providers — commercial real estate databases and business contact data services that aggregate publicly available information.
Information Collected Automatically
- Website usage data — IP address, browser type, device information, pages viewed, referring URL, and approximate location.
- Cookies and similar technologies — used to operate the website, remember preferences, and analyze traffic.
3. How We Use Information
We use the information we collect to:
- Identify and reach out to property owners, business owners, brokers, and other professionals about commercial real estate opportunities, including property sale inquiries, leasing opportunities, and tenant representation.
- Respond to inquiries and provide information about our services.
- Deliver, manage, and report on client engagements.
- Send transactional, conversational, and informational text messages and emails to recipients who have provided their contact information or with whom we have a legitimate business interest.
- Maintain records of opt-in consent and opt-out requests.
- Operate, secure, and improve our website and services.
- Comply with legal obligations and enforce our agreements.
4. SMS / Text Messaging
This section explains how we use phone numbers for text messaging and is provided to comply with the requirements of mobile carriers and The Campaign Registry (TCR) for A2P 10DLC messaging.
How We Obtain Your Phone Number
We may obtain your phone number when you (a) submit a form on our website, (b) provide it during a phone call, email exchange, or in-person conversation, (c) it is publicly listed as a business contact number, or (d) we receive it through a referral or business relationship.
Types of Messages You May Receive
- One-to-one conversational text messages from a member of our team regarding a specific commercial real estate opportunity, follow-up to a prior call or email, or response to your inquiry.
- Scheduling and appointment-related messages.
- Information related to our services that you have requested or that follows from a prior business interaction.
Message frequency varies based on the nature of the conversation. Message and data rates may apply.
Consent and Opt-In
Where consent is required, you consent to receive SMS messages from us by (a) checking the SMS opt-in box on a form on our website where applicable, (b) providing your mobile number directly to us with the understanding that we may follow up by text, or (c) replying to a text message from us in a manner indicating you wish to continue the conversation.
How to Opt Out
You can opt out of SMS messages from us at any time by replying STOP to any message you receive. You will receive a one-time confirmation that you have been unsubscribed, after which no further messages will be sent. To re-subscribe, reply START. For help, reply HELP or contact us using the details in Section 11.
Mobile information, including phone numbers and SMS opt-in consent data, will not be shared with third parties or affiliates for marketing or promotional purposes. All other categories of personal information described in this Privacy Policy follow the standard sharing practices below; however, text messaging originator opt-in data and consent are excluded from any third-party sharing.
5. How We Share Information
We do not sell personal information. We may share information in the following limited circumstances:
- Service providers — vendors who help operate our business (for example, CRM, email, calling, and texting platforms; cloud hosting; analytics) under written agreements requiring confidentiality and use only for purposes we authorize.
- Clients — when you become a client of Origination Inc., we share campaign data, prospect lists, call notes, and reports with you and your authorized team members.
- Legal and safety — when required by law, subpoena, or court order, or to protect rights, property, or safety.
- Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.
As stated above, mobile phone numbers and SMS consent data are not shared with third parties or affiliates for marketing purposes under any circumstance.
6. Cookies and Analytics
We use cookies and similar technologies to operate the website, remember preferences, and understand how visitors use the site. You can control cookies through your browser settings. We may use third-party analytics services that collect information about website use; this information is aggregated and used to improve the site.
7. Data Retention
We retain personal information for as long as needed to deliver our services, maintain business records, comply with legal obligations, resolve disputes, and enforce agreements. SMS opt-out records are retained as required by applicable law and carrier requirements (including a minimum of 10 years where applicable).
8. Data Security
We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. No system is perfectly secure, and we cannot guarantee absolute security.
9. Your Rights and Choices
- Access, correction, deletion — you may request a copy of the personal information we hold about you, ask us to correct it, or ask us to delete it, subject to legal retention requirements.
- Opt out of SMS — reply STOP to any message, or contact us as described in Section 11.
- Opt out of email — use the unsubscribe link in any marketing email, or contact us directly.
- Do not call — you may ask us to stop calling you and we will honor that request.
- State-specific rights — if you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another state with applicable privacy laws, you may have additional rights including the right to know, the right to delete, the right to correct, the right to opt out of certain sharing, and the right to non-discrimination for exercising your rights. To exercise these rights, contact us using the details in Section 11.
10. Children's Privacy
Our services are directed to businesses and professionals. We do not knowingly collect personal information from children under 13. If you believe a child has provided us information, please contact us and we will delete it.
11. Contact Us
If you have questions about this Privacy Policy or wish to exercise any rights, contact us:
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page shows when changes were made. Material changes will be posted on this page and, where appropriate, communicated to you directly.