Email & Electronic Communications Policy 

Purpose  #

Easy Realty is committed to safeguarding confidential information, maintaining professional communication standards, and reducing cybersecurity risks associated with real estate transactions and brokerage operations. 

This policy establishes mandatory requirements for the use of Easy Realty’s company-managed email platform and related security controls. The purpose of this policy is to protect the brokerage, our agents, and our clients by ensuring that business communications are conducted through secure, monitored, and professionally managed systems. 

Background  #

Real estate professionals routinely receive, transmit, and store sensitive and confidential information belonging to our buyers, sellers, and clients. 

Examples of information commonly handled during brokerage operations include: 

• Driver’s licenses 

• Passports 

• Bank statements 

• Earnest money deposit checks 

• Account and routing numbers 

• Wire instructions 

• Tax documents 

• Purchase agreements and disclosures 

• Property records 

• Financial information 

• Contact information 

• Other personally identifiable information (PII) 

The real estate industry continues to be a target for email spoofing, phishing attacks, business email compromise (BEC), wire fraud schemes, identity theft, and unauthorized access attempts. 

As custodians of this information, Easy Realty and its associates share a responsibility to take reasonable measures to protect client information, maintain accurate business records, and reduce the risk of fraud, data loss, and unauthorized disclosure. 

The implementation of the Easy Realty email platform is intended to: 

• Enhance cybersecurity protections 

• Reduce the risk of email spoofing and fraud 

• Improve communication reliability 

• Support regulatory and compliance obligations 

• Improve record retention and business continuity 

• Protect confidential client and brokerage information 

• Maintain consistent professional communication standards 

Policy Statement  #

Effective October 1, 2026, all brokerage-related business communications conducted on behalf of Easy Realty must be transmitted through the associate’s assigned Easy Realty email account. 

All agents, staff members, contractors, team members, and other associates affiliated with Easy Realty are required to use their Easy Realty email account for all brokerage business communications. 

No alternative email platforms are authorized for brokerage business communications. 

Scope  #

This policy applies to all communications relating to brokerage business, including but not limited to: 

• Buyer representation 

• Seller representation 

• Prospective clients and leads 

• Active and pending transactions 

• Compliance matters 

• Internal brokerage communications 

• Communications with cooperating brokers and agents 

• Communications with lenders 

• Communications with title companies 

• Communications with inspectors 

• Communications with attorneys 

• Communications with vendors 

• Marketing conducted on behalf of Easy Realty 

• Transaction-related document exchange 

• Any communication involving brokerage business activities 

Authorized Email Platform  #

The only authorized email accounts for conducting Easy Realty business are company-issued email accounts utilizing the Easy Realty domain. 

All brokerage business communications must be conducted through the associate’s assigned Easy Realty email account. 

Email Address Naming Standards  #

To promote accountability, professionalism, regulatory compliance, and accurate identification of licensees, Easy Realty email addresses will be issued using the licensee’s legal name or the name under which the licensee is registered with the applicable licensing authority. 

Email addresses will follow the brokerage’s established naming convention and may not utilize nicknames, aliases, team names, marketing brands, or other identifiers in place of the licensee’s registered name. 

Examples: 

• john.smith@easy.realty 

• jennifer.rodriguez@easy.realty 

• michael.johnson@easy.realty 

For branding and marketing purposes, associates may customize their sender display name, provided that: 

• The associate’s registered last name remains visible. 

• The display name is not false, misleading, deceptive, or likely to create confusion. 

• The display name complies with applicable licensing and advertising regulations. 

• The display name does not imply ownership, management authority, broker status, team status, certifications, designations, or specializations not otherwise authorized. 

Examples of acceptable display names may include: 

• Mike Johnson 

• Michael Johnson, REALTOR® 

• Jenny Rodriguez | Easy Realty 

• Jennifer Rodriguez, Luxury Homes 

Easy Realty reserves the right to modify or require modification of any display name that may create confusion, create compliance concerns, or conflict with brokerage standards. 

Ownership of Email Accounts  #

All Easy Realty email accounts, domains, aliases, signatures, associated data, and related communication systems are the sole property of Easy Realty. 

Email accounts are provided to associates solely for the purpose of conducting brokerage business on behalf of Easy Realty. 

Upon transfer, termination, resignation, deactivation, expiration of affiliation, or any other separation from the brokerage, Easy Realty reserves the right to: 

• Suspend or terminate email access 

• Disable forwarding 

• Remove aliases 

• Reassign email addresses 

• Retain email records 

• Modify account settings as necessary to protect brokerage operations and client interests 

Associates do not obtain any ownership rights to brokerage-issued email accounts or related communication systems. 

Brokerage contact information and communication data  #

For purposes of this policy, “Brokerage Contact Information” includes any email address, telephone number, name, username, account identifier, profile information, roster, directory entry, distribution list, membership list, channel membership, workspace information, or other contact or identifying information relating to an Associate, employee, contractor, applicant, client, vendor, or other person connected with the Brokerage. 

“Brokerage Communication Data” includes recipient information, sender information, headers, copied recipients, blind-copied recipients, reply chains, signatures, attachments, message exports, channel data, member lists, workspace data, and information obtained from any Brokerage communication or system. 

Brokerage Contact Information and Brokerage Communication Data constitute confidential and proprietary Brokerage information when obtained through or derived from: 

• The Easy Realty email system; 

• The Easy Realty Slack workspace; 

• Brokerage directories, rosters, distribution lists, or group communications; 

• Email recipient fields, including the To, CC, and BCC fields; 

• Forwarded messages or reply chains; 

• Brokerage support systems, portals, transaction systems, files, records, or databases; 

• Brokerage meetings, events, educational programs, or onboarding materials; 

• Any other system, communication, document, or resource provided, maintained, sponsored, or facilitated by the Brokerage. 

The availability or visibility of contact information within a Brokerage system or communication does not make that information public, grant permission for its reuse, or authorize an Associate to compile, retain, redistribute, or use it for another purpose. 

Limited authorized use  #

The Brokerage provides Associates with limited access to Brokerage Contact Information solely as reasonably necessary to: 

• Conduct legitimate brokerage business; 

• Communicate regarding a specific transaction, referral, client matter, compliance issue, or operational need; 

• Obtain appropriate professional assistance from another Associate; 

• Participate in approved Brokerage systems and community channels; or 

• Perform another activity expressly authorized in writing by the Broker or the Broker’s authorized representative. 

Access to Brokerage Contact Information constitutes a limited, revocable, nonexclusive, and nontransferable permission to use the information only for its authorized purpose. It does not convey ownership of the information or create a right to use the information for personal, commercial, organizational, political, recruiting, advocacy, or other independent purposes. 

No permission shall be inferred from prior communications, access to a system, inclusion in an email, visibility within Slack, the absence of a technical restriction, or a recipient’s failure to object. 

Prohibited collection, scraping, and use  #

Associates shall not, directly or indirectly: 

• Scrape, harvest, crawl, copy, photograph, capture, download, export, extract, compile, aggregate, reproduce, or create a database from Brokerage Contact Information; 

• Obtain email addresses or other contact information from the To, CC, or BCC fields of a Brokerage message for reuse outside the original communication; 

• Use information collected from Slack profiles, channel membership, workspace directories, Brokerage emails, rosters, transaction records, or other Brokerage systems to create a mailing list or contact list; 

• Combine Brokerage Contact Information with information obtained from another source to create or expand a mailing list, database, audience, or campaign; 

• Upload Brokerage Contact Information to a personal email account, marketing platform, customer relationship management system, contact-management system, social-media platform, advertising audience, messaging platform, artificial-intelligence service, or third-party database; 

• Sell, license, trade, exchange, publish, disclose, transmit, or provide Brokerage Contact Information to another individual or entity; 

• Permit another person or entity to use Brokerage Contact Information; 

• Use another individual, business, vendor, marketing platform, automated tool, alias, account, or communication method to engage in conduct prohibited by this policy; 

• Circumvent access controls, communication restrictions, account limitations, or other safeguards implemented by the Brokerage; or 

• Retain Brokerage Contact Information after the authorized purpose has ended or after the Brokerage requests its return or deletion. 

These restrictions apply whether the information is collected manually, automatically, through software, through an export function, from a forwarded message, from an email recipient list, or by any other means. 

Prohibition on unauthorized group communications  #

No Associate may send or cause to be sent a mass, bulk, roster-wide, group, or coordinated communication to Associates without prior written authorization from the Broker or the Broker’s authorized representative. 

This prohibition applies regardless of: 

• The number of intended recipients; 

• Whether the recipients are placed in the To, CC, or BCC field; 

• Whether the communication is sent through an Easy Realty account, personal account, third-party platform, text-messaging service, social-media service, or another communication method; 

• Whether the communication is described as informational, educational, personal, professional, charitable, political, commercial, or noncommercial; or 

• Whether the sender believes the recipients may be interested in the subject matter. 

Prohibited uses include, but are not limited to: 

• Advertising or marketing a product or service; 

• Promoting a personal business, affiliate offer, investment, event, platform, software, training program, or paid service; 

• Recruiting for another brokerage, organization, team, vendor, or business opportunity; 

• Distributing newsletters, promotions, surveys, petitions, solicitations, fundraising requests, or advocacy messages; 

• Organizing Associates outside approved Brokerage channels; 

• Requesting participation in a coordinated response, campaign, complaint, or reply-all discussion; 

• Promoting a third party or allowing a third party to communicate with Associates; and 

• Sending any other unsolicited communication to a compiled group of Associates. 

A communication does not become authorized merely because it concerns real estate, agents, the Brokerage, the industry, professional education, or a matter the sender considers beneficial. 

Recipient privacy and email practices  #

When the Brokerage authorizes a group email, the sender must follow all instructions issued with that authorization and must: 

• Use an approved Brokerage account or communication platform; 

• Limit recipients to the authorized audience; 

• Use BCC, an approved distribution system, or another privacy-protective method when individual recipient addresses do not need to be disclosed; 

• Avoid unnecessary use of Reply All; 

• Accurately identify the sender and purpose of the communication; 

• Include required disclosures, contact information, and opt-out functionality when the message is commercial or when otherwise required by law or Brokerage instruction; 

• Honor recipient communication preferences and opt-out requests; 

• Protect recipient information from further use or disclosure; and 

• Comply with applicable law, this policy, the Independent Contractor Agreement, the Office Policy Manual, and all Brokerage instructions. 

Federal CAN-SPAM guidance applies to commercial email, including business-to-business commercial email, and requires specified sender, content, postal-address, and opt-out practices. Compliance with those minimum legal requirements does not replace the requirement to obtain written Brokerage authorization before using Brokerage Contact Information for a group communication. [ftc.gov], [ftc.gov] 

Approved agent community platform  #

The Easy Realty Slack workspace is the approved platform for general Associate community engagement, including: 

• Sharing professional knowledge and ideas; 

• Asking other Associates for assistance; 

• Seeking community support; 

• Discussing general real estate practices and resources; 

• Sharing appropriate professional opportunities; 

• Participating in Brokerage announcements and discussions; and 

• Communicating with colleagues on matters appropriate for the broader agent community. 

Use of Slack remains subject to the Independent Contractor Agreement, Office Policy Manual, Brokerage policies, applicable law, workspace rules, and moderation by the Brokerage. 

Slack shall not be used to scrape member information, build contact lists, conduct unauthorized solicitation, promote prohibited products or services, distribute member information outside the workspace, or circumvent this policy. 

The Brokerage may designate additional approved channels or may direct that a particular communication be submitted to management for distribution instead of being posted or sent directly by an Associate. 

Consent and recipient authorization  #

An Associate who wishes to communicate with another Associate outside approved Brokerage channels is responsible for ensuring that the communication is individualized, legitimate, professional, and related to an appropriate brokerage purpose. 

Consent to receive one communication does not constitute consent to receive unrelated communications, recurring communications, marketing, solicitations, or messages from third parties. 

Participation in Easy Realty, access to Slack, receipt of Brokerage emails, or inclusion in a Brokerage roster does not constitute consent to receive independent mass communications from another Associate. 

The Brokerage may require documented recipient consent before approving recurring, promotional, or commercial communications. 

No authority to speak for or bind the Brokerage  #

Unless expressly authorized in writing, an Associate may not state or imply that: 

• A mass communication is approved, sponsored, endorsed, or distributed by Easy Realty; 

• The Associate is communicating on behalf of Easy Realty or Brokerage management; 

• The Brokerage has approved a product, service, vendor, campaign, position, event, or opportunity; or 

• The recipient list was provided or approved by the Brokerage. 

Associates have no authority to bind the Brokerage, incur obligations on its behalf, waive its rights, make representations for management, or authorize another person to use Brokerage Contact Information. 

Reporting and preservation of evidence  #

An Associate who becomes aware of suspected scraping, harvesting, unauthorized disclosure, unauthorized mass communication, or other misuse of Brokerage Contact Information must promptly report the matter to Brokerage management. 

Upon receiving notice of a suspected violation, the Associate must: 

• Immediately stop the communication or use; 

• Preserve the original message, recipient list, headers, attachments, exports, source files, platform records, and related evidence; 

• Refrain from deleting, altering, concealing, or destroying relevant information; 

• Provide requested records and information to the Brokerage; 

• Identify any platform, vendor, individual, or third party that received the information; 

• Follow Brokerage instructions concerning correction, deletion, recipient notification, or containment; and 

• Confirm compliance in writing if requested. 

Nothing in this section requires an Associate to violate applicable law. Any legally required preservation obligation controls over a deletion instruction. 

Return and deletion  #

Upon request by the Brokerage, suspension of access, or termination of affiliation, an Associate must return or permanently delete all Brokerage Contact Information and Brokerage Communication Data in the Associate’s possession or control, including copies stored in: 

• Personal email accounts; 

• Contact applications; 

• Mobile devices; 

• Computers; 

• Cloud-storage systems; 

• Marketing platforms; 

• Customer relationship management systems; 

• Spreadsheets; 

• Backup files; and 

• Third-party services. 

If requested, the Associate must provide written certification that the information has been returned or deleted and identify any copy that cannot lawfully or technically be deleted. 

Enforcement and remedies  #

A violation of this policy may result in one or more of the following, subject to applicable law and the governing agreements: 

• A directive to cease the communication immediately; 

• Removal of a message or post from a Brokerage-controlled system; 

• Temporary or permanent restriction of access to email, Slack, directories, rosters, support systems, or other Brokerage resources; 

• Required deletion or return of Brokerage information; 

• Compliance review or investigation; 

• Written warning or corrective instruction; 

• Required training; 

• Referral to the Broker or other appropriate authority; 

• Termination of affiliation; and 

• Any other lawful action reasonably necessary to protect the Brokerage, its systems, its Associates, and its clients. 

The Associate remains responsible for losses, claims, penalties, expenses, remediation costs, or third-party charges caused by the Associate’s unauthorized conduct to the extent provided by the Independent Contractor Agreement, Office Policy Manual, other applicable agreement, or law. 

The Brokerage may seek injunctive or other available relief when unauthorized use or disclosure threatens continuing or irreparable harm. The Brokerage’s decision not to enforce a provision on one occasion does not waive its right to enforce that provision or any other provision in the future. 

The Brokerage’s rights and remedies are cumulative to the extent permitted by law. 

Exceptions  #

An exception is valid only when: 

• It is approved in writing by the Broker or the Broker’s authorized representative; 

• It identifies the permitted purpose, audience, communication method, and duration; and 

• The Associate follows all conditions attached to the approval. 

Emergency communication involving an immediate threat to health, safety, property, or an active transaction may be made when reasonably necessary, but must be limited to appropriate recipients and reported promptly to the Brokerage when prior approval is impracticable. 

Survival  #

The obligations concerning confidentiality, nondisclosure, nonuse, evidence preservation, return, deletion, responsibility for unauthorized activity, and protection of Brokerage Contact Information survive suspension, resignation, transfer, termination, or any other end of affiliation. 

Interpretation  #

This policy establishes Brokerage requirements in addition to applicable legal requirements. If any provision is determined to be invalid or unenforceable, the remaining provisions shall continue in effect to the fullest extent permitted by law. 

Where a legal requirement, Independent Contractor Agreement, Office Policy Manual provision, or written Broker instruction imposes a stricter requirement, the stricter lawful requirement controls. 

Prohibited Email Use  #

Beginning October 1, 2026, personal email accounts may not be used to conduct brokerage business. 

Examples include: 

• Gmail 

• Yahoo Mail 

• Outlook.com 

• iCloud Mail 

• AOL Mail 

• Proton Mail 

• Any other personal or consumer email service 

Personal email accounts may not be used to transmit, receive, store, archive, or discuss: 

• Client documents 

• Transaction records 

• Financial information 

• Identification documents 

• Personally identifiable information (PII) 

• Compliance-related communications 

• Brokerage-related business communications 

Multi-Factor Authentication (MFA)  #

To reduce the risk of unauthorized access and account compromise, Multi-Factor Authentication (MFA) is mandatory for all Easy Realty email accounts. 

All associates must: 

• Complete MFA enrollment during onboarding 

• Maintain access to their approved authentication method 

• Protect devices used for MFA authentication 

• Immediately report lost, stolen, replaced, or compromised authentication devices 

• Comply with future security requirements implemented by the brokerage 

Associates may not disable, bypass, or circumvent MFA protections. 

Failure to maintain MFA protection may result in suspension of email access until compliance is restored. 

Account Security Requirements  #

All associates are responsible for maintaining the security of their Easy Realty email account. 

Users must: 

• Use strong and unique passwords 

• Keep login credentials confidential 

• Secure devices used to access company email 

• Promptly install security updates when required 

• Exercise caution when opening links or attachments 

• Verify unusual requests involving financial information, banking instructions, or confidential documents 

• Follow brokerage cybersecurity procedures and guidance 

Email credentials may not be shared with any other individual. 

Suspicious Activity Reporting  #

Associates must immediately report any suspected cybersecurity or fraud-related incident, including: 

• Phishing attempts 

• Spoofed email messages 

• Suspected account compromise 

• Unauthorized account access 

• Wire fraud attempts 

• Suspicious requests involving client funds 

• Lost or stolen devices 

• Any incident that may expose client or brokerage information 

Prompt reporting is critical to protecting our clients, our agents, and the brokerage. 

Protection of Client Information  #

Associates are expected to exercise reasonable care when handling confidential information and client records. 

Client information shall only be disclosed to authorized parties and only for legitimate business purposes. 

Particular care should be exercised when transmitting: 

• Government-issued identification 

• Driver’s licenses 

• Passports 

• Bank statements 

• Account and routing numbers 

• Earnest money deposit checks 

• Wire instructions 

• Tax records 

• Financial documentation 

• Transaction documents 

• Personally identifiable information (PII) 

All associates must follow brokerage procedures designed to reduce the risk of fraud, unauthorized disclosure, identity theft, and data breaches. 

Record Retention and Brokerage Records  #

Communications conducted through Easy Realty email accounts are brokerage business records. 

To the extent permitted by law, Easy Realty reserves the right to retain, archive, access, review, monitor, and disclose business communications when reasonably necessary for: 

• Broker supervision 

• Compliance reviews 

• Audits 

• Risk management 

• Regulatory inquiries 

• Litigation 

• Security investigations 

• Business continuity 

• Operational purposes 

Associates should have no expectation of privacy regarding brokerage business communications conducted through brokerage-provided email accounts. 

Onboarding and Training  #

Easy Realty will provide account setup assistance, training resources, and technical support. 

Associates are expected to: 

• Complete account setup in a timely manner 

• Participate in required onboarding activities 

• Maintain access to their assigned email account 

• Comply with security training requirements established by the brokerage 

Compliance  #

Compliance with this policy is a condition of conducting business on behalf of Easy Realty. 

The use of unauthorized communication platforms creates increased risks related to: 

• Client privacy 

• Cybersecurity 

• Wire fraud 

• Regulatory compliance 

• Document retention 

• Broker supervision 

• Protection of confidential information 

Failure to comply with this policy may result in corrective action, suspension of system access, compliance review, or other actions deemed appropriate by brokerage management. 

Questions  #

Questions regarding this policy, onboarding assistance, technical support, or approved communication practices should be directed to Easy Realty management.