Last Modified: June 1, 2023
Overview and Scope
You should know what information the Company collects from you and how the Company uses it, and you should have meaningful control over both. This Policy describes how the Company collects and uses information, including personal information, with whom the Company shares information, your rights and choices, and how you can contact the Company about the Company’s privacy practices. This Policy does not apply to any third-party website you access that is not the Site.
When you access the Site or use the Company’s mobile applications, if any (“Online Services”), contact the Company, or otherwise interact with the Company (collectively, “Services”), the Company collects personal information about you. Personal information is information about an individual from which that person can be identified. It does not include information where the identity has been removed (e.g., anonymous data). The Company may also receive personal information about you from other sources. The Company may combine the personal information you provide to the Company with information that is collected through automated methods and with information the Company receives from other sources. Information the Company collects about you may include:
- Account: Through the Company’s Online Services you may create an account to, for example, save property searches, sign up for property alerts, access the Company’s real estate resources, and for other features the Company may add from time to time (“Account”). When you create an Account, the Company collects your first and last name, email address, username, and password. If you wish, you may provide the Company your phone number, street address and a state, city, or zip code. The Company uses this personal information to respond to your requests, manage and correspond with you about your Account, send you information and newsletters related to real estate markets, properties, and/or other information the Company thinks may interest you, to assist you in your home buying or home selling process, and for other matters described in this Policy.
- Contact: When you contact the Company with questions about the Company’s Services or other matters, the Company will use any personal information you provided, including, for example, your name, email, and phone to resolve your request or answer your questions, or to provide additional information related to your inquiry. The Company may place you on the Company’s marketing list for information related to your inquiry or which the Company otherwise believes would be of interest to you, and the Company may otherwise use your personal information as described in this Policy. You will always have the opportunity to opt-out of receiving communications from the Company by following the instructions provided in the Company’s communication(s).
- Online Services: Consistent with many websites and applications, the Company’s Online Services automatically collect certain information about your equipment, browsing actions, and patterns, including details of your visits, including traffic data, location data (if enabled), logs, and other communication data and the resources that you access and use on the Online Services, and information about your computer, mobile device, internet connection, including your IP address, operating system, and browser type. The Company also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information the Company collects automatically is only statistical data and does not include personal information, but the Company may maintain it or associate it with personal information the Company collects in other ways or receive from third parties. It helps the Company to improve the Online Services and to deliver a better and more personalized service, including by enabling the Company to: (1) estimate audience size and usage patterns; (2) store information about your preferences, allowing the Company to customize the Online Services according to your individual interests; (3) speed up your searches; and/or (4) recognize you when you return to the Online Services.
Company Use of the Information Collected
The Company uses information that the Company collected or that you provided to the Company, including any personal information: (1) to fulfill or meet the reason you provided the information; (2) to provide, support, personalize, and develop Services; (3) to create, maintain, customize, and secure your Account; (4) to provide you with support and to respond to your inquiries; (5) to personalize your experience with Online Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Online Services, third-party sites, and via email or text message (with your consent, where required by law); (6) help maintain the safety, security, and integrity of the Online Services, products and Services, databases and other technology assets, and business; (7) to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and/or (8) for testing, research, analysis, and product development, including to develop and improve the Online Services, products, and Services.
Legal Basis for Collection and Use of Information
The Company only uses the information that the Company collects about you or that you provided to the Company for the purposes set forth in this Policy and based on the following legal grounds: (1) your consent (as permitted by law); (2) the Company’s legitimate business interests, including but not limited to: (a) managing the Company’s relationship with you; (b) managing the Company’s relationship with the Company’s affiliates and/or associates; (c) direct marketing; (d) product development and enhancement; (e) fraud and financial crime detection and prevention; (f) information, system, network, and cyber security; and/or (g) general corporate operations and due diligence; (3) to provide services to you; and/or (4) to comply with a legal obligation and/or defend against legal claims.
Sharing Collected Information
The Company shares the information that the Company collects about you or that you provided to the Company as described in this Policy:
- Real Estate Network. The Company may share this information within the Company’s real estate Network, which includes the Company, its affiliates, subsidiaries, franchisees, and associates.
- Service Providers. The Company may share this information with service providers who provide certain services on the Company’s behalf such as data hosting or processing services. These service providers may need to access this information to perform their services. The Company authorizes such service providers to use or disclose this information only as necessary to perform services on the Company’s behalf or comply with legal requirements. The Company requires these service providers to contractually commit to protect the security and confidentiality of the information they process on the Company’s behalf.
- Business Partners. The Company may share this information with third party business partners. The Company requires such business partners to contractually commit to protect the security and confidentiality of the information they process on the Company’s behalf.
- Anonymized Information. The Company may share analyses of the Company’s server logs, traffic, or information relating to customer leads, including details regarding usage of the Online Services and general information about the Company’s audience, with current or potential advertisers or business partners. Such disclosures typically aggregate usage data from these analyses and other information not generally considered to be personal information.
- Corporate Transactions. In the event that the Company goes through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of the Company’s assets, personal information will, in most instances, be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Policy and the privacy choices you have made.
Rights and Choices Regarding Use and Disclosure
You have choices regarding the Company’s use and disclosure of your personal information.
- Electronic Communications. If you no longer want to receive marketing-related emails from the Company, you may opt-out via the unsubscribe link included in such emails. The Company will try to comply with your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from the Company, the Company may still send you important administrative messages that are required to provide you with the Company’s services. If you no longer want to receive marketing-related emails from any associate, affiliate, and/or third-party, you may out-out via the unsubscribe link included in those emails or contact them directly.
- If you created an Account, you can always access your personal information by logging into your Account. If you have trouble or you need further assistance with accessing your Account, or deleting your Account, you may contact the Company at email@example.com.
- Data Protection Rights. Depending on where you reside and subject to applicable law, you may have the following rights with regards to the personal information you shared with the Company: (1) right to request confirmation of whether the Company processes personal information relating to you, and if so, to request a copy of that personal information; (2) right to request that the Company rectify or update personal information that is inaccurate, incomplete or outdated; (3) right to request that the Company erase your personal information in certain circumstances provided by law; (4) right to request that the Company restrict the use of your personal information in certain circumstances; for example, while the Company considers a request to update your personal information; (5) right to request that the Company send to another company, where technically feasible, your personal information; (6) right to withdraw consent to processing your personal information that you previously gave; and (7) right to object to the processing of your personal information under certain circumstances. In order to exercise these rights, contact the Company at firstname.lastname@example.org. The Company will comply with your request to the extent required by applicable law. If you feel that you have not received a satisfactory response from the Company, you may consult with the data protection authority in your country.
The Company understands that the security of your personal information is important. For this reason, the Company maintains organizational, physical, and technical security arrangements designed to protect personal information within the Company against unauthorized access, destruction, loss, alteration or misuse. The Company periodically reviews the Company’s security measures and update them accordingly. Unfortunately, despite the Company’s best efforts, no data transmission or storage can be guaranteed to be 100% secured.
The Company stores your personal information in the Company’s servers, and/or on the servers of the cloud-based database management services the Company engages, located in the United States (or elsewhere if needed). The Company will only retain your information for as long as necessary to fulfill the purposes for which we collected your personal information, unless a longer retention period is required or permitted by law.
Links to Websites and/or Social Media
The Company’s Online Services may offer links to websites, apps, tools, widgets and plug-ins, such as Facebook “Like” buttons, that are run by third parties. If you visit a third-party website, you should read the website’s privacy notice, terms and conditions, and their other policies. The Company is not responsible for the policies and practices of third parties. Any personal information you give to those organizations is dealt with under their privacy notice, terms and conditions, and other policies.
The Online Services are not intended or directed to children under the age of 18, and the Company does not knowingly collect personal information relating to children or track their use of the Online Services.
International Data Transfer
Your personal information may be accessed, stored and processed in a country where the Company has operations or where the Company engaged service providers. This means that the Company may transfer personal information that the Company maintains about you to recipients in countries other than the country in which the information was originally collected. The data protection and privacy laws in those countries may offer a lower level of protection than the data protection and privacy laws of your country. By using the Company’s Services, you acknowledge that such transfers of information outside of your country of residency may occur.
Transfers from the EEA or Switzerland
The Company, its subsidiaries and affiliates (collectively the “Company”), adopt this Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Policy. You are strongly urged to read this Policy from beginning to end. This Policy is easy to navigate and provides quick access to information you may care about and is easy to understand because it is in plain English.
The Company collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In the last 12 months, the Company has collected the following categories of personal information from consumers:
Categories Examples Collected
Identifiers. A real name, alias, postal address, unique Yes
personal identifier, online identifier, Internet
Protocol address, email address, account name,
Social Security number, driver’s license number,
passport number, or other similar identifiers.
Personal information A name, signature Social Security number, Yes
listed in the California physical characteristics or description, address,
Customer Records statute telephone number, passport number, driver’s
(Cal. Civ. Code § license or state identification card number,
1798.80(e)). insurance policy number, education, employment, employment history, bank account number,
credit card number, debit card number, or any
other financial information, medical information,
or health insurance information. Some personal
information included in this category may overlap
with other categories.
Protected classification Age (40 years or older), race, color, ancestry Yes
Characteristics under national origin, citizenship, religion or creed
California or federal marital status, medical condition, physical or
Law. Mental disability, sex (including gender, gender
Identity, gender expression, pregnancy or
childbirth and related medical conditions),
sexual orientation, veteran or military status,
genetic information (including familial genetic
Commercial information. Records of personal property, products or Yes
services purchased, obtained, or considered,
or other purchasing or consuming histories or
Biometric information. Genetic, physiological, behavioral, and No
biological characteristics, or activity patterns
used to extract a template or other identifier or
identifying information, such as, fingerprints,
faceprints, and voiceprints, iris or retina scans,
keystroke, gait, or other physical patterns, and
sleep, health, or exercise data.
Internet or other similar Browsing history, search history, information Yes
activity. on a consumer’s interaction with a website,
application, or advertisement.
Geolocation data. Physical location or movements. Yes
Sensory data. Audio, electronic, visual, thermal, olfactory, No
or similar information.
Professional or Current or past job history or performance Yes
Non-public education Education records directly related to a student No
Information (per the maintained by an educational institution or
Family Educational party acting on its behalf, such as grades,
Rights and Privacy transcripts, class lists, student schedules,
Act (20 U.S.C. Section student identification codes, student financial
1232g, 34 C.F.R. information, or student disciplinary records.
Inferences drawn from Profile reflecting a person’s preferences, Yes
other personal characteristics, psychological trends,
information. predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.
Personal information does not include: (1) publicly available information from government records; (2) deidentified or aggregated consumer information; or (3) information excluded from the CCPA’s scope, such as, for example: (a) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
The Company collects the categories of personal information listed above from the following categories of sources:
Categories Sources of Personal Information
Identifiers. Directly from consumers. For example, when consumers create accounts or contact the Company.
Indirectly from consumers by observing their actions on the Company’s Online Services.
Third parties. For example, MLS services, Facebook, Google, and consumer identity and access management companies.
Personal information Directly from consumers. For example, when
categories listed in the consumers create accounts or contact the Company.
California Customer Records
Statute (Cal. Civ. Code Indirectly from consumers by observing their actions
- 1798.80(e)). on the Company’s Online Services.
Third parties. For example, MLS services, Facebook, Google, and consumer identity and access management companies.
Protected classification Third parties. For example, consumer identity and
characteristics under California access management companies.
or federal law.
Commercial information. Directly from consumers. For example, when consumers use the home valuation feature on the Company’s Online Services.
Third parties. For example, consumer identity and
access management companies.
Internet or other similar Directly from consumers when they interact with
network activity. the Company’s Online Services.
Indirectly from consumers by observing their actions on the Company’s Online Services.
Geolocation data. Indirectly from consumers by observing their actions on the Company’s Online Services.
Professional or employment Third parties. For example, consumer identity and
-related information. access management companies.
Inferences drawn from other Directly from consumers. For example, from
personal information. information provided through consumer’s account.
Third parties. For example, consumer identity and
access management companies.
Use of Personal Information
The Company may use or disclose to others the personal information the Company collects for one or more of the following purposes: (1) to fulfill or meet the reason you provided the personal information; (2) to provide, support, personalize, and develop the Company’s Services; (3) to create, maintain, customize, and secure your account with the Company; (4) to provide you with support and to respond to your inquiries; (5) personalize your experience on the Company’s Online Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Company’s Online Services, third-party sites, and via email or text message (with your consent, where required by law); (6) to help maintain the safety, security, and integrity of the Company’s Online Services, products, databases and other technology assets, and business; (7) for testing, research, analysis, and product development, including to develop and improve the Company’s Online Services and products; (8) to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; (9) to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company is among the assets transferred; and/or (10) as described to you when collecting your personal information or as otherwise set forth in the CCPA. The Company will not collect additional categories of personal information or use the personal information the Company collected for materially different, unrelated, or incompatible purposes without providing you notice.
Personal Information Disclosed
The Company may disclose your personal information to third-party service providers for a business purpose or disclose your personal information to other third-parties, subject to your right to tell the Company not so share your information (see Personal Information Sales Opt-Out and Opt-In).
When the Company discloses personal information to third-party service providers for a business purpose, the Company enters into contracts that describe the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. When the Company discloses your personal information to other third-parties, the CCPA prohibits those third parties from selling it unless you have received explicit notice and an opportunity to opt-out of further sales.
In the last 12 months, the Company has disclosed the following categories of personal information: (1) identifiers; (2) personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (3) commercial information; (4) Internet or other similar network activity; (5) geolocation data; and (6) inferences drawn from other personal information.
The Company discloses your personal information for the following categories of third parties: (1) service providers; (2) affiliated brokers and sales associates; (3) consumers using the Company’s Online Services; (4) web analytics services; (5) email service providers; and (6) approved suppliers.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to specific information and data portability rights
You have the right to request the Company to disclose certain information to you about the Company’s collection and use of your personal information over the past 12 months. Once the Company receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), the Company will disclose to you: (1) the categories of personal information the Company collected about you; (2) the categories of sources for the personal information the Company collected about you; (3) the Company’s business or commercial purpose for collecting or disclosing that personal information; (4) specific pieces of personal information the Company collected about you; and (5) if the Company disclosed your personal information for a business purpose, two separate lists disclosing: (a) the categories of personal information and the categories of services providers to whom the Company disclosed such information; and (b) the categories of personal information and the categories of third parties to whom the Company disclosed such information.
Deletion Request Rights
You have the right to request the Company to delete any of your personal information that the Company collected from you and retained, subject to certain exceptions. Once the Company receives and confirms your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), the Company will delete (and direct the Company’s service providers to delete) your personal information from the Company’s records, unless an exception applies.
The Company may deny your deletion request if retaining the information is necessary for the Company or the Company’s service providers to: (1) complete the transaction for which the Company collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of the Company’s ongoing business relationship with you, or otherwise perform the Company’s contract with you; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) debug products to identify and repair errors that impair existing intended functionality; (4) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with the Company; (8) comply with a legal obligation; and/or (9) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising access, data portability, and deletion rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to the Company by either calling (248) 981-6427, emailing email@example.com, or mailing 423 S Washington Avenue Royal Oak, MI 48067. If you have questions about your rights, please email the Company at firstname.lastname@example.org. Please note that only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (1) provide sufficient information that allows the Company to reasonably verify you are the person about whom the Company collected personal information or an authorized representative; and (2) describe your request with sufficient detail that allows the Company to properly understand, evaluate, and respond to it. The Company cannot respond to your request or provide you with personal information if the Company cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with the Company. The Company will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In.
Response Timing and Format
The Company endeavors to respond to a verifiable consumer request within 45 days of its receipt. If the Company requires more time (up to 90 days), the Company will inform you of the reason and extension period in writing. The Company will deliver a written response by mail or electronically. Any disclosures the Company provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response will also explain the reasons the Company cannot comply with a request, if applicable. For data portability requests, the Company will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. The Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If the Company determines that the request warrants a fee, the Company will tell you why that decision was made and provide you with a cost estimate before completing your request.
Personal information sales opt-out and opt-in rights
You have the right to request the Company to not disclose your personal information to non-service provider third parties at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to the Company by emailing email@example.com.
Once you make an opt-out request, the Company will wait at least 12 months before asking you to reauthorize personal information disclosures to non-service provider third parties. However, you may change your mind and opt back into personal information disclosures to non-service provider third parties at any time by emailing firstname.lastname@example.org. You do not need to create an account with the Company to exercise your opt-out rights. The Company will only use personal information provided in an opt-out request to review and comply with the request.
The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not: (1) deny you goods or services; (2) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) provide you a different level or quality of goods or services; (4) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, the Company may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive the Company offers will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Company’s Online Services that are California residents to request certain information regarding the Company’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email email@example.com.
The Company reserves the right to amend this Policy at the Company’s discretion and at any time. When the Company makes changes to this Policy, the Company will post the updated Policy on the Company’s Online Services and update the Policy’s effective date. Your continued use of the Company’s Online Services following the posting of changes constitutes your acceptance of such changes.
If you have general questions or comments about the Company or this Policy, contact the Company by email at firstname.lastname@example.org, or by mail at 423 S. Washington Avenue Royal Oak, MI 48067.