PRIVACY POLICY
Last updated June 06, 2024
This privacy notice for Dan Kenney, The RAD Realtor ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
Visit our website at http://www.radrealtor.com, or any website of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dankenneyrealty@gmail.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.radrealtor.com/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names
phone numbers
email addresses
contact preferences
contact or authentication data
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
financial data
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: http://www.radrealtor.com/cookie-policy.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: http://www.radrealtor.com/cookie-policy.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
Send users information about special offers and discounts on our products and services
Develop and display personalized and relevant advertising content for our users
Analyze how our Services are used so we can improve them to engage and retain users
Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: http://www.radrealtor.com/cookie-policy.
Google Analytics
We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dankenneyrealty@gmail.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: http://www.radrealtor.com/cookie-policy.
If you have questions or comments about your privacy rights, you may email us at dankenneyrealty@gmail.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
CategoryExamplesCollected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information as defined in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
YES
C. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information
YES
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO
G. Geolocation data
Device location
NO
H. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our business activities
NO
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
NO
L. Sensitive personal Information
NO
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
Category A - Until the user requests to be removed from our roles
Category B - Until the user requests to be removed from our database
Category D - Until the user requests to be removed from our database
Category H - 1 year
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting http://www.radrealtor.com/contact, by emailing us at dankenneyrealty@gmail.com, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at dankenneyrealty@gmail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at dankenneyrealty@gmail.com or contact us by post at:
Dan Kenney, The RAD Realtor
2120 A Academy Circle
Colorado Springs, CO 80909
United States
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: http://www.radrealtor.com/contact.
BETTER HOMES AND GARDENS REAL ESTATE KENNEY & COMPANY Privacy Policy
Effective Date: January 1, 2023
Better Homes & Gardens Real Estate LLC (“BHGRE”) and our affiliate and subsidiary companies (such as Anywhere Real Estate Inc., Guaranteed Rate Affinity, Anywhere Integrated Services, Anywhere Advisors, Realogy Insurance Agency, and Anywhere Leads Inc.) (collectively, “BHGRE” “we,” “our,” or “us”) are committed to privacy and to transparency in our information practices. This Privacy Policy describes how we collect, use, disclose, and otherwise process the personal information described in this Privacy Policy, as well as the rights and choices individuals have regarding such personal information. This Privacy Policy applies to the extent we process personal data on our own behalf, as a controller or business.
If you are a California resident, please be sure to review Section 17B. California Residents for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws.
You can click the links below to go directly to a particular section in our Privacy Policy.
SCOPE OF THIS PRIVACY POLICY
OUR COLLECTION OF PERSONAL INFORMATION
PURPOSES AND LEGAL BASIS FOR OUR PROCESSING
DISCLOSURE OF PERSONAL INFORMATION
Aggregate and Non-identifiable Data
COOKIES, TRACKING, AND ANALYTICS
INTEREST-BASED ADVERTISING
SOCIAL FEATURES AND THIRD-PARTY PLUG INS
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
SECURITY
DATA RETENTION
YOUR RIGHTS AND CHOICES
CHILDREN
THIRD-PARTY WEBSITES
CHANGES TO THIS PRIVACY POLICY
CONTACT US
ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS
EEA and the United Kingdom
California Residents.
Residents of Other U.S. States
1. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to our collection, use, disclosure, and other processing of personal information related to:
Our websites (each, a “Website”) and mobile applications (each, an “App”) that display or link to this Privacy Policy and our other services, products, and technology solutions (collectively, the “Services”).
Former, current, and prospective clients, brokers, independent agents, and customers.
Other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services or our business.
Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This Privacy Policy is intended to describe our overall privacy and data protection practices.
Not covered by this Privacy Policy. This Privacy Policy does not apply to our employees and non-employee workers.
Additional privacy notices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information. The additional notice will control to the extent there is a conflict with this Privacy Policy, with respect to your personal information that is subject to that notice.
2. OUR COLLECTION OF PERSONAL INFORMATION
Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services or we may be unable to fully respond to your inquiry.
We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use). In some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Information we collect directly. We collect information that you provide to us, such as:
When you create an account, provide contact information, or send other personal information to us.
When you complete or submit a form through our Services, for example, “Contact Us” or “More Information” forms.
When you participate in surveys or contests, submit orders or requests, or register for or use our Services, or otherwise contact us.
Information you submit or provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria, information about financing for the purchase of real estate, and other information related to the purchase or sale of real estate.
Information we collect from third parties. We may collect or receive personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), brokers and affiliated agents, and other real estate professionals, and third parties. For example:
Social media. If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.
Real estate professionals. If you interact or list a property with a broker, independent agent, or other real estate professional associated with an Anywhere brands, we may receive personal information about you and your property from them, such as your name and property address, listing and contact information, among other things. These real estate professionals may be affiliated with independently owned and operated brokerages, or with an Anywhere company.
Property records. We may collect information about individuals and real estate property through public databases, such as property ownership and tax records maintained by state, local and county agencies.
3. PURPOSES AND LEGAL BASIS FOR OUR PROCESSING
Certain laws, including the EU General Data Protection Regulation (“GDPR”), UK and Brazil data protection law, and similar laws require that we inform applicable individuals of the legal basis for our use and other processing of their personal information. In this section, we described the purposes for which will collect, use, disclose and otherwise process personal information, as well as the legal bases for such processing, generally, under such privacy laws.
Legal bases under certain privacy laws. Pursuant to the GDPR, UK and Brazil data protection law, and similar laws we collect, use and otherwise process personal information for the following legal bases:
Performance of contract: as necessary to enter into or carry out the performance of our contract with you.
Compliance with laws: for compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, data protection, tax, and corporate compliance laws.
Our legitimate interests: in furtherance of our legitimate business interests including, for example:
Performance of contracts with franchisees and other parties
Implementation and operation of global support (e.g., IT) services for our business operations
Customer relationship management and improving our Services, including marketing and analytics
Marketing and advertising
Fraud prevention, including misuse of company IT systems or money laundering
Physical, IT, and network perimeter security
Internal investigations
Mergers, acquisitions, and reorganization, and other business transactions
With your consent: in some cases, we rely on your consent to collect and process your personal information. (See Section 17A below for information about withdrawing your consent.)
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes of processing. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we collect, use, disclose and otherwise process personal information for the purposes set forth below, as well as the legal basis for such processing, as applicable under relevant laws (see above for further explanation of these legal bases):
Providing support and services: including, for example, to send or facilitate communications among you, independent real estate professionals and our affiliated entities, and other users of the Services, provide products and services you request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your requests and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
Analyzing and improving our business:including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys, and other evaluations, such as customer satisfaction surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests)
Personalizing content and experiences: including to provide or recommend features, content, social connections, and referrals; tailor content we send or display on our Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate interests and/or with your consent)
Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate interests and/or with your consent)
Securing and protecting our business:including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate interests and/or compliance with laws)
Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate interests and/or compliance with laws)
Planning and facilitating business transactions: related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate interests and/or compliance with laws)
Auditing, reporting, corporate governance, and internal operations:including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; and our general business, accounting, record keeping and legal functions. (Legal basis: our legitimate interests and/or compliance with laws)
Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests. (Legal basis: our legitimate interests and/or compliance with laws)
4. DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect to third parties, as reasonably necessary for the purposes described above and as otherwise directed or consented to by you, including:
Service providers: to third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.
Subsidiaries and affiliates: to our subsidiary and affiliated companies (i.e., companies under common ownership, control or management with us), such as Anywhere Real Estate Inc., Guaranteed Rate Affinity, Anywhere Integrated Services, Anywhere Advisors, Realogy Insurance Agency, and Anywhere Leads Inc., who may process your personal information in accordance with the principles of this Privacy Policy, including to share relevant news, information and offers with you. Where required by applicable law, we will obtain your consent to such sharing.
Third parties: to third parties in order to provide our Services, respond to or carry out your requests, and/or with your consent, including to:
Independent real estate professionals and owners and operators of real estate brokerage companies to enable them to provide services you request through the Services.
Third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.
The public if you submit to a public part of the Services, such as comments, social media posts, or other features viewable by the public or generally by registered users of the Services.
Third parties with whom you choose to let us share information, for example other apps or websites that integrate with the Services, or those with Services with which we integrate.
Third parties we work with to provide you with more personalized content and ads, and to track the effectiveness of campaigns.
Business transfers: as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event; and prior to the completion of such a transfer, where necessary for due diligence or to plan for the transfer, such as to lenders, auditors, and third-party advisors, such attorneys and consultants, where permitted by law.
Legally required:where we are required to do so by law or legal process (e.g., to law enforcement, courts or others, or in response to a subpoena or court order).
Protect our rights:where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers or others. including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
5. Aggregate and Non-identifiable Data
We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our deidentification processes are reasonable and adequate).
6. COOKIES, TRACKING, AND ANALYTICS
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associated with your usage of and activities on our Services.
We use the information for security purposes, to facilitate navigation, to improve, analyze and optimize our Services and their functionality, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns, and to better reach users with relevant advertising both on our Services and on third party websites.
Click “Cookie Preferences” link in the footer of our Website for more information about cookies on that Website, and to review and update your preferences for most types of cookies (other than those that are necessary to the functionality of that Website).
Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Service.
If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
Third party analytics tools. Our Websites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices and opt-out of collection of your browsing data by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Browser signals. Please note that our Websites do not recognize or respond to browser “do-not-track” requests or other browser privacy signals. However, you can review and update your cookie preferences on our Websites as discussed above.
7. INTEREST-BASED ADVERTISING
On some of our Websites, we may work with third-party ad networks, analytics companies, measurement services and others (“third-party ad companies”) to display advertising on our Services and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.
You can review and manage your preferences for targeting cookies and get information about to targeting cookies in use on one of our Websites by clicking “Cookie Settings” in the footer of our website.
You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks at the industry websites below:
8. SOCIAL FEATURES AND THIRD-PARTY PLUG INS
The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
9. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
BHGRE is headquartered in the United States and has affiliates and service providers in multiple jurisdictions. As such your personal information may be transferred to the United States and other jurisdictions where we or our service providers have operations, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such of these jurisdictions upon transfer. Some of these jurisdictions—including the United States—may not provide the same level of data protection as your home country. In such cases, we rely on suitable personal information transfer safeguards. You may request a copy or information about those safeguards by contacting us as detailed below.
10. SECURITY
We use technical, administrative, and physical controls in place to help protect personal information from unauthorized access, use, and disclosure. Even so, despite our efforts, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us in accordance with Section 16. Contact Us.
11. DATA RETENTION
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients’ instructions.
12. YOUR RIGHTS AND CHOICES
We provide several ways for you to exercise certain privacy choices regarding your personal information processed by us, as described in this section. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy laws require that we provide specific information about individual rights to applicable consumers, which we have set forth in Section 17 of this Privacy Policy. California residents, please review Section 17B. California Residents for information about your California privacy rights.
Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Cookies preferences. To review and update your preferences for most types of cookies (other than those that are necessary) for one of our Websites, Click “Cookie Preferences” link in the footer of that Website.
Deactivation. You can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfill this request.
Access, amendment and deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted or otherwise exercise your rights over your personal information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:
By submitting an email request to us at dataprivacy@anywhere.re
By contacting us at (888) 778-6995 (toll free)
We will process in accordance with and where required by applicable law, and with respect to your personal information that is linked or linkable to the email that you use to send us your request and the verifiable information provided by you as a part of your request. We will take steps to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
13. CHILDREN
The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.
14. THIRD-PARTY WEBSITES
The Services may contain links to third-party services. We do not own, operate, or control the websites of third parties, including those of independently owned and operated franchisees. Accordingly, this Privacy Policy does not apply to any services maintained or operated by third-parties. When you click on those links, you will go to a third-party website where you will be subject to that service’s privacy policy or similar statement and terms of use, and we encourage you to read that policy statement. We are not responsible for the privacy practices of other services, and we expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal information by those third parties.
15. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Services. Any material changes to this Privacy Policy will be effective 10 days after our posting of the updated Privacy Policy or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy.
16. CONTACT US
If you have any questions or concerns about this Privacy Policy, please use the following contact information:
Email: dataprivacy@anywhere.re
Mailing address: 175 Park Ave., Madison, NJ 07940 Attn: Data Privacy
Phone number: (888) 778-6995
17. ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS
Residents of certain states have additional rights under applicable privacy laws, as described in this section.
If you are a resident of the EEA or the United Kingdom, please review Section 17.A below for additional information about your privacy rights under applicable privacy laws.
If you are a resident of the United States, please review Section 17.B below for additional information about the categories of personal information we collect about you and your privacy rights under applicable California privacy laws and Section 17.C below for additional information about privacy rights under other U.S. state privacy laws.
A. EEA and the United Kingdom
The GDPR and UK data protection laws (where applicable), gives data subjects the following rights regarding their personal information:
Right of access: You have the right to obtain from us confirmation as to whether or not personal information concerning you is being processed, and where that is the case, to request access to the personal information. The accessed information includes – among others – the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal information have been or will be disclosed. You have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectify and complete personal information: you can request the rectification of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if we are legally obliged to do so.
Right to erasure (right to be forgotten): You have the right to obtain from us the erasure of personal information concerning you in limited circumstances where:
it is no longer needed for the purposes for which it was collected;
you have withdrawn your consent (where the data processing was based on consent);
following a successful right to object;
it has been processed unlawfully; or
the data has to be erased in order to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation, or the establishment, exercise or defense of legal claims.
Right to restriction of processing: You have the right to obtain from us restriction of processing your personal information. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised, subject to certain limitations, where: (i) the accuracy of your personal information is contested; (ii) the processing is unlawful, but you do not want the personal information erased; (iii) it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or (iv) you have exercised the right to object, and verification of overriding grounds is pending.
Right to data portability: You have the right to receive the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us, but in each case only where the processing is (a) based on your consent or on the performance of a contract with you, and (b) also carried out by automated means.
Right to object:You have the right to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Right to object to our use of your personal information for direct marketing: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to withdraw consent: if you have given us your consent for the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to obtain a copy of safeguards:you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.
You may submit your GDPR request to us via:
Our online webform
Phone at (888) 778-6995 (toll free)
B. California Residents.
This section provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.
In this section, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA.
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Below we describe the categories of personal information we may collect about California residents (including the categories of personal information that we have collected about California residents in the past 12 months):
Identifiers: includes direct identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Customer records: paper and electronic customer records containing personal information, which you provide to us in order to access or use our Services, such as name, digital signature, address, telephone number, email and other contact information, government identifiers, financial and payment information.
Characteristics of protected classifications: such as disability and health information (e.g., which we may collect in order to, for example, make accommodations available to you at events we host).
Commercial information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
Usage data:internet or other electronic network activity Information including without limitation browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Location data: location information about a particular individual or device.
Audio, Video and other Electronic Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage and thermal screenings (e.g., collected from visitors to our offices), photographs, and call recordings.
Employment history: professional or employment-related information.
Education information:education history and background.
Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Sensitive personal information: in limited circumstances, we may collect certain information considered to be sensitive personal information under the CCPA, including Social Security number and tax ID; driver’s license, state identification card, passport number, or other government identifier; financial account number and payment card data; and geolocation data.
Categories of third parties. Below we describe the third parties to whom we may disclose each category of personal information for a business or commercial purpose:
Identifiers:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
advertising networks
data analytics providers
social networks
operating systems and platforms
Customer records:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
operating systems and platforms
Characteristics of protected classifications:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
Commercial information:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
data analytics providers
social networks
operating systems and platforms
Usage data:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
advertising networks
data analytics providers
social networks
operating systems and platforms
Location data:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
operating systems and platforms
Audio, video and other electronic data:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
Employment History:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
Education information:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
Profiles and inferences:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
advertising networks
data analytics providers
social networks
Sensitive personal information:
service providers
advisors and agents
government entities and law enforcement
affiliates and subsidiaries
real estate professionals
In addition, we may disclose any of the categories of personal information we collect about you to other third parties as directed by or consented to by you, or where necessary to fulfill your specific requests.
Sales and sharing. The CCPA defines a “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA): (i) identifiers, usage data, customer records, commercial information and profiles with our affiliates and subsidiary companies (e.g., so that they may improve or enhance their own records and for other purposes); and (ii) identifiers, usage data and commercial information to ad networks, social media platforms and data analytics providers (e.g., in order to improve and measure our ad and marketing campaigns).
Sources of Personal Information. We may collect personal information from the following sources:
Directly from the individual
Real estate professionals, including brokers and independent agents of Anywhere brands
Property records, public records and other publicly available sources
Advertising networks
Data analytics providers
Social networks
Government entities
Data brokers
Affiliate and subsidiary companies
Service providers
Purposes of Collection, Use and Disclosure. As described in more detail in Section 3. Use of Personal Information and Section 4. Disclosures of Personal Information, we collect, use, disclose and otherwise process personal information (including sensitive personal information) for the following business or commercial purposes or as otherwise directed or consented to by you:
Providing support and services
Analyzing and improving our business
Personalizing content and experiences
Advertising, marketing and promotional purposes
Securing and protecting our business
Defending our legal rights
Planning and facilitating business transactions
Auditing, reporting, corporate governance, and internal operations
Complying with legal obligations
Retention. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy or otherwise disclosed to you at the time of collection unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.
Rights of California Residents. In general, California residents have the following rights under the CCPA:
California residents’ rights. Under the CCPA, California residents have the following rights (subject to certain limitations) with respect to the personal information we collect and maintain about them:
Opt out of sales and sharing: to opt-out of our sale and sharing of their personal information.
Limit uses and disclosures of sensitive personal information: to limit certain uses or disclosures of sensitive personal information to those uses authorized by the CCPA.
Deletion: to request deletion of their personal information, subject to certain exceptions.
To know/access: to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
Correction: to request correction of inaccurate personal information.
Non-discrimination: not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights to know/access, delate, correct, and limit use/disclosure of sensitive personal information by submitting a verifiable request to us via:
Our online webform
Phone at (888) 778-6995 (toll free)
We will respond to verifiable requests received from California residents as required by law. When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number) so that we can process and verify your request. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us via email or phone; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Requests to Opt Out. Our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. (You can also manage your preferences for targeting and other cookies on one of our Websites through the “Cookie Settings” link in the footer of the Website.) More information about GPC is available at: https://globalprivacycontrol.org/. You may also submit a request to opt out of other sharing and sales by submitting a request via:
Our online webform
Phone at (888) 778-6995 (toll free)
Financial Incentives. We may make available certain programs or offerings that are considered “financial incentives” under the CCPA, and we will provide notice of the material terms of such incentives and obtain consent from individuals before including them in such incentive programs. You can opt out of such programs at any time through the opt out mechanism provided in the program information.
Rights Under California Shine the Light Law. California residents may request from businesses with whom they have an established business relationship (1) a list of categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes and (2) the names and addresses of all such third parties. To request the above information please contact us by writing to us under the “Contact Us” section above. We will respond to such requests within 30 days of receipt.
For more information about our privacy practices, contact us as set forth in the Section 16. above.
C. Residents of Other U.S. States
Residents of certain U.S. states (including Virginia) may have additional rights under applicable privacy laws, subject to certain limitations. These rights may include:
Correction: to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.
Deletion: to delete their personal information provided to or obtained by us.
Access: to confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.
Opt-Out: to opt out of certain types of processing, including:
to opt out of the “sale” of their personal information.
to opt out of targeted advertising by us.
to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.
You may submit a request to exercise your privacy rights via:
Our online webform
Phone at (888) 778-6995 (toll free)
You may also opt out of targeted advertising via on one of our Websites, by clicking the “Cookie Settings” link on our website and turning off targeting (advertising) cookies. (See Section 12. Your Rights and Choices, for additional information about the privacy choices we provide and how to exercise them.) We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal our decision by submitting a request through our webform.