Privacy Policy

PRIVACY POLICY

LAST UPDATED APRIL 16, 2018

OUR COMMITMENT TO YOUR PRIVACY

We understand you value your privacy, and we do as well. This Privacy Policy governs information you provide to us or that we learn from your use of our website (the “Website”) and our services, and tells you how we may collect, use, and in some instances, share this information. We must request certain information to be able to provide services to you, but we will actively work to protect this information.

OUR POLICY

Please take a moment to review this Privacy Policy, which represents an agreement between Realty Holdings USA LLC and its affiliates (collectively referred to as “Realty Holdings”, “we”, “us” and “our”), and you, the end user (referred to herein as “you,” “your” or the “user”). By using, visiting or accessing the Website, you signify your acceptance of, and agree to be bound by, this Privacy Policy and our Terms of Use, which explains the conditions under which you may access and use the Website and which is incorporated herein by reference (this Privacy Policy and the Terms of Use are sometimes referred to collectively as the “Policies”). By choosing to provide us with Personal Information (as defined below), you are providing us permission so that we may use and store any such Personal Information consistent with the Policies. If you do not agree to be bound by the Policies, please immediately discontinue your use of the Website.

INFORMATION WE COLLECT AND HOW WE USE THE INFORMATION

We may ask you to provide us with Personal Information if you would like to benefit from services offered on the Website.

Personal Information: “Personal Information” is any information that can be used to identify a specific individual. We collect and store any Personal Information you choose to enter into the Website or choose to provide to us in some other manner. Such Personal Information may include, without limitation, your name, email address, home address, gender, and phone number. We may also obtain, as permitted, your Personal Information from third parties. Personal Information is required to conduct business between you and us, for us to communicate with you, so that we may verify your identity in accordance with legal and regulatory requirements, and to prevent fraud. If we coordinate information we obtain from third parties with Personal Information that you choose to and do directly provide to us by transacting business with us, all such related information will be deemed to be Personal Information and shall be treated as such according to this Privacy Policy.

Aggregate and Anonymous Data: Aggregate and anonymous data is information collected automatically through the operation of the Website, as well as certain Personal Information which we aggregate and use in a manner that does not identify you personally (“AA Data”). We may collect usage data (such as which pages of the Website you visit and in what sequence) through the use of various technologies. For example, we collect IP address, browser type, language preference, URL traffic, computer types and the operating systems used and visitor behavior statistics from individuals who access the Website. Unless you register to join the Website to access additional information, we do not link IP addresses to any Personal Information, so although your session will be logged, if you do not register to gain additional information through the Website, you will remain anonymous to us. We may also collect password information from you when you log in, as well as computer and connection information such as browser type or version. During some visits, we may use software tools, such as JavaScript and/or Google Analytics, to measure and collect session information, including page response times, download errors, time spent on certain pages, page interaction information, and methods used to browse away from the Website, and any such AA Data may be shared with third parties for any lawful purpose. We or our agents or service providers may store such information in databases, which may be used for a variety of legitimate business purposes, such as administration, performing assessments of usage of the Website, to further develop and improve the experiences of those who visit the Website, and to keep track of visitors use and interaction with the Website.

USE OF COOKIED AND SIMILAR TECHNOLOGIES

Cookies are little bits of information that may be assigned to your computer when you choose to visit any website and cookies can sometimes store and track information about how you use the Website. Like many businesses, we use “cookies” or other similar technologies to collect AA Data. Cookies allow us to measure traffic activity throughout the Website and to improve your user experience. For example, cookies enable us to remember your password and service preferences. Most browsers are initially set to accept cookies. If you prefer, you can set your web browser to refuse cookies or to alert you when cookies are being sent, but it is possible that some parts of the Website will not function properly if you do so.

In addition, we may use a service that collects data remotely by using so-called “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) embedded in website content. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to site visitors and may be associated with cookies on the visitors’ hard drives. This information is AA Data.

Some cookies may be served by third parties who may be delivering services for us. The use of such cookies by any third parties, including our service providers, shall not be covered by the Policies. We have no access to and are not able to control such third-party cookies.

OUR USE OF THE INFORMATION WE COLLECT FROM YOU

We process Personal Information as described above and also for such purposes as: (a) to identify and perform services for users, (b) to conduct research and analysis in order to maintain and improve our services, (c) to alert you to updates, special offers and updated information (you may opt-out of these communications if you so choose), (d) to contact you in response to requests for information such as through “Contact Us”, and (e) to notify our affiliates of your interest in using their services by using the Website to facilitate the introduction. We will use your Personal Information to enable you to use the features of the Website. We may also use your Personal Information to provide you with information about features, services and other offerings that may be of interest to you, and to verify your eligibility in connection therewith. We may use Personal Information to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

In addition, if you choose to and do provide Personal Information in order to enter the Website to access information not generally available to the public, we may use your Personal Information to provide you with access to additional information and to analyze and be aware of your use of the Website.

If you object to our collecting and storing any Personal Information discussed above (and any other information we may collect) you should not visit or use the Website.

EMAIL COMMUNICATIONS

For communications by email between you and us: (a) we will email you regarding and to provide our services you’ve requested by registering at the Website while trying to not email you excessively; (ii) you may choose to opt out of certain types of email notifications; (iii) we may email to you notices about our services from time to time when appropriate and necessary; (iv) if you call or email us, we may email, text or call you and keep records of all correspondence and communications; and (iv) we may contact you occasionally by email, text or phone to make you aware of special offers or to share other information. You are required to keep a valid current email address with us, and to let us know of any changes to your email address or telephone number.

THIRD PARTIES

Except as stated in this Privacy Policy, we do not disclose your Personal Information to third parties without first informing you and giving you the opportunity to opt out of having your Personal Information shared. We may disclose your Personal Information to third parties without informing you in connection with the following:

  • Protecting our legal rights, privacy or safety and that of our affiliates and their respective members, officers, directors, employees and agents; protecting the safety and security of other users of the Website; protecting against fraud or other illegal activity, performing property ownership confirmation or for risk management purposes; responding to inquiries or requests from governmental authorities and agencies and law enforcement officials pursuant to, and complying with, laws, securities regulations, subpoenas or court orders; permitting us to pursue available remedies or limit the damages that we may sustain; or enforcing our Policies.

  • Like many businesses, to help us improve the services we provide, we may hire other companies to perform certain business-related functions or services on our behalf such as hosting specific portions of the Website, account processing, maintaining databases, providing communications and other forms of client services, mailing information or processing payments to you. When we employ a third party to perform these functions, that third party will be provided with the particular Personal Information it needs to perform its function. We require such third-party service providers to keep the Personal Information confidential and to only use it to provide us with the services we request of them and for no other purpose.

  • If you indicate an interest in selling your home and/or buying your next home using one of our Cooperating Brokers that you select, we will provide your Personal Information to our affiliate in whom you have indicated an interest to be introduced.

  • If we sell all or part of our business, or make a sale or transfer of assets or are otherwise involved in a merger or business transfer, we may, in our sole discretion, transfer, sell or assign your Personal Information to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity will govern the further use of your Personal Information.

OUR COMMITMENT TO DATA SECURITY AND PROTECTING YOUR PERSONAL INFORMATION

The safety and protection of your Personal Information is an important function for us and we take reasonable security precautions, using industry standards and best practices, to secure the Personal Information that you choose to provide against the loss, misuse, alteration or unauthorized access of such information, by using encryption and authentication tools to preserve the confidentiality of your Personal Information, including but not limited to using secure sockets layer (SSL) technology, and by limiting as much as possible who may access, or for what reasons may anyone access, your Personal Information. Unfortunately, no transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties, not under our control, to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please notify us of the problem by contacting us at Contact@HomeProgram.com. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take suitable protective steps. We may post a notice on the Website or otherwise contact you electronically if a security breach occurs so that you may take protective steps. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at the above email address. We may also send you, without your prior request, notice of a security breach if we are required to do so under applicable law. Notwithstanding such efforts, please be aware that we cannot guarantee or promise the privacy and security of your Personal Information and we make no representation or warranty concerning the security of your account or Personal Information.

CORRECT INFORMATION

You alone are responsible to assist us in maintaining correct and complete Personal Information for you. Please be sure to review your Personal Information on a regular basis to be sure it is always correct, up to date and complete. Please contact us at Contact@HomeProgram.com at any time you may determine that any of the Personal Information is incorrect, not up to date or is incomplete.

If you ask that we stop using your Personal Information, we will take reasonable steps to honor that request on a prospective basis. However, as a result, you may not be able to continue to utilize some or all of the features of the Website.

If you have registered to enter the Website or use the services available through the Website, you have the ability to review, change or update portions of your Personal Information and preferences at any time by accessing your personal information, or contacting us at: Contact@HomeProgram.com. If you choose to cancel your registration to use the Website or the services available through the Website, we may retain records of your Personal Information for analytical purposes, record-keeping integrity, to prevent fraud, enforce our Terms of Use, or as needed in order to comply with applicable federal, state, or local law. In addition, if certain Personal Information has already been provided to third parties as described in this Privacy Policy, retention of such information will be subject to the respective third parties’ privacy policies. At any time, you may choose to not share any or all of your Personal Information or you may ask us to remove your Personal Information from our database, however under such circumstances we may no longer be able to provide you with some of the services and functions found on or through the Website.

We will maintain your Personal Information while your registration with us remains active and for as long as is necessary to perform any services for you or to perform analytical, record keeping, anti-fraud or other tasks as described in the Policies. You may update or delete the Personal Information you provide to us by logging in using your user name and password and updating your information. However, we may maintain some information as may be required by law or for reasonable business purposes as we may determine.

SUBMITTING CONTENT TO HOMEPROGAM.COM

We may allow you to post information for public viewing on portions of the Website. The formal and legal guidelines concerning all such postings are set forth in, and governed by, our Terms of Use and applicable laws. In addition, such postings may appear on other websites when searches are executed on the subject of your posting. It is important to understand that, whenever you voluntarily disclose your Personal Information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. Except with respect to certain non-public portions of the Website, we cannot control who views your public posting or what other users may do with publicly viewable Personal Information (as described above) and any other information you voluntarily post. As such, we encourage you to exercise discretion and caution with respect to your Personal Information. Once you have posted information on publicly-viewable web pages, you or we might not be able to edit or delete such information.

AFFILIATED AND OTHER WEBSITES

This Privacy Policy applies to the Website which is owned and operated by Realty Holdings USA LLC. We do not exercise control over the Websites of third parties that you may link to or view as part of a frame on a page on the Website. These other sites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. We are not responsible for the actions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.

CHANGES AND UPDATES

We may occasionally update, modify, replace, change or amend this Privacy Policy, effective immediately, by simply posting such update, modification, change or amendment and without any additional notice to you. When we do, we will also revise the “effective date” on the Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the Personal Information we collect. Your continued use of the Website constitutes your agreement to this Privacy Statement and any updates.

USERS OUTSIDE OF THE UNITED STATES

The Website may be accessed and/or used from outside the United States. Should you choose to access the Website from the European Union, the United Kingdom or from other locations outside of the United States with local laws governing the collection and use of data, you are electing to transfer your Personal Information to us within the United States from a location outside the United States; by providing us with your Personal Information on or through the Website or through any other means from outside the United States, you consent to such transfer of your Personal Information.

CHILDREN AND PRIVACY

The Website is not open to persons under 18 years of age. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age. By using, accessing or viewing the Website, you affirm that you are at least 18 years of age. If you are under the age of 18 (or the applicable age of majority in your state or country of residence, if greater), please do not submit any Personal Information to us and please immediately cease using the Website and delete all copies of any information you obtained from or through the Website. If you become aware of anyone under the age of 18 (or the applicable age of majority in his or her state or country of residence, if greater) having registered to enter the Website, please contact us and we will do our best to delete any such information from our data records.

OTHER APPLICABLE TERMS AND CONDITIONS

Your right to access and use the Website is also subject to the Terms of Use.

CONTACTING US

If you have any questions, comments, or concerns about this Privacy Policy, please email us at Contact@HomeProgram.com. We are committed to cooperating to achieve a proper resolution of your privacy concerns.

– 5 –