Our Privacy Policy

ScaleYourBrokerage.com

(collectively, “We”, “Our” or “Us”)

recognize the importance of protecting the privacy of personal information

collected by us. This Privacy Notice describes how we collect, use, disclose,

retain, and transfer personal information, in connection with the operation of

our businesses, which include, real estate, insurance, relocation, mortgage,

and other related services. It also describes your rights and choices regarding

use, access and correction of your personal information. Personal information

may be requested/collected to enable the delivery of our services, to operate

our business and to make the experience of using our websites faster and more

effective. This Privacy Notice applies to the extend we process personal

information on our own behalf, as a controller, processor or business.

By using our website(s), you consent to the terms of this

Privacy Notice and to Our processing of personal information for the purposes

stated in this Privacy Notice, as well as those explained where We collect

personal information on the web. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE,

YOU CANNOT USE OUR SERVICES.

If you are a California resident, please be sure to

review Section 17.B California Residents for important information

about the categories of personal information we collect and disclose as well as

your rights under California privacy laws.

1. Scope of this Privacy Notice

This Privacy Notice 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 Notice, our other services, products, and technology solutions (collectively, the “Services”). Former, current, and prospective clients, brokers, independent agents, real estate professionals, 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 Notice is intended to describe our overall privacy and data protection

practices.

Not covered by this Privacy Notice:

 This Privacy

Notice does not apply to job applicants and candidates who apply for employment

with us, or 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 Notice, 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 Services, and in some cases,

from third parties (such as a relocating employee’s employer, social networks,

platform providers, payment processers, 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, submit a webform to us, register

for events, or otherwise provide contact information, and share other personal

information with us.

When you complete or submit a form through our Services, for

example, via “Contact Us” or “More Information” forms.

Contact information and profile data: such as your name, address, email and other contact information, as well as any personal data you post or submit, such as demographics, preferences, or that you otherwise submit to us through your account. Payment and purchase information: in some circumstances, we may collect purchase and payment information in order to process payments to or from you, such as your credit card number, direct deposit or financial account number, billing address, and other account information. Communications and interactions: when you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records, communications and information that you post in chat sessions, forums and in other areas of the Services, as well as on our social media channels, and information you provide to us related to any customer support requests. Surveys and promotions: When you participate in surveys, contests or promotions that we offer, we will collect your name, age, email address, and other registration information, as well as your responses to any survey questions or other requests. Events and other requests: if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event, including name, contact information, and professional affiliations, as well as any dietary restrictions or other requested accommodations. When you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests. Other information: in some cases, we may collect personal information, such as driver’s license, SSN, tax IDs, and other government identifiers. For example, where necessary or verify your identity, complete a transaction or comply with a legal obligation. This information is considered sensitive personal information under certain privacy laws. Additionally, we may need to collect special category information, which could include racial/ethnic origin, health data, biometric data or sexual origination in connection with our services. We will obtain your explicit consent to collect any special category data when required by applicable law. We do not sell or share this information or use it for marketing purposes.

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 real estate agents, and other real estate

professionals, and third parties. For example, without limitation, if you

choose to link, create, or log in to your 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

Information from social media and third-party platforms: If you post information about us or engage with us on third party platforms, or choose to link to or log in to our Services with a third-party account, we may collect personal information about you from that third party platform or account. We may also collect other information about you from that third party platform or account. We may also collect other information that you share or make public on your account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy notices. Listing, search and other real estate information: if you interact or list a property with a broker, independent real estate agent, or other real estate professional associated with one of our brands, we may receive personal information about you and your property from them, such as your name and property address, property and listing details, contact information, search criteria and preferences, household members, and co-owners, among other things. These real estate professionals may be affiliated with independently owned and operated brokerages, or with an company. Property records: we may collect information about individuals and real estate property through public databases, such as property ownership, purchase and sale transactions and data (including purchase/sale price) buyer and seller names and contact information, and tax records maintained by state, local and county agencies.

Information we collect automatically or derive about you:

 We

automatically collect personal data related to your use of our Services and

interactions with us and others, including information we collect automatically

(e.g., using cookies and pixel tags), as well as information we derive about

you and your use of the Services. Such information includes:

Device and browsing information: we automatically collect information when you visit a Website or user our Services, such as IP address, general location information, domain name, page vies, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. Activities and usage: we also automatically collect activity information related to your use of the Services, such as information about the links clicked, searches, properties viewed, features used, items viewed, time spent within the Services. Location information: We may collect or derive location information about you such as through your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings. Profiling and characteristics: we may also derive information about you based upon the other information we have collected, such as whether you may be interested in purchasing.

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

describe the purposes for which We will collect, use, disclose and otherwise

process personal information, as well as the legal basis for such processing

under certain 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 a 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, and data protection, tax, and corporate compliance laws. Our or our clients’ legitimate interests: in furtherance of Our or our clients’ legitimate business interests including, for example: Performance of contracts, including for relocation services, with franchisees or others 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 where We need and obtain your consent to collect and process your personal information.

In addition, we may process your personal information where

necessary to protect the vital interests of any individual.

Real Estate Services: In general, we use the personal information we collect in order to respond to your request and provide you with the Services or information about property listings or to be connected with buyer or seller agents to assist you with home searches and real estate transactions, we may collect and disclose information about you and your request in order to facilitate communications among you, independent real estate professionals, our affiliated entities, and other users of the Services. If you express an interest in a listing or request information, we may send you information in response to your request and we may share your information so that a broker or agent can respond to your request.

We may also process the personal information (described

above) that we collect, for the following general business and commercial

purposes:

Providing support and services: including, for example, to send or facilitate communications with you, your employer or membership group, to provide the Services, provide products and services you or your employer 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 or your employer or membership group; and our and our clients’ 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 satisfactions 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 other wise personalize your experiences. (Legal basis: our legitimate interests and/or with your consent). Advertising, marketing and promotional purposes: including to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; and to contact you about our Services or information we think may interest you; to administer surveys, promotions and contests; to share information of new home sales and enable other businesses to contact you about products and services you may be interested in, such as home warranties. (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 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). 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; our general business, accounting, record keeping and legal functions; and 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 interest and/or compliance with laws). Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as 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 that we collect to

third parties, as reasonably necessary for the purposes described above or as

otherwise directed or consented to by you, including:

Service providers: We may disclose personal information 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: We may share your personal information with our affiliated companies (i.e., companies under common ownership, control or management with us), as defined in the beginning of this Privacy Notice, who will process your personal information in accordance with the principles of this Privacy Notice. Where required by applicable law, we will obtain your consent to such sharing. Third Parties: we may share transaction information about property sales (most of which is also recorded in and publicly available through public records) with certain partners and companies with which we work; these third parties and others they work with may contact you about products and services you may be interested in. We may also disclose your personal information to third parties in order to provide our Services, facilitate your requests, and/or with your acknowledgement and consent, including to: independent real estate professionals and owners and operators of real estate brokerage companies, moving services providers, immigration and visa service providers to enable them to provide services you request through the Services. third parties to provide you a service you or your employer requested. the public if you submit information, such as comments, social media posts, or other features viewable by the public. 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 to track the effectiveness of campaigns and our Services. Business transfers: We may disclose or transfer personal information 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, including related to due diligence conducted prior to such event where permitted by law. Legally required: We may disclose personal information if we are required to do so by law or legal process (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order). Protect our rights: We may disclose personal information 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 Websites. For instance, when you visit our

Websites, 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 activities on our

Services.

We use the information for security purposes, to facilitate

navigation, to improve, analyze and optimize our Services and functionality, to

personalize and improve your experience while using the Services, to improve

and measure our advertising campaigns, and to better reach users.

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 sites. 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 on 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 sue 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

collections of your browsing data by Google Analytics 

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 of 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 preference for targeting

cookies and get information about targeting cookies in use on our Websites by

clicking “Cookie Settings” in the footer of the 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:

Canada: 

www.youradchoices.ca

EU: 

www.youronlinechoices.eu

UK: 

www.youronlinechoices.com/uk/

U.S.: 

www.aboutads.info

8. Social features and third-party plug ins

Some of our 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. We do not receive or store passwords

to your third-party social media accounts in this context.

9. International transfers and personal information

Our Websites are hosted on servers located in the United

States or European Union. As such, we and our service providers may transfer

your personal information to, or access it in, jurisdictions, including the

United States and possibly to other jurisdictions (e.g., to your relocation

departure and destination location) where we, our affiliates and service

providers have operations), which may not provide the same level of protection

under your local data protection laws. If you are located, for example, in

European Economic Area or Switzerland (collectively, “EEA”) or United Kingdom

(“UK”), and we process your personal information in a jurisdiction that has

been deemed to not provide an adequate level of data protection (a “third

country”), we will implement suitable personal information transfer safeguards.

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..

11. Data retention

We will retain your personal information for the period

necessary to fulfill the purposes outlined in this Privacy Notice 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 applicable law and 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 Notice..

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.

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

Our Websites are not directed to children under the age of

16 (“Children”), and we do not knowingly ‎collect any information, including

personal information from Children.‎‎

14. Third-party websites

Our Websites 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

Notice 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 third-party’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 third-party 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 Notice

We may amend this Privacy Notice 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 our

Websites or by other means we deem appropriate. Any material changes to this

Privacy Notice will be effective 10 days after our posting of the updated

Privacy Notice 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 Notice.

16.

Contacting

us/correction/updating personal information/exercising your rights

You may contact us through the methods stated below for a

number of purposes, including: (1) if ‎you no longer wish to use the site; (2)

to opt-out of communications or unsubscribe from any ‎industry updates; (3) to

receive ‎information or special offers; (4) to provide feedback and comments on

this Privacy Notice; (5) to ‎request access to your personal information,

deletion of your incorrect personal information or ‎correction of your personal

information; and (6) to make inquiries whether we hold or process on ‎behalf of

a third party, any of your personal information or complaints/objections

regarding our ‎Privacy Notice and/or privacy practices.‎

For U.S. based inquiries:

Email: 

[email protected]

Mailing Address: Attn: Data Privacy, 4 Cote Ave, Suite 3,

Goffstown, NH 03045

We will respond to your request within a reasonable

timeframe, but in no event later than 45 ‎days, or such lesser period

prescribed by applicable law.‎

17.

Additional

information for residents of 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 United States, please rev

iew below

for additional

information about the categories of personal information we collect about you

and your privacy rights under applicable California privacy laws and

below for additional information

about privacy rights under other U.S. state privacy laws.

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.

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, user ID, username, account number; phone number, unique ‎personal identifier, online identifier, IP address, ‎app ID, email address, account name, social security ‎number, social insurance number, driver’s license ‎number, passport number, or other similar identifiers. Customer records: includes personal information that you or your employer or membership group provide us in order to obtain our products and services, such as ‎name, account name and number, signature, contact information, employment information, social security number, social insurance number, passport number, driver’s license and other government identifiers, insurance information and financial ‎information. For example, this may include information collected when an individual registers for our services. 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: includes records of real or personal property, products or ‎services purchased, ‎obtained, or considered, or other purchasing or use ‎histories or tendencies.‎ Usage Data: includes browsing history, ‎clickstream data, search history, and information ‎regarding a resident’s interaction with an internet ‎website, application, or ‎advertisement, including access logs and other usage data related to your use ‎of ‎any company websites, applications or other online services. Location data: location information about a particular individual or ‎device.‎ Audio, video and other electronic data: includes audio, electronic, visual, thermal, ‎olfactory, or similar information ‎such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices), photographs and call ‎recordings (e.g., of customer support calls). Professional Information: includes professional or employment-related information.‎ Education information: includes information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates). 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, or passport number; 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 your general location to data analytics providers internet service providers business customer/client social networks operating systems and platforms Customer records: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries internet service providers may collect your IP address as a function of using our services operating systems and platforms business customer/client Characteristics of protected classifications: service providers advisors and agents government entities and law enforcement affiliates and subsidiaries Commercial information: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries advertising networks your general location to data analytics providers business customer/client social networks operating systems and platforms Usage Data: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries internet service providers may collect your IP address as a function of using our services business customer/client advertising networks data analytics providers social networks operating systems and platforms Location Data: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries operating systems and platforms Audio, video and other electronic data: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries Professional Information: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries business customer/client Education Information: service providers advisors and agents real estate professionals government entities and law enforcement affiliates and subsidiaries business customer/client 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 business customer/client

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 or your employer’s

or membership group’s 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); (ii) identifiers, customer

records and commercial information (related to property sales and transactions)

with partners and third party businesses, who may use or process the

information for their own commercial purposes; and (iii) 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 Our business clients, including your employer Internet service providers Operating systems and platforms

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 Notice 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, delete, correct, and

limit use/disclosure of sensitive personal information by submitting a

verifiable request to us:

By email to

[email protected]

Or mail to 4 Cote Ave, Suite 3, Goffstown, NH 03045

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 any form we provide to you (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 Websites 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: 

globalprivacycontrol.org

. You may also

submit a request to opt out of other sharing and sales by submitting a request

via:

By email to 

[email protected]

Or Mail to: 4 Cote Ave, Suite 3, Goffstown, NH 03045 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.

Cartus does not provide personal information to third parties for direct

‎marketing purposes.

C.

Residents of Other U.S. States

Residents of certain U.S. states 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. Appeal: to appeal our denial of your privacy request, which you can do by submitting a request through our webform.

You may submit a request to exercise your privacy rights

via:

By email to 

[email protected]

Or Mail to: 4 Cote Ave, Suite 3, Goffstown, NH 03045

You may also opt out of targeted advertising via one of our

Websites, by clicking the “Cookie Settings” link on the Website and turning off

targeting (advertising) cookies.

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 any of the methods of contact stated above.

The ScaleYourBrokerage Logo is registered service marks owned by Samoset Media Group, LLC. Samoset Media Group, LLC fully supports the principles of the Fair Housing Act and the Equal Opportunity Act. Each franchise is independently owned and operated. This is not intended, and shall not be deemed to constitute, an offer to sell a franchise. Franchise offerings made only by a Franchise Disclosure Document. This advertisement is not an offering. An offering can only be made by a prospectus filed first with the Department of Law of the State of New York or any other applicable state. Such filing does not constitute approval by the Department of Law.