Commissions Inc. (the “Company,” “us,” “we” and “our”) is committed to protecting your privacy. This Privacy Notice defines the Personal Information and Usage Information that we collect and describes how that information is collected, used, and shared. This Privacy Notice also describes your choices regarding our use of that information, the steps we take to protect your personal information and how you can review and correct your personal information.
This Privacy Notice is in effect for any web page, mobile application, email list, and information, including Personal Information, collected and/or owned by us, regardless of the method of collection (e.g., mail, facsimile, email, sign-up/sign-in page), including collection through any online features, services, and/or programs we offer (collectively, the “Web Properties”). This Privacy Notice is not applicable to any web page, mobile application, social media site, or information, collected and/or owned by any entity other than the Company.
Types of Information Collected
The Company, and any third party we engage for the purpose of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Web Properties, may collect two types of information when you visit the Web Properties: Personal Information and Usage Information. Generally, you can visit the Company's websites without entering any Personal Information. In certain cases, we may ask you for personal information to provide a service or carry out a transaction that you have requested.
Personal Information: The types of information we collect may include, among other things, the following categories of information (collectively, “Personal Information”):
- contact information (e.g., name, title, company/organization name, email address, telephone and facsimile numbers, and physical address);
- demographic information, such as date of birth, nationality and country of residence, which allows us to determine your eligibility under certain regulations to receive certain information;
- information about your company and job function;
- your email marketing preferences;
- inquiries about and orders for our products and services;
- event registration information;
- feedback from you about the Web Properties and our products and services generally;
- financial information, such as bank account and credit/debit card numbers;
- other information specific to you.
You are not required to provide any of this information, but if you choose not to provide certain information, we may not be able to provide the requested service or complete your transaction.
Usage Information: The types of usage information we collect may contain generic information about your visit to the Web Properties, such as the following categories of information (collectively, “Usage Information”):
- Internet Protocol (or IP) address, protocol and sequence information;
- browser language and type;
- domain name system requests;
- operating system and platform, device type and device identifiers;
- hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data; and
- MAC address, device ID / UDID, or similar device - specific code.
We do not link the above information to your identity or a user account for use in connection with the Web Properties (your “User Account”), unless you enter the site with a User Account or are logged into your User Account at the time you visit the site.
On sites that you enter with a User Account, we may connect your browsing history (including time spent at the Web Properties, time and date of your visit, links you click), number of bytes transferred, the material and pages you accessed, the number of clicks, and other actions taken at a Web Property (all of which are also Usage Information) with your identity to determine your potential interests in our products and services.
How Information Is Collected
Personal Information: We may collect Personal Information and Usage Information about you from the following sources:
- information we receive from you as a result of your use of our services;
- information we receive from you, or on your behalf, through forms you complete, or through your communication to us (for example, an inquiry about a property, to sign up for our mailing list, or to receive our mailings, newsletter or updates);
- information we receive from you through the Web Properties, such as when creating a User Account;
- information we receive from your computer or mobile device;
- information we receive from our partners or service providers;
- information we receive from other sources, as permitted by applicable laws, rules and regulations; and
- information we receive from you, even if we have not requested such information and the information is not information that we normally collect.
Usage Information: We may collect Usage Information from you as follows:
Cookies: From time to time, we may use “cookies” to keep track of your visit and use of the Web Properties. Cookies are small files that websites save to your hard disk or to your browser's memory. We may use them to track the number of times you have visited the site, to track the number of visitors to the site, to determine and analyze visitors' use of our sites (including the effectiveness of online advertising), to store information that you provide such as your preferences, and to store technical information useful for your interactions with our websites. We may use session cookies (cookies that are deleted when your browser session ends) to store your User Account, elements of your user profile, to facilitate your movement around our websites (particularly in connection with information searches and order placement) and other information useful in administering the session. You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not fully be able to experience the features of the Web Properties.
Web Analytics: The Company uses industry standard web analytics to track web visits.
Web Beacons: Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as ‘clear gifs’). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may include web beacons in promotional email messages or Newsletters in order to determine whether messages have been opened and acted upon.
Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Web Properties and some of the electronic communications you receive from us. We keep this information for our internal use, and this information is not shared with others.
Use of Collected Information
Information collected by us may be used for the following main purposes:
Web Properties Operation and Improvement: We may use your information to (a) improve Web Properties and related products or services, or to make the Web Properties easier to use (for example, by eliminating the need for you to repeatedly enter the same information), (b) setting up and managing your User Account, including processing your requests for information; (c) providing support, products or services to you, and/or (d) customizing the Web Properties to your particular preference or interests.
Services and Transactions: We and our third party service providers may use your personal information to deliver services or carry out transactions you have requested or in which you may be interested.
Communications: With your permission, we may use your personal information gathered via the Web Properties to inform you of products or services available from the Company. We and/or any of our third party service providers may send you information about existing and new services, products, and special offers, by email, telephone, mail or by means of any other contact details you provide to us or our affiliates, or to such third party service providers. In order to offer you a more consistent experience in your interactions with us, information collected by our Web Properties may be combined with information we collect by other means. Each advertising email communication we send includes an unsubscribe link allowing you to stop delivery of that type of communication. If you elect to unsubscribe, we will remove you from the relevant list within 10 business days.
Employment Applications: In connection with a job application or inquiry, you may provide us with information about yourself, such as a resume or curriculum vitae. We may use this information throughout the Company and its controlled subsidiaries and affiliates for the purpose of employment consideration. We will keep the information for future consideration unless you direct us not to do so.
This Privacy Notice is not intended to place any limits on what we can do with information that is aggregated or de-identified so it is no longer associated with an identifiable user of the Web Properties.
Disclosure of Your Information
Except as described below, the information you provide to the Company through the Web Properties will not be shared outside of the Company affiliates without your permission.
Disclosure to Service Providers and Customers. We may provide Personal Information and Usage Information to our subsidiaries, affiliated companies, and other businesses or persons for the purposes of processing such information on our behalf and promoting the products and services of our trusted business partners. For example, we may transfer Personal Information and other information about you to a local real estate broker or participating lender where you have shown an interest in residential properties. We require that these parties agree to process such information in compliance with our Privacy Notice or in a similar, industry-standard manner. These parties may store some or all of your information on servers outside of the United States. The use of your information by one of our trusted business partners may be subject to that party’s own privacy notice.
Transfers of Information: We reserve the right to transfer your Personal Information, as well as any information about or from you, in connection with the merger, sale or other disposition of all or part of our business and/or assets. We cannot make any representations regarding the use or transfer of your Personal Information or other information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. You expressly agree and consent to the use and/or transfer of your Personal Information or other information in connection with a sale or transfer of some or all of our assets in any of the above-described proceedings. Furthermore, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us.
We may also disclose your Personal Information with your permission or as directed by you.
We are committed to protecting the security of your personal information. We use technical, administrative and physical security measures designed to protect your personal information from unauthorized access, use, or disclosure.
You are ultimately responsible for ensuring the security of your username, password and User Account information from unauthorized access, use or disclosure to others. When using the Web Properties, you are not permitted to circumvent the Web Properties’ security features.
You agree to: (a) immediately notify us of any unauthorized use of your username, password and/or User Account, and/or any other breach of security; and (b) ensure that you log out from your User Account at the end of each session. While we use technologies and procedures designed to protect your confidential information and provide suitable security, please be aware that no security measures are perfect or impenetrable. We do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.
Reviewing and Correcting Your Personal Information
You can make a request to review and correct your Personal Information collected via the Web Properties by completing our Contact Us form or, if you have a User Account, by accessing your User Account. We may take steps to verify your identity before providing you access to your Personal Information. You can help us to maintain the accuracy of your information by notifying us of any change to your mailing address, phone number, or email address.
The Web Properties are not intended for or designed to attract children under the age of eighteen (18). By using the Web Properties, you affirm that you are more than eighteen (18) years of age, or an emancipated minor, or possess parental or legal guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Notice, and to abide by and comply with this Privacy Notice.
Links to Other Sites
The Web Properties may now or in the future contain links to other sites such as Commissions Inc. affiliates, professional organizations, and third party businesses that advertise on the Web Properties. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites. Other than under agreements with certain reputable organizations and companies (such as certain third party advertisers on the Web Properties), and except for third party service providers (as described in this Privacy Notice), we do not share any of the Personal Information that you provide to us with any of the websites to which the Web Properties links, although we may share aggregate, non-personally identifiable information with those other third parties. Please check with those websites in order to determine their privacy policies and your rights under them.
European Union Users
If you are visiting us from the European Union, please note that we may collect, transfer, and continue to use your Personal Information outside the European Union for any of the purposes described in this Privacy Notice. By using the Web Properties and providing us with your Personal Information, you consent to our collection, transfer, and continued use of your Personal Information in accordance with this Privacy Notice.
Choices with Your Personal Information
Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide Personal Information. However, in the event this information is essential for us to provide certain services to you, we will be unable to provide you with those services if you choose to withhold requested information.
You may choose to prevent us from disclosing or using your Personal Information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Notice, or by following the procedures set forth in an electronic communication from us, if applicable. We will undertake reasonable efforts to notify third parties with whom we have shared your Personal Information as permitted under this Privacy Notice of your election to opt out. There are some uses from which you cannot opt out, such as to provide products or services that you have requested from us.
"Do Not Track" Signals
Note that your browser settings may allow you to transmit automatically a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Company currently does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.
Your Consent to This Privacy Notice
By using the Web Properties, you consent to the collection and use of your information (including Personal Information) by us in compliance with this Privacy Notice, unless you inform us otherwise by means of the procedure identified below. If we change this Privacy Notice or some part of it, we will post the updated Privacy Notice on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Web Properties following our publication of any revision to this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.
Effective as of: March 20, 2018
Last updated: March 20, 2018