PRIVACY POLICY OF INTERO REAL ESTATE SERVICES UPDATED JANUARY 1, 2020‌

We Are Committed to Safeguarding Customer Information

‌We understand that you may be concerned about what we will do with the information, particularly any personal or financial information, you provided to us. We agree that you have a right to know how we will utilize personal information you provide to us. In order to better serve your needs now and in the future, you have provided or made available to you this privacy policy and our privacy policy on https://www.intero.com/privacy (collectively “Privacy Policy”) to provide you certain information and explain your rights.

Applicability

‌Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws, below is a summary of the personal information we collect as a real estate brokerage, the reason we use your personal information, where we obtain and store your personal information, and your rights that can be asserted under the CCPA. This Privacy Policy does not cover the collection of information by those other companies and consumer applications. Although we encourage third parties to provide their own privacy policies, we are not responsible for their activities, such as how they handle the information they collect online.

‌Categories of Personal Information That We Collect

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. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described and for the purposes also detailed below.

Personal information does not include:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA’s scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

     

    We obtain the categories of personal information listed above from the following categories of sources:

• Information from you that you actively provide: We collect this information from sources including from online forms, e-mail, and via telephone.

• Information from you that you provide passively from your use of your sites and services: We collect this information from sources including from a web browser, e-mail, app, or smartphone.

• Third Parties (information we collect about you from third party sources): We collect this from sources including marketing partners, lead generators, and website and app vendors.

  ‌Use of Information

  The information you provide us is for our own legitimate business purposes and not for the benefit of any affiliated or nonaffiliated party. Therefore, we will not release, share, use or sell your information to affiliated and nonaffiliated parties except:

  • To fulfill or meet the services for which the information is provided.

  • To provide you with information, products or services that you request from us.

  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

  • To improve our website and present its contents to you.

  • For testing, research, analysis and product development.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

   

  Sharing Personal Information

  We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

  In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  Category A: Identifiers.

  Category B: California Customer Records personal information categories. Category C: Protected classification characteristics under California or federal law. Category D: Commercial Information

  Category I: Professional or employment-related information.

  We disclose your personal information for a business purpose to the following categories of third parties:

   

• Our affiliates.

• Service providers.

• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

   

  Categories of Personal Information Sold

  The CCPA defines a “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation from such third parties, we do disclose or make available the categories of personal information that we collect to our affiliate and subsidiary companies. We also may make certain categories of personal information available to third parties, in order to receive certain services or benefits from them (such as when we allow third party tags to collect browsing history and other information on our Services to improve and measure our ad campaigns), including:

   

• Category A. Identifiers. Name, contact information and other identifiers

• Category B. Personal information categories listed in the California Customer Records statute.

  Customer Records, Profiles and inferences

• Category C. Protected classification characteristics under California or federal law. Customer Records, Profiles and inferences.

• Category D. Commercial Information. Usage data, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

   

  Rights of California Residents

  California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below.

• Do-Not-Sell: California residents have the right to opt-out of our sale of their personal information Opt-out rights can be exercised by clicking on the “Do Not Sell My Information” under the “Submitting Requests” section below or the homepage of our website. We do not sell personal information about residents who we know are younger than 16 years old without opt-in consent.

• Initial Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

• Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.

• Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:

  • categories of personal information collected;

  • categories of sources of personal information;

  • business and/or commercial purposes for collecting and selling their personal information;

  • categories of third parties/with whom we have disclosed or shared their personal information;

  • categories of personal information that we have disclosed or shared with a third party for a business purpose;

  • categories of personal information collected; and

  • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

     

    California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law.

     

• Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

• Financial incentives: A business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, where the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent. We do not offer any such incentives at this time.

   

  Submitting Requests

  Do-Not-Sell (Opt-out) Requests, Requests to Know, and Requests to Delete may be submitted:

• Do-Not-Sell: By clicking on the “Do Not Sell My Information” at the homepage of our website

• Requests to Know, Requests to Delete: Submitting a request to us at privacy@intero.com

• All requests: By contacting us at (866) 420-5700 (toll free)

We will respond to verifiable requests received from California residents as required by law. For more information about our privacy practices, contact us as set forth above.

You may only make a verifiable consumer request to know information twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Once we receive your verifiable consumer request, we will send you an acknowledgement letter within 10 days which will describe our verification process. We will respond to your request within 45 days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note we are unable to disclose or provide you with your Social Security Number, Driver’s License Number, or other government issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

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 “Submitting Requests” section above. We will respond to such requests within 30 days of receipt.

‌Changes to Our Privacy Notice. Intero Real Estate Services, Inc. reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website or Services following the posting of changes constitutes your acceptance of such changes.

Confidentiality and Security

We will use our best efforts to ensure that no unauthorized parties have access to any of your information. We restrict access to personal information about you to those individuals and entities that need to know that information to provide products or services to you. We will use our best efforts to train and oversee our employees and agents to ensure that your information will be handled responsibly and in accordance with this Privacy Policy. We currently maintain physical, electronic, and procedural safeguards that comply with federal and California regulations to guard your personal information.

‌Agent Acknowledgement

I,                                                                          (agent signature), delivered a copy of the

Privacy Policy of Intero Real Estate Services, Inc. to my client(s),

on                                              ,                      , 20      .

Signature:                                                              Date:                        

Signature:                                                              Date: