Through the Services—We collect Personal Information through the Services, for example, when you fill out aan availability form when using our Services, register an account to pay rent on line via access through our Services, fill out a rental application, or contact us by telephone or email. •
Use of Personal Information We and our service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.—To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related user support services.—To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions or comments, or when you request other information about our Services.—To send administrative information to you, such as changes to our terms, conditions and policies.— To allow you to send messages to another person through the Services if you choose to do so. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with marketing materials and facilitating social sharing—To send you marketing related emails with information about our services, new products, and other news about our company.—To facilitate social sharing functionality that you choose to use.—We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.—To analyze or predict our users’ preferences in order to prepare aggregated trend reports, so we can improve our Services.—To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.—To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you. We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law. We use this information to manage our contractual relationship with you.
- Aggregating and/or anonymizing Personal Information.— We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
- Accomplishing our business purposes.—For data analysis, for example, to improve the efficiency of our Services;—For audits, to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements;—For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;—For developing new products and services;—For enhancing, improving, or modifying our current products and services;—For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;—For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and— For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interests.
- Disclosure of Personal Information We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.—These can include providers of services such as data analysis, payment processing, user support service, email delivery, auditing, and other services.
- To our rental agents where you have requested such sharing or inquired about a property.
- By using the Services, you may elect to disclose Personal Information.—On message boards, chat, blogs, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
- Other Uses and Disclosures We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law and regulations.—This may include laws outside your country of residence.
- To cooperate with public and government authorities.— To respond to a request or to provide information we believe is important.—These can include authorities outside your country of residence.
- To cooperate with law enforcement.—For example, when we respond to law enforcement requests and orders or provide information we believe is necessary or appropriate.
- For other legal reasons.—To enforce our terms and conditions; and—To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.—We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
OTHER INFORMATION “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information • App usage data • Information collected through cookies, pixel tags and other technologies • Demographic information and other information provided by you that does not reveal your specific identity • Information that has been aggregated in a manner such that it no longer reveals your specific identity
- Collection of Other Information We and our service providers may collect Other Information in a variety of ways, including:
- Through your browser or device—Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Physical Location—We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Security We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the“Contacting Us” section below.
Choices and Access Your choices regarding our use and disclosure of your Personal Information We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving marketing-related emails from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out
- Our sharing of your Personal Information with our affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out.
- Our sharing of your Personal Information with our third-party business partners for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our business partners for their direct marketing purposes, you may opt out. TO OPT OUT– Please contact us at firstname.lastname@example.org for assistance with the above. 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.
- How you can access, change or delete your Personal Information If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may update your information by emailing us at email@example.com. We will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you are a current rental client, you may not be able to change or delete the Personal Information provided until after the completion of lease).
- Retention Period We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
- Use of Services by Minors The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.
- Jurisdiction and Cross-Border Transfer Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/ data-transfers-outside-eu/adequacy-protection-personaldata-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as certification to the EU-U.S. Privacy Shield Framework, to protect your Personal Information (please see our EU-U.S. Privacy Shield Statement at the end of this policy). You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
- Sensitive Information Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
- In the event sensitive personal information, including social security numbers, are disclosed to us, CA White will take all reasonable steps to protect the confidentiality of Social Security numbers, prohibit unlawful disclosure of Social Security numbers, and limit access to Social Security numbers.
- Sources of Personal Information We collect Personal Information from:
- Our interactions with you, such as when you use our websites or applications, contact us online or on the phone, sign up for a newsletter, register an account, purchase a product or service, or attend one of our events; and
- Our affiliates, third-party providers of software applications made available on the KW Marketplace, and publicly available online sources.
- Categories of Personal Information Collected We may collect, and may have collected within the preceding 12 months, the following categories of Personal Information as listed in the CCPA: Category A. Identifiers, such as name, contact information, IP address and other online identifiers; Category B. Personal information, as defined in the California customer records law, such as name, contact information, payment card number, financial information, employment information, insurance information, and government-issued ID numbers; Category C. Characteristics of protected classifications under California or federal law, such as marital status; Category D. Commercial information, such as transaction information and purchase history; Category F. Internet or network activity information, such as browsing history and interactions with our website; Category H Geolocation data, such as device location; Category G. Professional or employment-related information; and Category K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
- Use of Personal Information • We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:—Fulfill your requests, respond to your inquiries, and process your transactions;—Provide, develop, improve, repair, and maintain our products and services;—Provide tools and services to our franchisees and agents;—Personalize, advertise, and market our products and services;— Conduct research, analytics, and data analysis;—Maintain our property and our records, and undertake quality and safety assurance measures;—Conduct risk and security control and monitoring, and detect and prevent fraud;— Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;—Carry out corporate transactions, such as mergers, joint ventures or acquisitions; and—Comply with law, legal process, and internal policies, and exercise and defend legal claims.
- Disclosure of Personal Information We have disclosed the following categories of Personal Information as listed in the CCPA to third parties for our operational business purposes within the preceding 12 months: Category A. Identifiers, such as name, contact information, IP address and other online identifiers; Category B. Personal information, as defined in the California customer records law, such as name, contact information, payment card number, financial information, employment information, Category C. Characteristics of protected classifications under California or federal law, such as marital status; Category D. Commercial information, such as transaction information and purchase history; Category F. Internet or network activity information, such as browsing history and interactions with our website; Category G. Geolocation data, such as device location; Category I Professional or employment-related information; and Category K. Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics. We have disclosed these categories of Personal Information to our affiliated entities, trusted third-party service providers, licensed franchisees, and business partners, as well as to our agents, brokers, and market centers where you have requested such sharing. We have not sold Personal Information, as “sale” is defined in the CCPA.
- Individual Rights and Requests If you are a California resident, you may request that we: • Disclose to you the following information covering the 12 months preceding your request: • Delete Personal Information we collected from you. To make a request for the disclosures or deletion described above, please contact us at DSAR-KW@kw.com or (877) 507-0072 We will respond to your request consistent with applicable law. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
- Changes to this CCPA Notice We may change or update this CCPA Notice from time to time. When we do, we will post the revised CCPA Notice on this page with a new “Last Updated” date.
Contact Us If you have any questions regarding this CCPA Notice, please contact us at firstname.lastname@example.org.