COLDWELL BANKER REALTY PRIVACY NOTICE FOR CALIFORNIA CONSUMERS
In this Privacy Notice for California Consumers (the “Privacy Notice” or “Notice”) we provide information for California residents about our collection and use of personal information related to our real estate brokerage and related services(“Services”). This Notice is intended to satisfy our requirement under California privacy laws, including the California Consumer Privacy Act (“CCPA”), to provide privacy notice to California residents at or before the time when we collect their personal information. This Privacy Notice supplements the information contained in our Privacy Policy, located at coldwellbankerhomes.com/privacy. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person. It does not include personal information that is exempt under the CCPA, such as publicly available data as defined by the CCPA, de-identified or aggregated consumer information, or information subject to the Gramm-Leach Bliley Act or the California Financial Information Privacy Act. Categories of Personal Information Collected: Our real estate business collects and receives personal information primarily for the purpose of helping you complete your real estate transaction. We may collect personal information directly from you, automatically related to your use of our Services, as well as from third parties, such as business partners, title or escrow companies, lenders or mortgage brokers, and other third parties. Below please find the categories of personal information—as defined by the CCPA—about California residents that we collect, sell, and/or disclose:*In certain real estate transactions, a title company may be required to collect certain identifying information, such as social security numbers, driver’s license numbers and/or passport numbers, per US Treasury department anti-money laundering rules where the buyer is an entity and purchasing without a bank loan. Our agents may assist in this process. Purposes for Our Collection, Use and Disclosure of Personal Information We collect and use your personal information primarily to facilitate your real estate transaction and provide our Services to you. In doing so, we may also share certain information with third parties, such as multiple listing service companies, title or Category Description Identifiers Such as real name, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, SSN, driver’s license number, passport number, or other similar identifiers.*Customer records (subject to Cal. Civ. Code § 1798.80(e)). Paper and electronic customer records containing personal information, such as name, signature, SSN, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number (e.g., for home/title insurance), education, and employment, as well as sales information such as listing price and purchase price, or other financial information relating to the financing of a real estate transaction (as examples, information provided to an agent by a lender or mortgage broker; information related to the verification of a down payment typically required by a real estate purchase agreement; or information provided to an agent when a “net sheet” is created).*Protected classifications under California or federal law Citizenship or marital status, family status, medical condition, veteran or military status, or mental capacity (as sometimes issues of capacity arise in a real estate transaction).* Commercial information Such as records of real property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies, such as sales information, purchase price, listing price or contract terms other similar information that is received to facilitate a real property purchase transaction. Internet or other similar network activity Such as internet or other electronic network activity Information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. Geolocation information Precise location information about a particular individual or device. Audio, video, and other electronic data Such as, CCTV footage, photographs, and call recordings, and other audio or visual data. Employment information Current or recent professional or employment-related information.*Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, or attitudes, including lists of potential buyers or sellers (“lead lists”).
2January 2020(2) escrow companies, lenders or mortgage brokers, and other business partners and third parties. While our use and disclosure of personal information may vary depending upon the circumstances, in general we may collect, use and disclose personal information for the purposes described below. Purpose Description Facilitating real estate transactions In order to facilitate the purchase, sale or marketing of your property or to otherwise facilitate the completion of your real estate transaction. Providing support and services To communicate with clients and prospective clients relating to our Services; to respond to inquiries; and for other customer service and support purposes. Analyzing and improving our business To evaluate and improve our services and business operation; to conduct surveys, and other evaluations, such as customer satisfaction surveys; to prepare benchmarking reports and analyze market trends and comparable sales; and for other research and analytical purposes. Advertising, marketing and promotional purposes To better target our ad and marketing campaigns; to evaluate, measure, and improve the effectiveness of our 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. Securing and protecting our business 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 the rights or safety of any person or third party, or other unauthorized activities or misconduct. 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. 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. Complying with legal obligations Including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests. More Information Our Privacy Policy: For more information about our information practices, as well as your rights and choices regarding your personal information, please review our Privacy Policy: www.coldwellbankerhomes.com/privacyOpt-out: To submit a request to opt out of our sale of your personal information to third parties, such as real estate professionals and other business partners, go to: dataprivacy@realogy.com. Further, to opt out of the collection of personal information by third party advertising cookies on our Websites, go to www.privacyrights.info.Contact Us: If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact dataprivacy@realogy.com.
