Brokerage Engine PRIVACY POLICY
Revised: November 2018

The purpose of this Privacy Policy is to describe how Brokerage Engine, Inc., (“Brokerage Engine”) may collect, use, store, disclose and process (“process”) your information, through your access to or use of the Brokerage Engine platform, including the website and associated domains of http://www.brokerageengine.com, related Brokerage Engine mobile applications, any other Brokerage Engine services or websites that link to this Privacy Policy, all of which as may be updated from time-to-time, including any successor websites, domains, and mobile applications (collectively, the “Service”).

Your privacy is important to us. Brokerage Engine encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

  1. General

    1. Consent

      By accessing or using the Service, you consent to the processing of your information in accordance with: (i) this Privacy Policy; (ii) any related terms of service, end user license agreement, or services agreement, including, if you are accessing or using the Service through your affiliation with a real estate brokerage or agency, the enterprise agreement between Brokerage Engine and such brokerage or agency (collectively, “Service Terms”); and (iii) as permitted or required by applicable law.

    2. Interpretation

      For the purposes of this Privacy Policy, the words “such as,” “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation.”

  2. How Brokerage Engine Collects and Uses Information

    1. Information That You Provided Directly

      Brokerage Engine may ask for or you may provide certain information such as your name, physical address, email address, telephone number, password, and other information. Brokerage Engine may retain any such information, as well as messages, media (e.g., photos and video), and other content that you send through the Service or that you otherwise provide to Brokerage Engine. Brokerage Engine processes this information to operate, maintain, improve, and provide the features and functions of the Service, and as further described below.

    2. Information Collected or Received from Third Parties.

      Brokerage Engine may receive information about you from third parties. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Service. Brokerage Engine may also collect information about you from Brokerage Engine’s third-party business associates, publicly-available sources and Brokerage Engine’s affiliates.

    3. Analytics information

      Brokerage Engine may receive information about you from third parties. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Service. Brokerage Engine may also collect information about you from Brokerage Engine’s third-party business associates, publicly-available sources and Brokerage Engine’s affiliates.

      For more information about how such Analytics Tools may use your information and how you may be able to control use of such information, please visit the URL provided for each.
    4. Cookies

      When you access or use the Service, Brokerage Engine may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation within the Service. A cookie may also convey information to Brokerage Engine about how you use the Service (such as the pages you view, the links you click and other actions you take), and allow Brokerage Engine or Brokerage Engine’s third-party business associates to track your usage of the Service. Brokerage Engine uses at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your device after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and is deleted after you close your browser. You can set your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if cookies are disabled.

    5. Log File.

      Log file information is automatically reported by your browser each time you access a web page. When you access or use the Service, Brokerage Engine’s servers may automatically record certain log file information, such as your web request, internet protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links within the Service, domain names, landing pages and pages viewed.

    6. Clear GIFs/Web Beacons.

      Clear GIFs (also known as web beacons) allow for the tracking of a user’s response to an email or usage of a website in a manner that does not reveal personally-identifiable information. Brokerage Engine may use clear GIFs or similar technologies to assess responses to emails and usage of the Service, such as tracking when emails are opened and which links are clicked by recipients. You can disable the ability of clear GIFs to capture information by blocking cookies.

    7. Device Identifiers.

      When you access or use the Service using a mobile device, Brokerage Engine may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (UUID). Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by Brokerage Engine. A device identifier may convey information to Brokerage Engine about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation within the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

    8. Advertising Identifiers.

      Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Advertising identifiers may be modified or disabled by users in the device operating system’s settings.

    9. Location Data

      When you access or use the Service, Brokerage Engine may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (such as latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to Brokerage Engine information about how you browse and use the Service. Some features of the site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

    10. Commercial Communications.

      Brokerage Engine may use the information Brokerage Engine collects or receives to communicate directly with you, such as sending you emails containing newsletters, promotions and special offers. Brokerage Engine may also use the information to send you service-related notices (such as account verification, technical and security notices).

    11. Use of Certain Service-Type Data.

      Brokerage Engine may process the information described in this Section 2 to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (ii) provide custom, personalized content or information; (iii) monitor and improve the effectiveness of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.

    12. Use of Information with Your Consent

      Brokerage Engine may further process your information for any other purpose for which you provide consent.

    13. Account Login

      If you have an account with the Service and log in while you access or use the Service, the information described in this Section 2 may be collected and maintained in a manner that associates such information with your name or contact information.

    14. Combining Information.

      Brokerage Engine may combine any of the information that Brokerage Engine collects from or about you, from one or multiple sources, and process it in the manner described in this Privacy Policy.

  3. How Brokerage Engine May Share Your Information

    1. Business Associates and Service Providers.

      Brokerage Engine may share information about you with third-party business associates and service providers that perform services on Brokerage Engine’s behalf in connection with the Service. Brokerage Engine may also share information about you with any of Brokerage Engine’s affiliates for purposes consistent with this Privacy Policy and the Service Terms.

    2. Business Change.

      If Brokerage Engine becomes involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of Brokerage Engine’s business otherwise changes, Brokerage Engine may share or transfer your information to third parties in connection with such transaction or change in ownership, including as part of the due diligence process conducted by the parties to a potential transaction.

    3. Necessary Disclosure:

      Regardless of the choices you make concerning your information and to the extent permitted or required by applicable law, Brokerage Engine may disclose information about you to third parties to: (i) enforce or apply this Privacy Policy or the Service Terms; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect Brokerage Engine’s rights, reputation, safety or property, or that of Brokerage Engine’s users or others; (iv) protect against legal liability; (v) establish or exercise Brokerage Engine’s rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; violation of the Service Terms; or as otherwise required by law.

    4. Sharing Information.

      Brokerage Engine may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks) with Brokerage Engine’s third-party business associates for the purposes described in Section 2. Brokerage Engine may also aggregate or otherwise remove all personally-identifying characteristics from your information and share that aggregated, de-identified data with third parties.

  4. How Brokerage Engine Protects Your Information

    Brokerage Engine takes physical, technological and organizational measures to protect the information you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. Brokerage Engine encrypts your information and complies with applicable data protection laws, including applicable data breach notification laws, to protect your information. However, Brokerage Engine cannot ensure or warrant the security of any information you transmit to Brokerage Engine or guarantee that information within the Service will not be accessed, disclosed, altered or destroyed. Communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to Brokerage Engine via email.

  5. Your Rights over Your Information

    1. Accessing and Managing Your Personal Data

      You may access and modify your personal data through the settings menu on the Service. To delete, download or restrict use of your personal data, or for any additional assistance or inquiry regarding such data, please contact privacy@brokerageengine.com. To help protect your privacy and maintain security, Brokerage Engine may take steps to verify your identity before granting you access to the personal data. To the extent permitted by applicable law, a charge may apply before Brokerage Engine provides you with a copy of any personal data that it maintains about you.

    2. Controlling Your Settings

      You can manage settings through the settings menu on the Service. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from Brokerage Engine by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails, such as those concerning your relationship or dealings with Brokerage Engine and those necessary to provide the Service.

    3. Targeted Advertising

      You can learn more about targeted ads and your choices to prevent third parties from delivering targeted ads to your browser or device by visiting http://optout.networkadvertising.org/ and http://optout.aboutads.info/. You should be aware that even if you opt out of targeted ads, you may still see ads within the Service, although the ads may not be tailored to your interests.

    4. Do Not Track

      At this time, Brokerage Engine does not recognize “do not track” signals sent from web browsers. Third-party services that Brokerage Engine uses may collect personal information about individual users and their activities over time and across different websites. In some cases, you may be able to disable tracking mechanisms, but doing so may disable certain features of the Service. To disable tracking, please consult the documentation for your browser, operating system or device. For some devices, it may not be possible to disable tracking mechanisms. Section 2 of this Privacy Policy provides more detail on how Brokerage Engine uses cookies and similar technologies.

  6. How Long Brokerage Engine Keeps Your Information

    Brokerage Engine will retain your information as long as necessary for the purposes outlined in this Privacy Policy, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law.

  7. Additional Privacy Information

    1. International

      The Service may be hosted or operated in countries other than the country in which you reside. Those countries may have different data protection laws and regulations from those that apply in your home country. By accessing or using the Service, you authorize Brokerage Engine to process and transfer your information in the United States and in any other country where it operates. Please be aware that the governments, courts, and law enforcement, security or agencies of a particular jurisdiction may be able to obtain access to or disclosure of your information as permitted by the laws of that jurisdiction.

    2. Children's Privacy.

      The Service is not directed to children and is intended for use by adults only. Brokerage Engine does not knowingly collect personal information from individuals under 13 years of age. If you are under the age of 13, you may not use the Service or submit any personal information through the Service.

    3. Third-Party Services and Services.

      The Service may reference or provide links to other websites or resources. If you access any website or resources provided by a third party, this Privacy Policy will not apply. Your interactions with such websites and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

    4. Updates to this Privacy Policy.

      Brokerage Engine may update this Privacy Policy from time to time, and the updated version of this Privacy Policy will be effective upon posting. Please check this page to review the most up-to-date version of this Privacy Policy. By continuing to use the Service after an updated version has been posted, you agree that the new policy will apply to you.