Effective Date: September, 2020
This Privacy Notice applies to Personal Information processed by LGBTQ+ Real Estate Alliance (hereinafter “Alliance”, “us”, “our”, “we”) in the course of our business, including information needed to process transactions, fulfill requests and maintain membership records; all operating on the applicable websites RealEstateAlliance.org (“Site(s)” and the services provided through the Sites (collectively with the Sites, the “Services“).
Fair Housing Act Compliance: NOTE: TO THE EXTENT IT IS APPLICABLE, Alliance complies with the Fair Housing Act as identified in Sec. 800, 42 U.S.C. 3601. Information, references or characteristics of an individual, identified for any reason, are done in compliance with the Fair Housing Act and as a necessary requirement for any organization operated by, and serving, minority populations.
Personal Information Collection and Use
This Privacy Notice covers our use of Personal Information. “Personal Information,” means any information that relates to you and can, either on its own or in combination with other information, identify you as an individual. Personal information does not include information that has been de-identified or aggregated such that you can no longer be identified.
The types of information we collect depends on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services.
All Users of the Alliance Sites
From registered and unregistered users of the Sites, we automatically receive and record information whenever you interact with the Sites. This includes IP address data from our server logs, cookie information, browser information, information about your activity while on the Sites (such as the pages you request, properties that you view or save, and property that you claim), and the URL of the site you came to the Sites from. We also may collect the mobile device ID (such as the ID for Advertising on iOS and Android ID on Android) from users of the Alliance Applications. If permitted by the settings on your device and/or with your consent, we will also collect your geo-location information. We may also approximate your location based off your IP address, to customize your experience on our Sites.
We may also use the information listed above to help diagnose problems and performance with the Services, analyze trends, customize your experience, and administer the Services. We may provide IP addresses to third-parties to help us analyze website user survey data. We may also use the information described in this section to better target information about Alliance’s Sites and Services, for example, by displaying more accurate or relevant information on our Sites, matching you to a public record listing of a property, tailoring the advertising we display on third party websites and platforms, and sending better targeted and tailored messages, including via email and/or push notifications.
Registered Users of the Alliance Sites
Communicating and Marketing
Alliance may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request technical support, register an account, create a profile, connect via third party authentication or otherwise communicate with us.
We may send marketing materials to Alliance account holders, users and clients using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. In addition, Alliance may record any telephone calls between you and Alliance for training and quality assurance purposes.
Alliance may offer interactive features such as forwarding content to third parties, chat services, forums, member profiles, groups, adding friends, private messaging members, member review and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered “public” and will not be subject to the privacy protections referenced herein.
Aggregated and De-Identified Information
We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purpose.
Information Collected Automatically
We may collect certain information automatically when you use the Sites. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
Cookie and Pixel Tags/Web Beacons
Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Sites that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.
Information You Provide
Throughout use of the Sites, you will be asked to provide certain information, some information is required to be provided by you for use of the Sites, other information is not required for use of the Sites. Any information you provide Alliance, required or not required, shall be deemed public information; this includes, but is not limited to sexual orientation and gender identity. The existence of any privacy settings within the Sites does not alter this general provision. You should not use the Sites if you do not want any information you provide to be generally available to the public.
Information from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance the functionality of the Sites.
Additional Uses of Information
In addition to the specific collection and uses listed above, we may use any of the Personal Information we collect for the following business purposes:
- to manage your Personal Information and accounts;
- to respond to your questions or inquiries;
- to conduct promotional activities, including contests or surveys;
- to undertake internal research for technological development and demonstration;
- to improve, upgrade or enhance our Sites and services;
- to send you informational or promotional communications;
- to detect bugs, security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
- to identify and repair errors that impair existing intended functionality;
- to undertake activities to verify or maintain the quality or safety of a service, Site or transaction;
- to make statistical reports, including demographic reports;
- to carry out other purposes that are disclosed to you and/or to which you consent; and
- to pursue our legitimate interests where your rights and freedoms do not outweigh these interests.
- Personal Information Sharing
We may exchange your Personal Information with others for monetary or other valuable consideration additionally, we may share your Personal Information with the following categories of third parties as part of our Services to you or to assist us in conducting our marketing and advertising, or for other business or commercial purposes listed above in this Privacy Notice.
- Public Record Information
Please be aware that home sales and purchases may be a matter of public record, and your name and address, the price you paid, your property taxes, and other information may be available from public sites regardless of the brokerage(s), if any, who assist in the transaction. We may post on our Sites some information that typically becomes part of the public record of a home sale or purchase.
- Non-Public Record Information
We may share information obtained from you, MLSs and other third-party sources that is not on the public record related to sales transactions. This includes: search history, sale history, information from listing websites, potential buyers, potential sellers and home sale specifics including offers, counteroffers and sale status..
- Requests to Alliance
Through the Site, you may be able to request such things as make a request to tour a home, get in contact with a real estate agent, receive help selling or buying a home, or submit other requests. When you make such a request through Alliance, you authorize Alliance to share your Personal Information including your contact information, home search history, favorites and saved searches, with a real estate professional for the purpose of responding to your request.
- Service Providers and Business Partners
We may share your Personal Information with third-party service providers that assist us in providing the Sites. We use reasonable efforts do so with the appropriate contractual protection in place to ensure that your Personal Information is protected and used only in accordance with this Privacy Notice. We may also provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services in accordance with applicable law.
Alliance may use third party processors for credit card information, you can request information about the processor directly from Alliance; you are responsible for all terms, conditions and obligations of any third-party processor and agree to indemnify and hold-harmless Alliance from any issue, dispute or other conflict with any third-party processor.
- Third-Party Cookies and Information Used to Target Ads to You
We may share the information that we collect about you with others (including advertising networks and service providers) to tailor and serve you ads, as well as other websites and social media networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” These advertising networks track your online activities over time by collecting information through automated means, including through the use of various technologies (e.g., cookies, web-beacons and other methods). This allows Alliance to target our advertising to you through demographic, behavioral and contextual means. As a result, you may see ads for Alliance on other websites and social media.
- Information Disclosed in Connection with Business Transactions
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
- Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.
- Individual Options
You may have the right to opt in, object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use Personal Information regarding your activities on our Sites and/or information from the advertisements on third party websites for other legal purposes as described above in accordance with applicable law. Specifically, the Sites may display any and all information You provide Alliance, including, but not limited to: sexual orientation, gender identity, pronouns and other information that some may deem sensitive. YOU SHOULD NOT PROVIDE ALLIANCE WITH ANY INFORMATION YOU DO NOT WANT SHARED PUBLICLY.
- Electronic Messages, Phone Calls and other Communications
Tracking and Opting Out
Cookies: We put Alliance cookies on your device’s browser to help us keep track of when you were last on the Sites, and what you last searched on the Sites. We may also use third-party cookies. to help analyze user/member use of the Sites. Disabling cookies on your browser is available but may affect functionality.
Opting Out. The following items may be used by Alliance; Google Analytics, Interest-based Advertising, Mobile Device ID Tracking, Flash Cookies,to the extent they are used, the required opt out provisions will be made available:
We may send you push notifications through the Alliance mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Alliance may also collect location-based information if you use our mobile applications. You may opt-in or opt-out of this collection by changing the settings on your mobile device.
Deleting Your Account
You may delete your Alliance account at through this link available on the Sites. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. Alliance may be required to keep a copy of your Personal Information in accordance with Section 5 below.
Individual Rights in Personal Information
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by Alliance, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, Alliance may take steps to verify your identity before fulfilling your request.
Personal Information Retention
Alliance retains the information we receive as described in this Privacy Notice for as long as you use our Sites or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Alliance follows generally accepted, or better, standard to protect the information it collects and makes it available via its Sites. Alliance tests their security procedures regularly and modifies them as new technologies become available; this includes, but is not limited to using encrypted servers.
Personal Information Storage and Security
Alliance is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Sites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Sites, by mail or by sending an e-mail to you.
Alliance Sites and Services are not directed to minors under the age of 18 (or other age as defined by local law), and we do not knowingly collect Personal Information from minors. Please contact Alliance at the contact information provided below and Alliance will promptly take steps to delete such information.
Notice to California Residents
California Residents should review the “California Privacy Notice Provisions” appended below as Appendix A. to this Privacy Notice.
Links to Third Party Sites/Applications
The Sites may contain links to other websites/applications and other websites/applications may reference or link to our Sites. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. Alliance does not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Changes to this Privacy Notice
Alliance may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law, which may include updating our notice on our Sites. You understand that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
If you have any questions about our privacy practices or this Privacy Notice, please contact us at:
Zaylore Stout & Associates
333 Washington Ave. S. Ste. 300
Minneapolis, MN 55401
Updated September 2020.
California Privacy Notice Provisions
The follow provisions supplement the information contained in our privacy Notice above and applies solely to individuals, who reside in the State of California (“consumer” or “you”) in our role as an organization. We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
In providing our Services, we may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).
Personal Information does not include:
- Publicly available information from government records.
- Deidentified 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.
Some of the items that may be collected are as follows:
- Identifies: including names, addresses, email addresses, IP addresses account names etc.
- Protected Classes Info: including age, race, color, marital status, sex, gender, general identify, gender expression and sexual orientation.
- Internet Activity: including browsing history, search history, consumer’s interaction with a website, application or advertisement.
- Geolocation data: including physical location or movements.
- Professional or Employment Data: including current or past job history or performance.
- Financial Information: including address, telephone number, banking information, bank account numbers, insurance information, credit card numbers, debit card numbers.
Information we do not collect are as follows:
- Commercial Information: including records of personal property, purchases products or services, consumer history.
- Biometric Information: including, physiological, biological, or behavioral characters, fingerprints, retina scans, voiceprint or health information.
- Sensory Data: including audio, electronic, visual, thermal olfactory or similar info.
- Non-public Education Information: including grades, transcripts, class lists or disciplinary records.
- Inference Drawn from Other Personal Information to Create a Profile: including consumer’s preferences, psychosocial trends, predispositions, behavior attitude intelligence abilities and aptitudes.
Business or Commercial Purposes for Collecting Personal Information
We may use or disclose the Personal Information we collect for the business purposes describe in this Privacy Notice. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you additional notice.
Disclosures of Personal Information for a Business Purpose
We may disclose your Personal Information to the third parties or others as described above in this Privacy Notice, for any of the business purposes described above in this Privacy Notice. 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.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold any Personal Information in our role as a business as defined in the CCPA or other applicable laws.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your request, we will disclose to you:
- The specific pieces of Personal Information we collected about you
- The categories of Personal Information we collected about you.
- The categories of sources from which the Personal Information is collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- If we sold or disclosed your Personal Information for a business purpose
Right to Delete
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may not be able to honor your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Right to Know and Right to Delete
To exercise the access and deletion rights described above, please contact us in writing at the address listed above in this Privacy Notice. Only you, or an authorized agent registered with the California Secretary of State that you authorize to act on your behalf, may make a consumer request related to your Personal Information. You may also make a consumer request on behalf of your minor child (12 and under). If you have any questions about your access or deletion rights described above, you may also contact us via email or regular mail at the contact information contained below in this Privacy Notice.
You may only make a Right to Know request twice within a 12-month period.
We cannot respond to your request to delete or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm 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.
Response Timing and Format
Where possible, we will respond to a verified consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.
Any disclosures we provide will only cover the 12-month period preceding the verified consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
Personal Information Sales Opt-Out and Opt-In Rights
We do not disclose your Personal Information to any third-party in a manner that would be considered a sale under the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites and Services who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below in this Privacy Notice.