Attn: Data Protection Officer
- A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at the address indicated in paragraph (1).
- Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data, including aggregated and de-identified data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
- (a) Information You Provide to Us.
- We may collect Personal Data from you, such as your first and last name, gender, e-mail, property information and password when you create an account to log in to our network (“Account”).
- If you use our Services on your mobile device we may collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can deactivate GPS on your mobile device.
- Our Site lets you store preferences like how your content is displayed, your location, safe search settings, and favorite widgets. We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you participate in one of Aalto’s surveys, we may collect additional information.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
- We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.
- (a) Information You Provide to Us.
You may also provide information, (such as information regarding the property you wish to sell) to be published or displayed (“posted”) on semi-public areas of the Site visible to other registered users of the Site, or transmitted to other users of the Site (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
- (b) Information Collected via Technology. As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
- Pixel Tag. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
- How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
- Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
- (c) Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at the address given in paragraph (1) to request the removal of this information from our database.
- (d) Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. In particular, we use third party data providers such as House Canary (for tax data), OnBoard and Infomatics (for neighborhood information). These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.
We do not collect Personal Data automatically, but we may tie the information that we collect automatically to Personal Data about you that we collect from other sources or that you provide to us.
6. Use of Your Personal Data
- (a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- identify you as a user to other users in our system;
- provide improved administration of our Site and Services;
- provide the Services you request, including but not limited to posting your property information on the Site and allowing users to contact your broker through Twilio;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- provide you with aggregated, de-identified and anonymized information based on our analysis of users’ views and engagement with your property page;
- perform research and development based on your Personal Data to improve our Services;
- send you administrative e-mail notifications, such as security or
- support and maintenance advisories;
respond to your inquiries related to employment opportunities or other requests;
- make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
in any other way we may describe when you provide the Personal Data; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.
We may use your Personal Data to contact you about our own and third parties’ goods and services that may be of interest to you.
- (b) User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city or employing brokerage (if an agent). We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
- (c) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.
- (a) Third Parties Designated by You. When you use the Services, the Personal Data you provide may be shared with your broker (to the extent that your broker is an Aalto registered user) and any other third parties that you designate to receive such information. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.
- (b) Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company.
- (f) Other Disclosures. We may also disclose your Personal Data, to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide it; or with your consent.
9. Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
- (b) Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
- (c) Changing or Deleting Your Personal Data. All users may review, update, correct or delete the Personal Data furnished by a user in their user account (including any imported contacts) by contacting us, or by editing their profile via the Services. If you completely delete all of your Personal Data, then your user account may become deactivated and your broker may be notified of your request to delete or deactivate your account. We will use commercially reasonable efforts to honor your request. If you wish to delete any Personal Data furnished to us by your broker, please contact your broker directly or have your broker make a request for deletion of such Personal Data on your behalf. We may retain an archived copy of your records as required by law or for legitimate business purposes.