Privacy Policy

The policy set forth below is provided in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or please do not use this web site.

Sotheby’s International Realty® Online Privacy Statement

Sotheby's International Realty Affiliates LLC and our affiliate and subsidiary companies (collectively, "we," "our," or "us") are committed to privacy and to transparency in our information practices. In this Privacy Notice (the "Notice"), we describe how we may collect, use, disclose, and otherwise process personal information related to our websites (each, a "Website") and mobile applications (each, an "App") that display or link to this Notice and our other services, products, and technology solutions (collectively, the "Services").

Last Updated on December 18, 2020

Profiles and inferences: inferences drawn from any of the above used to create a profile reflecting an individual’s preferences, behaviors or other characteristics.

OVERVIEW OF OUR COLLECTION AND USE OF PERSONAL INFORMATION

We think transparency is important. In this overview, we summarize the personal information we collect and how we use it, which is further explained in our Privacy Notice below. Keep in mind that the actual information we collect, and our use of such personal information varies depending upon the nature of our relationship and interactions with an individual. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

Categories of Personal Information We Collect. Generally, we collect the following types of personal information:

• Identifiers: such as name, contact information, IP address and online identifiers, Social Security number and other government identifiers.
• Customer Records: paper and electronic records containing personal information, which you provide to us in order to access or use our Services, such as name, digital signature, address, telephone number, email and other contact information.
• Characteristics of Protected Classifications: such as disability and health information (e.g., which we may collect in order to, for example, make accommodations available to you at events we host) and other profile information you provide to us.
• Commercial Information: including records of real property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Usage Data: internet or other electronic network activity Information including without limitation browsing history, search history, and information regarding an individual's interaction with our Services or an advertisement.
• Geolocation Data: precise location information about a particular individual or device.
• Audio, Video, and Other Electronic Data: audio, electronic, visual, or similar information, such as CCTV images and thermal screenings (e.g., collected from visitors to our offices), photographs and call recordings.
• Employment History: professional or employment-related information.
• Education Information: education information and records.
• Inferences: inferences drawn from any of the above used to create a profile reflecting an individual's preferences, behaviors or other characteristics.

Use of personal information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:

• Providing support and services
• Analyzing and improving our business
• Personalizing content and experiences
• Advertising, marketing, and promotional purposes
• Securing and protecting our business
• Defending our legal rights
• Auditing, reporting, corporate governance, and internal operations
• Complying with legal obligations

Individual rights. Please see Section 12, “Your Rights and Choices”, below for a description of the choices we provide and the rights you have regarding your personal information. If you are a California resident, please be sure to review Section 17 below titled "Additional Information for Certain Jurisdictions" for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws, including your right to submit a “Do Not Sell My Personal Information” request (i.e., to opt out of the sale of your personal information by us).

1. SCOPE OF OUR PRIVACY NOTICE

This Notice applies to our collection, use, disclosure, and other processing of personal information related to:

• the use of our Services that display or link to this Notice;
• former, current, and prospective clients, brokers, independent agents, and customers; and
• other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services

Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This privacy notice is intended to describe our overall privacy and data protection practices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information

Personal information. In this privacy notice, our use of the term "personal information" includes other similar terms under applicable privacy laws—such as "personal data" and "personally identifiable information." In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.

Not covered by this notice. This privacy notice does not apply to job applicants and candidates who apply for employment with us, or to our employees and non-employee workers.

2. OUR COLLECTION OF PERSONAL INFORMATION

Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services or we may be unable to fully respond to your inquiry.

We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use).

Information we collect directly. We collect information that you provide to us, such as

• when you create an account, provide contact information, and send other personal information to us;
• when you complete or submit a form through our Services, for example, "Contact Us" or "More Information" forms;
• when you participate in surveys or contests, submit orders or requests, or register for or use our Services, or otherwise contact us;
• information you submit or provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria, information about financing for the purchase of real estate, and other information related to the purchase or sale of real estate.

Information we collect from third parties. We may collect personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), from brokers and independent agents of Realogy Holdings Corp. brands, and from other third parties. For example, without limitation:

• Social media. If you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services.
• Real estate professionals. Information that may include, among other things, your name and email address, that you may have given to an independent real estate professional with whom you have a pre-existing relationship. The professional may collect such personal information from you with the sole purpose of pre-populating an account for the Services on your behalf and with your consent. You may choose not to finalize the creation of an account and may opt-out of certain future communications from us by following the instructions in the account creation notification or by contacting us at the email address in this Notice.
• Property records. We may collect information about individuals and real estate property through public databases, such as property ownership and tax records maintained by state, local and county agencies.

3. LEGAL BASES FOR OUR PROCESSING OF PERSONAL INFORMATION

Certain laws, including the EU General Data Protection Regulation ("GDPR"), requires that we inform applicable individuals of the legal bases for our use and other processing of personal information.

Pursuant to the GDPR (and other relevant laws), we process personal information for the following legal bases:

• Performance of contract: as necessary to enter into or carry out the performance of our contract with you.
• Compliance with laws: for compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, and data protection, tax, and corporate compliance laws.
• Our legitimate interests: in furtherance of our legitimate business interests including:

  • Performance of contracts with franchisees and other parties
  • Implementation and operation of global support (e.g., IT) services for our business operations
  • Customer relationship management and improving our Services, including marketing and analytics
  • Fraud prevention, including misuse of company IT systems or money laundering
  • Physical, IT, and network perimeter security
  • Internal investigations
  • Mergers, acquisitions, and reorganization, and other business transactions

• With your consent: where we have your consent (the GDPR (where it applies)) and other applicable laws give you the right to withdraw your consent, which you can do this at any time by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use of the Services may be taken as implied consent to the collection and processing of personal information as outlined in this privacy notice

In addition, we may process your personal information where necessary to protect the vital interests of any individual.

4. USE OF PERSONAL INFORMATION

While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below. Where GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases).

• Providing support and services: including, for example, to send or facilitate communications among you, independent real estate professionals and their affiliated entities, and other users of the Services, provide products and services you request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your requests and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
• Analyzing and improving our business: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys, and other evaluations, such as customer satisfaction surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests)
• Personalizing content and experiences: including to provide or recommend features, content, social connections, and referrals; tailor content we send or display on our Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate interests and/or with your consent)
• Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate interests and/or with your consent)
• Securing and protecting our business: including 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. (Legal basis: our legitimate interests and/or compliance with laws)
• 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. (Legal basis: our legitimate interests and/or compliance with laws)
• 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. (Legal basis: our legitimate interests and/or compliance with laws)
• 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. (Legal basis: our legitimate interests and/or compliance with laws)

Aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes.

5. DISCLOSURE OF PERSONAL INFORMATION

We may disclose the personal information that we collect about you as set forth below or as otherwise described at the time of collection or sharing.

• Service providers: We may disclose personal information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.
• Subsidiaries and Affiliates: We may share your personal information with our affiliated companies (i.e., companies under common ownership, control or management with us) - use will be subject to this privacy notice.
• Third Parties. We may disclose personal information to third parties in order to provide our Services, facilitate your requests, or with your acknowledgement and consent, including with:

  • independent real estate professionals and owners and operators of real estate brokerage companies to enable them to provide services you request through the Services.
  • third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.
  • the public if you submit to a public part of the Services, such as comments, social media posts, or other features viewable by the public or generally by registered users of the Services.
  • third parties with whom you choose to let us share information, for example other apps or websites that integrate with the Services, or those with Services with which we integrate.
  • third parties we work with to provide you with more personalized content and ads, and to track the effectiveness of campaigns.

• Business transfers: We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
• Legally required: We may disclose personal information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
• Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers or others.

Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics, and other purposes.

6. COOKIES, TRACKING, AND ANALYTICS

Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associates with your activities on our Services.

We use the information for security purposes, to facilitate navigation, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns and to better reach users with relevant advertising both on our Services and on third party websites. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

Cookies. Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Service.

• Essential cookies are essential, as they enable you to move around the Service and use its features. Without these cookies we could not, for example, authenticate your login or remember that you are logged-in as you move through the Service.
• Functionality cookies ïallow us to remember choices you make (such as the region you're in) and tailor the Service to provide enhanced features and content for you. For instance, they can be used to remember your login details or remember your nickname when you next login. They may also be used to provide services you've requested, for example leaving a comment on the Service.
• Analytics & performances cookies collect information about how the Service is used, for example which pages users visit most often and if any error messages are displayed on certain pages. Information collected using these cookies is used to monitor activity on the Service and understand how it is being used.

If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org.

Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Third party analytics tools. Our Websites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track signals. Please note that our Websites do not recognize or respond to any signal which your browser might transmit through the so-called 'Do Not Track' feature your browser might have. If you wish to disable cookies on our Websites, you should not rely on any 'Do Not Track' feature your browser might have.

7. INTEREST-BASED ADVERTISING

On some of our Websites, we may work with third-party ad networks, analytics companies, measurement services and others ("third-party ad companies") to display advertising on our Services and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device's geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

You can manage how your preferences regarding third party ad company cookies set by this Service by reading the cookie discussion above.

Please also see the cookie discussion above for information about the third parties we may work with to display targeted ads on third-party sites and to measure the success of our marketing and campaigns. You may also obtain more information about targeted or "interest-based advertising" and opt-out of many ad networks at the industry websites below:

• Canada: www.youradchoices.ca
• EU: www.youronlinechoices.eu
• U.S.: www.aboutads.info

8. SOCIAL FEATURES AND THIRD PARTY PLUG INS

The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not receive or store passwords to your third-party social media accounts in this context.

9. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The Services are hosted on servers located in the United States. Note that some countries may not provide the same level of data protection as your home country. If you are located, for example, in European Economic Area or Switzerland (collectively, "EEA"), your personal information will be transferred to the United States and possibly to other jurisdictions (e.g., to the location of a property for which you have requested information), which may not provide the same level of protection under your local data protection laws. In such cases, we rely on suitable personal information transfer safeguards. You may have the right to request a copy or information about those safeguards by contacting us as detailed below.

10. SECURITY

We use technical, administrative, and physical controls in place to help protect personal information from unauthorized access, use, and disclosure. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us in accordance with Section 16 below ("Contact Us").

11. DATA RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with our clients' instructions.

12. YOUR RIGHTS AND CHOICES

Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. 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.

Cookies and similar technologies. Please review your browser or device settings for certain cookies and see above to exercise certain choices regarding cookies.

Access, amendment and deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted or otherwise exercise your rights over your personal information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:

• By submitting a request to us at [email protected]
• By contacting us at (888) 778-6995 (toll free)

We follow applicable law to take steps to keep your personal information accurate, complete and up-to-date. In your request that is covered by an applicable privacy law, 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 or otherwise let us know what limitations you would like to put on our use of your personal information. We may only implement requests (a) where required by applicable law and (b) 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 see the Section 17 (“Additional Information for Certain Jurisdictions”) for information about individual rights under the CCPA and the GDPR.

Deactivation. You can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfill this request.

Responding to Requests. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Additional information for certain jurisdictions. We are committed to respecting the privacy rights of individuals under all privacy laws applicable to us. Some privacy laws require that we provide specific information about individual rights to applicable consumers, which we have set forth at the end of this privacy notice:

• California: if you are a California resident, you have certain rights, under California privacy laws, regarding your personal information as set forth in Section 17 below.
• EU/EEA: if you are in the European Union / European Economic Area, we provide further details about your rights under the GDPR in Section 17 below.

13. CHILDREN

The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.

14. THIRD-PARTY WEBSITES

The Services may contain links to third-party services. We do not own, operate, or control the websites of third-parties, including those of independently owned and operated franchisees. Accordingly, this Notice does not apply to any services maintained or operated by third-parties. When you click on those links, you will go to a third-party website where you will be subject to that service's privacy policy or similar statement and terms of use, and we encourage you to read that policy statement. We are not responsible for the privacy practices of other services, and we expressly disclaim any liability for their actions, including actions related to the use and disclosure of personal information by those third parties.

15. CHANGES TO THIS POLICY

We may amend this Notice at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on the Services. Any material changes to this Notice will be effective 10 days after our posting of the updated Notice or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Notice.

16. CONTACT US

If you have any questions or concerns about this Notice, please use the following contact information:

• Email: [email protected]
• Mailing address: 175 Park Ave., Madison, NJ 07940 Attn: Data Privacy
• Phone number: (888) 778-6995

17. ADDITIONAL INFORMATION FOR RESIDENTS IN CERTAIN JURISDICTIONS

Sierra Sotheby’s International Realty Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the foregoing Sotheby’s International Realty Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. As used throughout this notice, SIERRA Sotheby’s International Realty is referred to as “we,” “us,” or “our company”.

I. Received or Collected Information

This Table Discloses Information We May Receive or Collect, and Information We Do Not Receive or Collect
Category	We May Receive or Collect This Information	We Do Not Receive or Collect This Information
Identifiers	Your name, postal address and email address, online identifiers, internet protocol address *In certain real estate transactions, a title company may be required to collect social security (tax ID), driver’s license and 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.	Identifiers, alias, unique personal identifier, account name
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)).	Signature, address, telephone number, bank account number (for proof of funds if necessary), sales information such as listing price and purchase price, home/title insurance policy numbers 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). *In certain real estate transactions, a title company may be required to collect social security (tax ID), driver’s license and passport numbers and occupation 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.	Physical characteristics or description, State identification card number, other insurance policy numbers, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law.	Citizenship or marital status, mental capacity (as sometimes issues of capacity arise in a real estate transaction) *In certain real estate transactions, a title company may be required to collect 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.	Age (40 years or older), race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).*
Commercial information.	Information is received when used to facilitate a real property purchase transaction such as sales information, purchase price, listing price or contract terms.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric information.	We do not collect this information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	General geographic physical location	Physical movements.
Sensory data.	We do not collect this information	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment- related information.	*In certain real estate transactions, a title company may be required to collect occupation information 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.	Employment information, Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	We do not collect this information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.	Lists of potential buyers or sellers (“lead lists”)	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

* Social security (tax ID), driver’s license and passport numbers, and citizenship and occupational information may be collected pursuant to Treasury Department anti-money laundering rules when the buyer is an entity and is not using a bank loan to purchase residential real property. These Treasury Department rules are designed to uncover the identity of the natural person behind the entity. This information will be required to given to the title company when the transaction involves all of the following:

• Property is within the counties of Los Angeles, San Diego, San Francisco, San Mateo or Santa Clara
• Sales price is $300,000 or more
• Buyer is a “Legal Entity” such as a corporation, LLC or partnership Property is a 1 to 4 unit residential property (including condos)
• Some part of the purchase is made using ANY wired funds, cashier’s check, certified check, traveler’s check, personal check, business check, money order in any form, or a virtual currency (such as Bitcoin)
• Purchase is done without a bank loan or similar forms of external financing

Since a transaction will typically not close without the information, when required, our brokerage     may assist the title company in working with an entity buyer to gather it.

California law under the CCPA defines “personal information” broadly. However, there are some exceptions. Personal information does not include:

• Publicly available information from government records. De-identified 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.

II. Where do we receive information from?

Our company receives information directly from you

Our real estate business receives personal information primarily for the purpose of transacting real property sales and purchases. Nearly all of the information which we directly collect about you is received from the physical or electronic documents that constitute the real estate transaction. For example, the real property purchase agreement will contain your name, signature, purchase price and other personal information. Or, for example, a seller is required by law and contract to give the buyer various disclosures concerning a range of issues associated with the property, some of which information may constitute personal information. Once these documents come into our possession, by law a broker must maintain such record for three years. Typically, we retain our files for a longer period.

Cookies and Other Technologies

Our website and some of our online products and services, email messages and advertisements may use cookies, log files and other technologies to collect information about your use of our website, products and services and third-party websites that have a business relationship with our service providers. A cookie is a small data file that is sent to your browser from a website's servers and stored on your computer's hard drive, and is used to store information such as the name of your Internet service provider, your Internet Protocol (IP) address, the website that referred you, your general geographic location, the pages you request, and the dates and times of those requests.

Most internet browsers are initially set to accept cookies. If you prefer, you may set your browser so that it refuses cookies or alerts you when cookies are being created on your hard drive. You should be aware that by not accepting cookies you may impair your ability to use certain portions of our website, products and services. Our company receives some information indirectly.

Multiple Listing Service (“MLS”). An MLS is a database of properties for sale that is available and disseminated to and accessible by all other real estate agents who are participants or subscribers to the MLS. Property information submitted to an MLS describes the price, terms and conditions under which the seller’s property is offered for sale. It is likely that a significant number of real estate practitioners in any given area are participants or subscribers to an MLS. The MLS may also be part of a reciprocal agreement to which other MLSs belong. Real estate agents who belong to other MLSs that have reciprocal agreements with the MLS in which the property is placed may also have access to the information submitted the MLS. The MLS may further transmit listing information to internet sites that post property listings online. The placing of a listing on the MLS allows wide exposure of the property to the marketplace which tends to impact the sales price.

Title Companies and Escrows. These service providers are essential to real estate transactions. Not only do title and escrow companies receive information, but they supply invaluable assistance in providing information about all aspects of a real estate transaction to brokers and agents.

Lenders and mortgage brokers. Typically, agents and brokers will be in contact throughout the transaction with a lender or representative of a lender to keep informed on the progress of the lending process. During this process an agent may receive personal information relating to the loan, the loan application, the buyer’s qualifications for the loan, documents requested by the lender, or reasons why a loan is being denied, approved or delayed.

City, county, state and other agencies of government. Many aspects of a real estate transaction rely on information received from a variety of government sources. For example, the assessor will typically provide their estimate of the square footage of the house, among various other types of data concerning the property.

Reporting companies. Reporting companies will access public records for information concerning the property and then provide a summary of the information. This information is not typically considered “personal information.”

Other sources of information. Neighborhood advertising information; real property portals such as Realtor.com; HOA documents from HOAs; appraisers and appraisals; investigators, inspectors and contractors; and legally and contractually required disclosures generated by the seller are other sources of information from which personal information may be collected or received.

III. Use, Sharing and Sale of Personal Information

Use of Personal information

Assistance in buying or selling a house.The primary use of personal information is to help you buy or sell a house. For example, if you are seeking to buy a house, the personal information we collect will help our agents find the right house for you. If you are seeking to sell a house, the information will be used to find a buyer who will purchase your house on the agreed price and terms.

Web technologies. We use cookies and other technologies to verify user information, to make your use of our website, products and services more convenient and to assist in understanding your use of our website, products and services. We also use cookies to measure website activity and generate statistics that allow us to improve the services we provide online.

Additional Uses. We may use the personal information we collect for the following additional business purposes:

• To create, maintain, customize and secure the communications between you and us. To assist in preventing transaction fraud.
• To provide, support, personalize, and develop our website, products, and services.
• To personalize your online experience with us and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third- party sites, and via email or text message (with your consent, where required by law).
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by our company is among the assets.

Sharing of personal information and chart

Sharing information to promote the sale or purchase of homes. The sharing of information is integral to the process of buying or selling a house. First and foremost, we will share information with other agents and brokers, and sellers and buyers. It is only through the sharing of information that our agents can find the right house for you as a buyer, or if you are a seller, find a buyer who will purchase your house on the agreed price and terms.

Information supplied and received from the Multiple Listing Service (“MLS”). An MLS is both a source of information and a means to share information. As described in the previous section, an MLS is a database of properties for sale that is available and disseminated to and accessible by all other real estate agents who are participants or subscribers to the MLS. Property information submitted to an MLS describes the price, terms and conditions under which the seller’s property is offered for sale. An MLS will also act as a repository of information related to properties that have been sold through the MLS.

Since it is likely that a significant number of real estate practitioners in any given area are participants or subscribers to an MLS data, the sharing of MLS will typically be widespread. Moreover, an MLS may also be part of a reciprocal agreement to which other MLSs belong. Real estate agents who belong to other MLSs that have reciprocal agreements with the MLS in which the property is placed may also have access to the information submitted the MLS. The MLS may further transmit listing information to internet sites that post property listing online. The placing of a listing on the MLS allows wide exposure of the property to the marketplace which tends to impact the sales price.

Third parties we commonly share information with. As a real estate brokerage, we may typically share your personal information with the following third parties:

Brokers and agents
Buyers and sellers
Multiple Listing Services
Real estate portals such as Realtor.com
Title companies and escrows
Lenders
Service providers such as inspectors, appraisers or reporting companies
Other third-parties as necessary to complete the transaction

This table discloses which types of information our company has and has not disclosed for a business purpose within the last 12 months.
Category	Has Disclosed within Last 12 months	Has Not Disclosed within Last 12 Months
Identifiers	Name, postal address and email addresses. online identifiers, internet protocol address * In certain real estate transactions, a title company may be required to collect social security (tax ID), driver’s license and 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.	Alias, unique personal identifier, account name, or other similar identifiers
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)).	Signature, address, telephone number, bank account number, sales information such as listing price and purchase price, home/title insurance policy numbers 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) *In certain real estate transactions, a title company may be required to collect social security (tax ID), driver’s license and passport numbers and occupation 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.	Physical characteristics or description, state identification card number, insurance policy numbers, education, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law.	Citizenship, marital status, mental capacity (as sometimes issues of capacity arise in a real estate transaction) *In certain real estate transactions, a title company may be required to collect citizenship information and 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.	Age (40 years or older), race, color, ancestry, national origin, religion or creed, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information.	Information is received when used to facilitate a real property purchase transaction, sales information, purchase price, listing price, contract terms	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric information.	We do not collect or share this information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.	We do not share this information	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	We do not share this information	General geographic physical location
Sensory data.	We do not collect or share this information	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment- related information.	* Information relating to occupation may be collected per US Treasury department anti-money laundering rules in certain real estate transactions where the buyer is an entity and purchasing all cash.	Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	We do not collect or share this information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.	We do not collect or share this information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

* Social security (tax ID), driver’s license and passport numbers, and citizenship and occupational information may be collected pursuant to Treasury Department anti-money laundering rules when the buyer is an entity and is not using a bank loan to purchase residential real property. These Treasury Department rules are designed to uncover the identity of the natural person behind the entity. This information will be required to given to the title company when the transaction involves all of the following:

Property is within the counties of Los Angeles, San Diego, San Francisco, San Mateo or Santa Clara

Sales price is $300,000 or more

Buyer is a “Legal Entity” such as a corporation, LLC or partnership Property is a 1 to 4 unit residential property (including condos)

Some part of the purchase is made using ANY wired funds, cashier’s check, certified check, traveler’s check, personal check, business check, money order in any form, or a virtual currency (such as Bitcoin)

Purchase is done without a bank loan or similar forms of external financing

Since a transaction will typically not close without the information, when required, our brokerage may assist the title company in working with an entity buyer to gather it.

Sale of personal information and chart

“Sale” of information through MLS. Membership in the MLS confers benefits to an agent or broker. As part of membership, the agent or broker is bound to place their listings on the MLS and provide various information including pictures, price, terms and the conditions under which the property is offered for sale, unless the seller opts-out. As a member of the MLS, brokers and agents may be eligible to receive commissions offered through the MLS by other brokers. In this sense the placing of a listing on the MLS may constitute a “sale” of information as defined by the CCPA, even though the brokerage does not receive direct financial remuneration from the MLS. Referrals. With your consent, our company may share your personal information, your name and phone number with other agents and brokers for purposes of referring you to another brokerage. For this we often negotiate a referral fee in line with the traditional model of brokerage referral relationships. Such a fee does constitute a sale.

Other referrals. Referrals other than to agents and brokers do not typically involve a referral fee, since in most residential transactions the taking of a referral fee from a company such as an escrow or title company, mortgage broker, lender, or other settlement service provider is illegal under federal law. Even in those situations where it would be legally permitted, our agents will always disclose and obtain your consent before receiving a referral fee

This table discloses which types of information our company has and has not sold within the last 12 months.
Category	Sold	Not Sold
Identifiers	Referrals With your agreement we will refer you as a buyer or seller to another broker or agent and provide your phone number or email address. In line with traditional brokerage models we negotiate a “referral fee” with the other broker or agent.	Postal address, online identifiers, internet protocol address, Social Security numbers, driver’s license number, passport number, or other similar identifiers, alias, unique personal identifier, account name
California Customer Records statute information (Cal. Civ. Code § 1798.80(e)).	We do not sell this information	Social Security number,   physical characteristics or description, state identification card number, insurance policy number, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information. signature, address, telephone number, bank account number or other financial information (for example, when a seller demands verification of down, or when a “net sheet” is created), sales information such as listing price and purchase price
Protected classification    characteristics under California or federal law.	We do not sell this information	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information.	Multiple Listing Service Information is provided to a Multiple Listing Service (but not for direct financial benefit) such as sales information, purchase price, listing price, contract terms, and pictures of the property	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Biometric information.	We do not sell this information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity.	We do not sell this information	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data.	We do not sell this information	General geographic physical location
Sensory data.	We do not sell this information	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.	We do not sell this information	Current or past job history or performance evaluations.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	We do not sell this information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.	We do not sell this information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

IV. Your Rights and Choices

If you are a California resident, you have certain rights regarding your personal information under the CCPA. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

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. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.

The categories of sources from which we collected your personal information.

Our business or commercial purpose for collecting or selling your personal information. The categories of third parties with whom we share your personal information.

The specific pieces of personal information we collected about you.

If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing the following:

The categories of personal information that we disclosed about you for a business purpose.

The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category of personal information for each third party to whom the personal information was sold.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily useable format that allows you to transmit it to another entity without hindrance.

Deletion Request Rights

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. You must make a verifiable consumer request as described below. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. However, we will not direct the MLS to delete your personal information. For that, you must contact the MLS directly.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Retain transaction files or comply with any other legal obligation. Brokers are required to hold all transaction files for a period of at least three years under California law. However, other information may be required to be held for longer periods.

Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. For example, we will not delete your personal information while we are representing you in your real estate transaction.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

Debug to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

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 of our information is likely to render impossible or seriously impair the achievement of such research, so long as you have provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided it.

How to Exercise Your Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at: 775-832-4900

Emailing us at: [email protected]

You may also make a request on behalf of your minor child. You may only make a request for access to or disclosure of your personal information twice within a 12-month period. The request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we are unable to verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create a user account with us to make a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you provide us with personal information in your request, we will only use it to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will try to respond to your request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. But the extension period will be no more than an additional 45 days.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

If we deliver the information to you electronically, then the information will be portable and to the extent technically feasible, in a readily useable format that allows you to transmit it from another entity without hindrance.

We do not charge a fee to process or respond to your 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

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing: [email protected] with the subject “Do Not Sell My Personal Information”

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by:

Emailing your request to: [email protected]

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

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, deny discounts or other benefits, or impose penalties.

Provide a different level or quality of goods or services to you.

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 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. We currently provide the following financial incentives: None

To make such a request, please send an email to [email protected] or write us at:

Sierra Sotheby’s International Realty
Attn: CCPA requests
570 Lakeshore Blvd.
Incline Village, NV 88451

European Union / European Economic Area

The GDPR (where applicable), gives data subjects the following rights regarding their personal information:

• Right of access: You have the right to obtain from us confirmation as to whether or not personal information concerning you is being processed, and where that is the case, to request access to the personal information. The accessed information includes – among others - the purposes of the processing, the categories of personal information concerned, and the recipients or categories of recipient to whom the personal information have been or will be disclosed. You have the right to obtain a copy of the personal information undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
• Right to rectify and complete personal information: you can request the rectification of inaccurate data and the completion of incomplete data. We will inform relevant third parties to whom we have transferred your data about the rectification and completion if we are legally obliged to do so.
• Right to erasure (right to be forgotten): You have the right to obtain from us the erasure of personal information concerning you in limited circumstances where:

  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where the data processing was based on consent); or
  • following a successful right to object; or
  • it has been processed unlawfully; or
  • the data has to be erased in order to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for:

• compliance with a legal obligation; or
• the establishment, exercise or defense of legal claims.
• Right to restriction of processing: You have the right to obtain from us restriction of processing your personal information. In this case, the respective data will be marked and only be processed by us for certain purposes. This right can only be exercised where:

  • the accuracy of your personal information is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want the personal information erased; or
  • it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.
• Right to data portability: You have the right to receive the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us, but in each case only where the processing is (a) based on your consent or on the performance of a contract with you, and (b) also carried out by automated means.
• Right to object: You have the right to object at any time to any processing of your personal information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
• Right to object to our use of your personal information for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
• Right to withdraw consent: if you have given us your consent for the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to obtain a copy of safeguards: you can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
• Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.