Effective Date: January 1, 2017
Last Management Review: December 22, 2016
I. INFORMATION WE COLLECT
Established Business Relationship
When you provide us with information in connection with a particular activity or otherwise sign up for our Services, or provide your contact information, including an email address or telephone number, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about Entitle Direct products and Communities using the information you provided to us. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Information Collected Through Technology
Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) to improve security, analyze trends and administer the Entitle Direct Sites and our Services. We may track your movement within the Entitle Direct Sites, the pages from which you were referred, access times, and browser types. This information may include the browser you are using, the Internet address from which you linked to our Entitle Direct Sites, the operating system of your computer, the unique IP address of the computer you used to access our Entitle Direct Sites, and usage, and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Entitle Direct Sites and Services, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.
Web Beacons. Our web pages contain "web beacons." Web beacons allow us to count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we can measure the effectiveness of our advertising and how visitors use our Entitle Direct Sites and Services. This allows us to learn what pages are most attractive to our visitors, which parts of our Entitle Direct Sites and Services are the most interesting and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Entitle Direct Sites and Services are used only by us, while other web beacons are from our vendors who use this data to assist us in analyzing how our Entitle Direct Sites and Services are used.
Personal Information We Collect
We may collect nonpublic personal information about you from the following sources:
- Information we collect directly from you when you register to create an account or otherwise interact with the Entitle Direct Site(s) or Services.
- Information we receive from you such as an application or other forms.
- Information about your transactions we secure from our files, from our affiliates, or others.
- Information that we receive from others involved in your transaction, such as the real estate agents, lenders, consumer reporting agencies, settlement service providers, or other party necessary to complete your transaction.
From time-to-time we may also request information from you and other users via surveys or sweepstakes. Participation in these surveys or sweepstakes is completely voluntary so you and other users have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Contact information may be used to notify the winners and award prizes and file winners information as required by law. Survey information will be used for the purpose(s) of the survey, including the monitoring or improvement of the use and satisfaction of this Entitle Direct Sites.
Supplemental Information. We may from time to time supplement information you give us with information from other sources, such as information to validate or update your address, payment card or other credit or demographic information. We use this information to help us maintain the accuracy of the information we collect, to enable us to fulfill our products and services, to target our communications so that we can inform you of product and, services and offers that may be of interest, and for internal business analysis or other business purposes.
II. HOW WE USE YOUR INFORMATION
Transactions. We disclose your personal information in your account with our affiliates and nonaffiliated third parties, as permitted by law, who require such information to complete your transaction.
Service Providers. We may use third party service providers, including financial institutions, to help us operate our business and the Entitle Direct Sites and Services. We may share your information with these third parties for those limited purposes.
Third Party Offers. We will not share your information for marketing purposes with any third party without your consent. On occasion, we might offer you special products or services through a relationship with a third party. If you accept the offer, you will become a customer of the company that is fulfilling the offer, and we will not have control over their use of the personally identifiable information that you provide to them when you accept the offer. If you do not want us to use the information you provide to inform you of products and Communities that might be of interest to you, or to provide your information to third party companies, please let us know by contacting our privacy administrator at email@example.com.
Other Uses. We may use your personal information to contact you about services on our Entitle Direct Sites and Services, for which you have expressed an interest, for example, if you have contacted customer service or made an inquiry.
Announcements. We may send you announcements and emails from time to time relating to your account. These include emails such as order confirmations or customer service notifications. We may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, or the delivery of a service is delayed we might send you a notice, or if there is some service issue with something you might have ordered. You may not opt-out of these communications, which are not promotional in nature. We may also use your information to send you updates and communications about our Entitle Direct Sites, other products, and services.
Offers and Promotional Messages. We may also use your email address or phone number you provide to send you updates and communications about our products and services or other messages, such as newsletters, text messages, user check-ins, changes to features of the Service, or special offers. You also will be given the opportunity, in any promotional email or text message that we send to you to opt out of receiving such messages in the future. It may take up toten days for us to process an opt-out request. Just follow the unsubscribe instructions included in each email. You may also opt out by contacting our privacy administrator at firstname.lastname@example.org.
III. ACCESS TO YOUR INFORMATION
IV. CHOICE AND OPT OUT
You may remove your information from our database so as not to receive future communications or to close your account or opt out of our sharing information with third parties for marketing purposes by emailing us at email@example.com or sending snail mail (certified mail, return receipt requested is recommended) to the following address:
Entitle Direct Group, Inc.
800 Connecticut Avenue
Norwalk, CT 06854
If you prefer not to receive electronic promotional communications, you can opt-out by following the unsubscribe instructions included in each communication. Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. Finally, we are not responsible for informing third parties (including without limitation our third party service providers or strategic partners) with whom we have already shared your personally identifiable information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Security. We implement security measures to protect against the loss, misuse and alteration of information under our control such as 128-bit encryption for information transmitted over the Internet and digital certificate services to help identify when you are interacting with our Entitle Direct Sites. The Entitle Direct Sites are protected by regular security software vulnerability scans. WHILE WE USE REASONABLE EFFORTS TO PROTECT YOUR PERSONALLY IDENTIFIABLE INFORMATION, AS DESCRIBED IN THIS POLICY, ELECTRONIC COMMUNICATIONS AND ELECTRONICALLY- STORED INFORMATION AND DATA ARE NOT COMPLETELY SECURE, AND WE CANNOT ENSURE AND DO NOT GUARANTEE OR WARRANT THE SECURITY OF ANY INFORMATION YOU TRANSMIT OR OTHERWISE PROVIDE TO US, AND YOUR USE OF THE ENTITLE DIRECT SITES AND SERVICES INDICATES THAT YOU ARE WILLING TO ASSUME THIS RISK.
Children's Privacy. The Entitle Direct Sites and Communities are not directed or intended for anyone under 13 years of age. We do not knowingly collect Personal Information from individuals under 18 years of age. If you are under 13 years of age, you should not register or provide Personal Information. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user's Personal Information from our systems.
Your California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to the following address set forth below. Please allow 30 days for a response.
Entitle Direct Group, Inc.
800 Connecticut Avenue
Norwalk, CT 06854
Copyright ©2016 Entitle Direct Group, Inc.