This Privacy Policy is part of the Terms of Use and describes how Tross Equity of America, Inc. and our franchisees handle information collected and received from or through our websites, associated applications, including mobile apps, as well as any other source such as social media. This Policy does not govern the activities of any third party. By accepting the Terms of Use you are accepting and agreeing to be bound by this Privacy Policy and consent to our use and disclosure of such information as indicated herein.
Collection and Use of Personally Identifying Information
We collect and use personally identifying information that you provide to us in the course of seeking offerings or information from us. This personally identifying information may include your name, address, e-mail address, contact information, and information about a property you seek to sell.
We use this information (and other information we collect from you as described in this Policy) for our business purposes, including to contact you, evaluate and value any property you seek to sell, and formulating proposed transactions. We will also seek to match you to a franchisee, send you communications, including from a franchisee, contact you about changes to our Terms of Use and provide transaction related information. We may also communicate with you via text, including communications concerning franchisees. We will also monitor your compliance with our Terms of Use. We may also provide you with offers based upon the information we collect including your location. We may also contact you, or provide your information to a third party to contact you, during and after any initial contact so as to inquire as to your user experience, to provide you with an opportunity to participate in a survey and or to offer you an opportunity to provide feedback as to your user experience. This may include disclosures to a research firm to conduct email, online, phone, text and or zoom surveys to homeowners who contacted us but did not sell their house to us. We do not sell any of the personal information we collect about you to third parties.
Your personally identifying information will not be shared with any third party, with the following exceptions: A. information that Tross Equity in good faith determines is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; B. information revealed during the course of Tross Equity ’ enforcement of its policies and procedures, its Terms of Use, the terms of this Policy, the Online User Agreement, or any other agreement with us, or during the course of any disciplinary actions; C. information in a manner expressly permitted by the provisions of this Policy; D. information that Tross Equity in good faith determines must be disclosed to correct what it believes to be false or misleading information or to address activities that Tross Equity believes to be manipulative, deceptive or otherwise a violation of law; or E. unless you are otherwise notified at the time we collect the data.
Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth herein.
We may also share your personal information with third parties in connection with a merger, sale, acquisition, assignment, bankruptcy proceeding, reorganization or other disposition of some or all aspects of our business or assets.
“Nonpublic Personal Information” is the nonpublic information about you that is obtained by Tross Equity from you. Tross Equity and its advertisers may collect Nonpublic Personal Information from the online forms you complete, from information collected as a result of your transactions with Tross Equity, our advertisers, or others, and from consumer reporting agencies. Tross Equity will not disclose any Nonpublic Personal Information except as permitted or required by law or as described in this Policy. We may disclose all of the Nonpublic Personal Information we collect about you, as well as other information collected as described in this Policy, to our affiliates who offer related goods and services, and to nonaffiliated third parties that perform services on our behalf, including marketing services, or financial institutions with whom we have joint marketing agreements.
Other Information You Provide or Post
In addition to the practices described above, we may also use information we collect to, at your election, provide you with information and advertisements about goods and services we believe may be of interest to you.
You may provide us with testimonials about your experience with us (including a picture of yourself), and with feedback about our services. We may use any such information you provide to enhance our services and for public-facing marketing purposes, such as through online or public display of your testimonial, feedback, and/or picture. We may also incorporate information you provide through messages, e-mails, or other means (though not your personally identifying information) into our materials or offerings.
Accessing the Websites and Information Collection
When you access the Websites without actively providing any personal information we collect limited technical information, such as your IP address. We also use cookies as described below. As a registered user, we collect information about your use of the Websites including homes viewed, photos viewed, pages visited, information about your location and preferences for offerings. We will maintain your login information.
Records of your use of the Websites are the sole property of Tross Equity. Tross Equity reserves the right to use such information for its marketing, franchising, and membership endeavors.
Cookies
We, like most major websites, use cookies (text files placed on your hard drive by a web server) to help personalize and maximize your experience and time online. Cookies are not used to run programs or deliver viruses to your computer. They are uniquely assigned to your computer and can only be read by a web server in the domain that issued the cookie to you. We use cookies to improve the Websites and to facilitate your use of the Websites.
Location-Based Services
To provide location-based services, it may be necessary to collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine the location of your device. Unless you provide consent, such location data is collected anonymously in a form that does not personally identify you and is used to provide location-based services.
For example, your device may share its geographic location with a Service that selects and displays properties relative to the location of your device. Some location-based services may require your personal information for the service to be provided.
Links
The Websites contain links to other websites. Tross Equity is not responsible for the privacy practices of sites other than our own. We encourage you to be aware of the privacy statements on other websites and to read those statements.
Protection of Information
Some areas of the Websites are secured and can only be accessed using unique login credentials. You must have a specific user identifier (user ID) and password to access resources through any password-protected portions of the Websites. Your login credentials and password are for your use only and strictly confidential. You are responsible for maintaining the confidentiality and security of those credentials, and are responsible for all activity occurring on the Websites using your login credentials and password. You are strictly prohibited from any sharing of your login credentials and/or password with any other person(s) and from any use of your login credentials other than for your use of the Websites in compliance with the Online User Agreement.
Third-Party Data Collection/Online Tracking
We use service providers such as Google Analytics to help us understand and improve the usage of the Websites and the effectiveness of our marketing efforts. We, Google Analytics, and/or our other analytics providers may use cookies, your IP address or an anonymous identifier as well as certain information from your browser, together with other non-personal information about your visits to the Websites (this may include information like page views and visit times; app store views; app downloads; user engagement information like active devices and location; app crashes; and behavior metrics) and other websites, so that we, Google Analytics, or third parties may improve the Websites and provide you with advertisements about goods and services of interest to you on the Websites and other websites (including through search engine results pages) and/or to provide analytical information about our Websites. If you would like more information about advertising networks, including choices about the use of information by Google Analytics and other companies for multi-site advertising purposes, go to www.networkadvertising.org and www.networkadvertising.org/choices/. Also, Google offers a Google Analytics browser add-on (designed to be compatible only with certain browsers) to provide website visitors the ability to prevent their data from being collected and used by Google Analytics. That add-on may be obtained here.
Currently, various Internet browsers offer a “do not track” or “DNT” option that uses a DNT header to indicate the DNT preference setting on the browser. Tross Equity does not track your activity over time and across different websites or online services other than as set forth herein, and we do not currently respond to browsers’ DNT signals with respect to the Websites. We do not permit our third-party service providers to collect information from the Websites for other websites or for their own purposes other than as described in this Policy.
Social Media; Third-Party Applications
The collection and use of information on social media websites and applications are governed by their own privacy policies and terms. Please remember that any information posted on or through the Tross Equity pages such as Facebook, Twitter, Google+, or on other social media pages or channels, is subject to the policies and practices of the applicable social media channel.
We may receive personal information from a social media site platform or application when you connect through a social media feed, post content, or otherwise interact with us using social media tools. For example, we may receive basic Facebook account information (name, e‑mail, gender, birthday, current city, and profile picture URL) through Facebook. Also, when you “like” us, or send a “Tweet” to us through a social media channel, we may receive your username, handle, and any other available personal information from the social media site or application. All information received from social media sites and applications is treated and used in the same manner and for the same purposes as described in this Policy with respect to similar information we obtain through the Site.
Children’s Privacy
We are committed to complying with all applicable laws and regulations regarding the collection, storage, and use of personal information of minors under the age of 18, including the Children’s Online Privacy Protection Act of 1998.
We do not collect personal information from minors under the age of 18. Individuals under the age of 18 are not permitted to use the Websites without the supervision of a parent or legal guardian. We do not knowingly collect or solicit personal information from children under the age of 18 or knowingly allow such persons to register for an online account or to place orders or provide personal information through the Websites. If we learn that someone under the age of 18 has provided any personal information through the Websites, we will remove and permanently delete that information as soon as reasonably possible.
If you are a parent or guardian who believes that your minor under the age of 18 has submitted personal information or other information to us without your consent, please contact us using the contact information provided below. Once we verify that you are the parent or legal guardian, we will cooperate with you to discuss what, if any, personal information we have collected about your child and how that information may have been shared or used.
Changes to This Statement
Tross Equity reserves the right to change this Privacy Policy at any time. Notification of changes will be posted on the Websites. Because these changes may affect your personal information, we suggest that you look for information regarding changes on a regular basis and review the changes as soon as they are published on the website.
Disclosures for Compliance with Law
Notwithstanding the provisions of this Privacy Policy or the Online User Agreement, information may be and will be disclosed as needed in order to comply with law, respond to facially valid process or subpoena, to stop or mitigate illegal activity or potential harm, to protect the security of information, and to protect against fraud.
Maintenance of Information Collected
We may maintain the information that we collect indefinitely or may delete it at any time in our sole discretion.
Security
We employ reasonable security methods to prevent unauthorized access, maintain data accuracy, and ensure correct use of your information. We maintain organizational, technical and administrative measures designed to protect your information against unauthorized access, loss, alteration or misuse. However, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect your information, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.
Jurisdiction-specific Provisions and New Laws
This Privacy Policy is intended to comply with all legal requirements including the requirements of any jurisdiction having unique laws regarding the collection and use of personal data (e.g., the California Consumer Privacy Act or “CCPA”). Should you be a resident of any such jurisdiction, this policy is hereby deemed to be amended as appropriate to comply with any such laws. Moreover, to the extent there is any conflict with this Privacy Policy and any and all privacy requirements under the law, including the CCPA and laws that may be enacted after this policy has been updated, this Privacy Policy is to be deemed amended and updated to conform with any and all such legal requirements.
How do we keep your personal information secure?
We have implemented reasonable safeguards to protect your personal information from unauthorized access and improper use.
If the CCPA applies to you, then you have the following additional rights:
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain legal exceptions, such as U.S., state, local and non-U.S. laws, rules and regulations.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact Us section below.
For any requests relating to the exercise of your rights under this Privacy Policy, including the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
We will contact you to confirm receipt of your request, including under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
We will respond to a consumer request within forty-five (45) days of our receipt thereof. We will notify you in writing if we cannot comply with the request and provide an explanation of the reasons.
Contacting Us And Correcting Your Information
Please contact us with any questions including with any questions as to the correctness of the information that we collect and maintain. We strive to assure the correctness of the information we maintain. If the information we have about you is inaccurate, we will correct the information in a manner as timely as possible. To contact us, including to provide us with corrections, please do so in any of the following ways:
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