PRIVACY POLICY

Last revised: December 9, 2019

Your privacy is very important to us. This Site is hosted by Constellation Web Solutions, Inc. or one of its affiliates (collectively, "Constellation") on behalf of one of its real estate industry customers (the "Company," "we" or "us"). The Company is the data controller and its full name and contact details are set out on the Site. Constellation and the Company are independent contractors and are not partners or otherwise engaged in any joint venture in delivering the Site. Nothing in this Privacy Policy shall have the effect of making Constellation a sole or joint data controller. This Privacy Policy has been prepared to explain how we collect, use, protect, and share information and data when you use this Web site (the "Site"), including information and data that we share with our service providers such as Constellation. Constellation hosts multiple Web sites (together with this Site, the "Sites") on behalf of realtors ("Realtors") including the Realtor associated with this Site ("Your Realtor").

By visiting or using all or any part of this Site, you consent to this Privacy Policy.

Visitors
This Site links to this Privacy Policy because Constellation collects, uses, and retains all information, including Personal Information and Usage Data, that users share with or otherwise make available via the Site. For example, when you provide your contact information, this information is collected and stored by Constellation under the terms of Your Realtor's agreement with Constellation, is used by Constellation to provide services to, at the direction of or for the benefit of Your Realtor under that agreement and is shared with Your Realtor. Similarly, at some point, Realtors may require users to register on the Sites. Such registration information would be collected, stored and used, to provide services to, at the direction of, or for the benefit of Your Realtor by Constellation and shared with the applicable Realtor. This Privacy Policy, however, only covers Constellation's information privacy practices with respect to the information Constellation collects via the Site. Realtors may have different privacy policies and practices, but are required to have practices no less protective than the terms of this Privacy Policy. Realtors are required to take certain affirmative steps to protect Personal Information collected via the Site and to comply with all applicable privacy laws and regulations. However, Constellation does not control Realtors and is not responsible for their actions, including their compliance with privacy laws.

Managing Your Information Preferences
You can always review, correct, update, or change your Personal Information, or opt out of direct marketing efforts, or if you have questions or concerns regarding this Privacy Policy by sending an email to support@constellationws.com.

Information We Collect

Personal Information.
Constellation collects information that personally identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information"). In particular, the Site has collected the following categories of Personal Information from its consumers within the past twelve (12) months:

For purposes of this Privacy Policy, "Personal Information" does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from "Personal Information," 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.

Constellation collects Personal Information only if you choose to share it (for example, by inserting your information into forms you complete), and only at the direction of Your Realtor pursuant to Constellation's Agreement with Your Realtor. The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use certain features of the Sites.

Anonymous Usage Data.
The site automatically collects anonymous usage information that does not identify an individual user ("Usage Data"). For example, each time you use the Site, it automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits. Constellation uses this information to help understand how people use the Sites, and to enhance the services Constellation offers.

Cookies and Web Beacons.
The site may use cookies (a small text file placed on your computer to identify your computer and browser) and Web beacons (an electronic file placed on a Web site that monitors usage). These technologies may be used in connection with the Sites. Constellation uses cookies and Web beacons to improve the quality of the Sites. Constellation does not use cookies or Web beacons to collect Personal Information. Most Web browsers are initially set up to accept cookies. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies, though either of those actions may affect your use of the Site.

How We Use Information and When We May Share and Disclose Information

Generally.
Constellation uses Personal Information only at the direction and for the benefit of Your Realtor for internal purposes, such as to provide you with the Sites, to enable Constellation or Your Realtor to notify you of new products or services, and to otherwise communicate with you about your use of the Site or Your Realtor. Constellation will disclose your Personal Information to Your Realtor in accordance with this Privacy Policy. Constellation will not disclose Personal Information to third parties without your consent, including for their direct marketing purposes, except as explained in this Privacy Policy.

Service Providers.
From time to time, Constellation or Your Realtor may establish a business relationship with other businesses whom Constellation or Your Realtor believes is trustworthy and who we have asked to confirm that their privacy practices are consistent with ours ("Service Providers"). For example, Constellation may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, or marketing and promotions. Constellation only provide our Service Providers with the information necessary or helpful for them to perform these services on Constellation's behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than for the purpose for which such information was provided or as authorized by you.

Advertising.
We may work with third-party advertisers, search providers and ad networks ("Advertisers"). These companies may collect and use information about your use of the Sites in order to provide advertisements about goods and services that may be of interest to you. These companies may place or recognize a unique cookie on your computer or use other technologies such as Web beacons. This Privacy Policy does not cover any use of information that an Ad Network may collect from you.

Standard Analytics Information.
Constellation may use, and disclose to Realtors and third parties, certain Usage Data regarding the Sites. However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually.

Other Transfers.
Constellation may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with it. If Constellation is merged, acquired, or sold, or in the event of a transfer of some or all of Constellation's assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

Compliance with Laws and Law Enforcement.
Constellation cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Constellation may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in its discretion, it believes it is necessary or appropriate for any of the following reasons: (a) to respond to legal requests (including court orders and subpoenas); (b) to protect the safety, property, or rights of Constellation, any Realtor or any third party; (c) to prevent or stop any illegal, unethical, or legally actionable activity; or (d) to comply with the law.

Be Careful When You Share Information with Others
Please be aware that whenever you send messages, make postings, or otherwise post or transmit any information or content on this Site or any other of the Sites or any public forum available on or through the Sites, that information or content may be accessed by others. In addition, when you share information or any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Security
Constellation is very concerned about safeguarding the confidentiality of your Personal Information. Constellation employs reasonable physical and electronic measures designed to protect your information from unauthorized access. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while Constellation strives to protect information transmitted on or through the Sites, Constellation cannot and does not guarantee the security of any information you upload, store, share, transmit, or provide on or through any Site and you do so at your own risk.

Links to Other Web sites
The Sites may contain links to other Web sites, or allow others to send you such links. A link to a third party's Web site does not mean that Constellation or Your Realtor endorses it or that we are affiliated with it. Constellation dos not exercise control over third-party Web sites. You access such third-party Web sites or content at your own risk. You should always read the privacy policy of a third-party Web site before providing any information to the Web site.

Children's Privacy
Constellation does not knowingly collect Personal Information from children under the age of 13. If Constellation becomes aware that a user is under the age of 13, Constellation will terminate any account that user may have with it. If Constellation becomes aware that it has inadvertently received Personal Information from a child under the age of 13, Constellation will delete such information from its records.

Processing in the United States
Please be aware that your Personal Information may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Sites, you agree that the collection, use, transfer, and disclosure of your Personal Information will be governed by the applicable laws in the United States.

Privacy Policy Changes
From time to time, this Privacy Policy may be changed. If this Privacy Policy is changed, you will be informed by posting of the revised Privacy Policy on the Site. Those changes will go into effect on the Revision Date shown in the revised Privacy Policy. Your continued use of the Sites constitutes your consent to the revised Privacy Policy.

FOR CALIFORNIA CONSUMERS ONLY:

The California Consumer Privacy Act of 2018 ("CCPA"), as amended from time to time, applies solely to visitors, users, and others who reside in the State of California. The CCPA provides California residents with specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights.
You have the right to request that Constellation disclose certain information to you about its collection and use of your Personal Information over the past 12 months. Once Constellation receives and confirms your verifiable consumer request, it will disclose to you:

• The categories of Personal Information it collected about you.
• The categories of sources for the Personal Information it collected about you.
• Its business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom it shares that Personal Information.
• The specific pieces of Personal Information it collected about you (also called a data portability request).
• If Constellation sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
• Sales, identifying the Personal Information categories that each category of recipient purchased; and
• Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights.
You have the right to request that Constellation delete any of your Personal Information that it has collected from you and retained, subject to certain exemptions. Once Constellation receives and confirms your verifiable consumer request, Constellation will delete (and direct its service provider(s) to delete) your Personal Information from our records, unless an exemption applies.

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

• Complete the transaction for which the Personal Information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of its ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546, et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Constellation.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Constellation by either:

• Emailing us at ccpa@constellationws.com
• Calling us at 866-866-0899

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

Constellation cannot respond to your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with Constellation. Constellation will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format.
Constellation endeavors to respond to a verifiable consumer request within forty-five (45) days of its receipt. If more time is required (up to 90 days), you will be informed of the reason and extension period in writing by mail or electronically, at your option.

Any disclosures Constellation provides will only cover the 12-month period preceding the verifiable consumer request's receipt. The response Constellation provide will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, Constellation will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Constellation does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Constellation determines that the request warrants a fee, it will tell you why that decision was made and provide you with a cost estimate before completing your request.

Other California Privacy Rights.
California's "Shine the Light" law (Civil Code § 1798.83) permits users of the Site that are California residents to request certain information regarding Constellation's disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to ccpa@constellationws.com or write us at 6737 West Washington Street #2120, Milwaukee, WI 53214.