Privacy Policy

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Privacy Policy
Updated June 7, 2019

Who We Are and Why We Collect Your Information?

Connect Now Inc. (“Connect Now,” “we,” “us,” “our”) assists our clients to process their sales leads, follow up with potential customers, and manage their customer data using: (1) the websites that we own or operate, including, but not limited to, www.connectnowinc.com (collectively, the “Sites”); and (2) software applications, which include hosted applications, widgets, APIs (which can be deployed on third party websites, including our customers’ sites), and applications for mobile devices (collectively, the “Apps,” and each individually, an “App”) (the Apps and Sites are collectively referred to as the “Services” and each individually, as a “Service”). If you were directed here while entering your information into a third party website, please know that we are helping a client respond to your interest in its products or services.

We are committed to protecting the confidentiality, integrity, and security of your personal information. We take this responsibility seriously. This Privacy Policy is intended to help you understand how we collect and safeguard your information. By accepting the terms of this Privacy Policy, you hereby consent to our collection, use, and sharing of your information in the following ways.

What Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of (1) personally identifiable information, as defined by numerous statutes in the United States, including the California Online Privacy Protection Act (such statutes, the “PII Laws”), (2) personal information, as defined by the California Consumer Privacy Act (the “CCPA”), (3) personal data, as defined by the European Union General Data Protection Regulation (the “GDPR”), and (4) personal information, as defined by Canada’s Personal Information Protection and Electronics Documents Act (“PIPEDA”, and collectively with the PII Laws, CCPA, and GDPR, the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you access, view, complete, or use any of the Services or any webpage that hosts an App. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. For example, if you were directed here by a third party website, this Privacy Policy does not govern the company that maintains that website because Connect Now does not own or operate that website, although we may track your activity on the webpage that directed you here by virtue of the App that is hosted there.

Although this Privacy Policy is intended to govern our treatment of Personal Information generally, we reserve the right to provide a privacy policy that is specific to any particular Service (a “Service-Specific Policy”), in which case that privacy policy will supersede or supplement this Privacy Policy with regard to that Service.

What Information Does Connect Now Collect?

Connect Now does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect the following types of information from you:

Information You Provide to Us:
We may collect Personal Information from you when (i) you contact us with questions or concerns, and (ii) you interact with, respond to, or answer questions from any of the Services. The information we collect depends on the needs of the client that has retained us and the purpose for your use of the Services. Examples of Personal Information we may collect include the following:

  • your name;
  • personal contact information, including phone number and/or email address;
  • business contact information, including name, address, telephone number, and email address;
  • the product or service you are interested in, including any particular real estate property;
  • details of the products and services you have purchased from our clients or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries; inquiries regarding client services;
  • your photograph; and
  • other unique information such as user IDs and passwords, product functionality, product and service preferences, contact preferences, educational and employment background, and job interest data.

You can choose not to provide us with some or all of this information, although that may affect the functioning of the Services and/or prevent you from receiving assistance regarding the products or services in which you expressed an interest.

Information Collected Automatically:
When you use a Service, certain information is passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses, cookies, Global Positioning System (GPS) location data, and web beacons. These are described in more detail below:

  • IP Addresses. This site uses IP addresses. An IP address is a number assigned to your computer by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user’s computer).
  • Cookies. Cookies are small files that are stored on your computer, smartphone or other device by your web browser. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. We collect the following information via cookies: information related to your use of the Sites and any webpage that hosts an App (including your password, the links you click on, your movement around the site, the pages you visit, the number of times you open a page, information you consult, the website from which you arrived, your language, your access times, and use of particular features of the Services, including, but not limited to, viewing or responding to queries from consumers and client agents); your IP address; your device; your unique device identifier; your operating system; and your browser type. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to refuse some or all cookies, or to delete existing cookies from your device. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services’ features. This Privacy Policy does not cover the use of cookies by any third parties.
  • GPS Location Data and Other App Data. When a user downloads one of the Apps onto his or her smartphone, Connect Now uses the App to obtain GPS location data passively from the user’s smartphone.
  • Web Beacons. A web beacon (which is also known as a “clear gif” or “pixel tag”) is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. We may use web beacons to collect information regarding your activity on the Sites and whether you have read an email.

E-mail and Other Communications:
We may contact you, by email or other means; for example, we may send you promotional offers on behalf of Connect Now or our clients, or communicate with you about the Services. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by clicking on the unsubscribe link in any of our emails or by contacting us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

Personal Information from Other Sources
After collecting Personal Information from you as described above, Connect Now may use that The Personal Information collected from those sources may include, but is not limited to, your photograph, address, marital status, children, age, net worth, preferences, interests, real estate, and other demographic/profile information.

Special Categories of Personal Information:
Except as stated otherwise in this Privacy Policy and any Service-Specific Policy, we do not knowingly collect special categories of Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation. Where a Service-Specific Policy states that we collect and use such information, the Service-Specific Policy will explain the collection of such Personal Information and request your informed consent.

What Does Connect Now Do With Personal Information?

Assist Clients
Connect Now collects your Personal Information on behalf of our clients in order to assist their communications with you and to help manage their lead generation and their collection, storage, use, and disbursement of the data they process as part of their business development. Consequently, we share the Personal Information we collect with our clients. Additionally, as part of the services we provide to clients, Connect Now may use your Personal Information to:

  • Assist you in completing a transaction or registration with a client;
  • Improve and develop client products, services, and support through quality control, research, and data analysis activities;
  • Update you on new client products and services;
  • Measure performance of client marketing initiatives and behavioral targeted advertising;
  • Enable you to participate in client contests and surveys;
  • Answer inquiries, provide information, support, or advice about existing and new client products or services;
  • Provide access to protected areas of the Sites; and
  • Convert Personal Information to nonpersonal and aggregate information and provide that to clients for the purposes discussed in this Section III.A.

Improve the Services We Provide to Clients
Connect Now may also use your Personal Information to improve the services we provide to clients by:

  • Managing our relationship with you;
  • Communicating with you about our products, services, promotions, surveys, or support;
  • Sending marketing communications;
  • Providing products, services, promotions, surveys, and support to you;
  • Assessing and improving the performance and operation of the Services;
  • Keeping your contact details up to date and providing updated details to our service providers and suppliers where necessary;
  • Processing and responding to any complaint made by you;
  • Preventing and detecting security threats, fraud, or other malicious activity;
  • Improve and develop our products, services, and support through quality control, research, and data analysis activities;
  • Conducting due diligence checks on our business contacts as part of Connect Now’s information security program; and
  • Converting your Personal Information to nonpersonal or aggregate information to use the purposes discussed in this Section III.B.

We may derive your general geographic location (city, state or metropolitan region) based on your IP address. IP addresses are also used to provide an audit trail regarding use of the Services.

Sell on Behalf of Clients
At the direction of or with the permission of one or more clients, we may rent or sell Personal Information and nonpersonal and aggregate information derived from Personal Information to third parties for advertising and market research purposes.

Will Connect Now Share Any of the Personal Information it Collects?

We share your Personal Information with third parties as described below.

Clients that Have Retained Connect Now to Assist with Business Development and Data Management:
We disclose Personal Information and nonpersonal information that has been derived from Personal Information to our clients. Our clients include, but are not limited to, real estate brokerages, automotive dealers, and insurance brokerages.

Third Party Businesses We Do Not Control:
Third Party Businesses that Interact with You
In certain situations, businesses or third party websites we’re affiliated with may communicate with you, market to you, sell items. or provide services to you through emails or through a website (either alone or jointly with us). You can recognize when an affiliated business is associated with such communication, marketing, transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such activity. We have no control over the policies and practices of third parties or their websites as to privacy or anything else, so if you choose to engage with, enter into a transaction with, or to receive such service from a third party, please review the applicable third party’s privacy policies.

Third Party Businesses that Assist Connect Now Business Operations
Connect Now retains third party service providers and suppliers to manage or support its business operations, provide professional services, deliver complete products, services and customer solutions and assist Connect Now with marketing and communication initiatives. These providers and suppliers may be located in the US or other locations and include, for example, providers of customer support and live-help, marketing and communications, hosting and IT services, email services, automated data processors, shipping solutions, management and support of the Sites, order fulfillment services, and delivery services. Connect Now will only disclose your Personal Information to such service providers and suppliers to the extent necessary for those third parties to provide services and supplies for Connect Now.

Business Transfers:
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

Legal Obligations, Our Protection, and the Protection of Others:
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Connect Now, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With Your Consent:
Except as set forth above, we will obtain your consent before disclosing your Personal Information with third parties, and you will be able to prevent the sharing of this information.

Connect Now’s Legal Basis for Collecting and Using Your Personal Information
To the extent possible, Connect Now collects and uses your Personal Information pursuant to your informed consent, which you have granted by (a) confirming the prompts produced by each Service, and (b) continuing to use the Services, consistent with this Privacy Policy and any Service-Specific Policy. Please note that without your consent to collect and use the Personal Information required in any particular Service, Connect Now may not be able to connect you with more information, an agent, a broker, or a representative regarding the product or service in which you have expressed an interest. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Some of our clients operate or partner with websites that direct you to the Services, but do not give you the option of consenting to our collection and use of your Personal Data or provide this Privacy Policy to you. In those situations, Connect Now relies on the websites to provide the necessary disclosures and obtain the necessary consents for us to collect and use your Personal Information. In the event that such a website does not properly disclose or obtain your consent for Connect Now’s collection and use of your Personal Data, the operators of that website are liable.

For individuals and Personal Information Subject to the GDPR: In addition to relying on informed consent, Connect Now reserves the right to process your Personal Information:

(1) As a processor, pursuant to the written authorization of a controller, i.e., a client. Consistent with the GDPR, the controller determines the purposes and means of processing your Personal Information. As a processor, Connect Now relies on the controller to obtain the necessary legal basis from each data subject before collecting and processing Personal Information. In the event that the controller does not have a legal basis to collect and process your Personal Information, the controller will be liable for all damages arising due to that deficiency.

(2) As a processor, in order to pursue the legitimate business interests of our clients, which are to develop sales leads and manage relevant data generated as part of their business operations.

(3) In order to pursue our legitimate business interests in assisting clients to manage their sales leads and data and to improve the Services.

(4) In order to perform a contract to which you are a party. Where the processing is based on a contractual requirement, your failure to provide the relevant Personal Information may result in Connect Now being unable to assist with the completion of the contract. For example, if you do not provide your Personal Information in response to a website or Service requesting it as part of coordinating a sale, Connect Now may not be able to connect you with the appropriate sales representative to conclude the sales contract.

Any one or more of these bases are the legal basis for our collection and use of your Personal Information, depending on (x) how you use this the Services, and (y) your relationship with Connect Now.

How Long Will Connect Now Retain Your Personal Information?

Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, Connect Now maintains Personal Information as follows:

  • Account Information. Except for managed accounts, we retain account information for as long as an account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain your information as necessary to resolve disputes, to enforce our agreements, and to continue to develop and improve the Services.
  • Managed Accounts If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by your employer under our agreement with your employer as required by the administrator of your account. If your account is deactivated, your information and conversations you may have had and actions you may have taken on the Services will remain in order to allow your team members to make full use of the Services. Such organization account data is retained per the Account Information entry above.
  • Marketing Information If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services. Every marketing email we send will provide you with the option to opt out of receiving future emails.
  • Other Information. Other than as described above, we will determine the retention period for your Personal Information based on the following criteria:
    1. The nature of our relationship with the relevant client;
    2. The nature of our relationship with you;
    3. The nature of the Personal Information in question; and
    4. Our internal research needs.
What Are Your Rights to Control Your Personal Information?

Except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Connect Now’s collection and use of your Personal Information.

Requests to Connect Now:

You may request (1) the correction, updating, deletion, or restriction of collection and use of your Personal Information, (2) the categories of Personal Information Connect Now has collected, (3) the categories of sources from which Connect Now has collected your Personal Information, (4) the business purpose(s) for collecting and disclosing your Personal Information, (5) an account of how Connect Now has used or is using your Personal Information, (6) a copy of your Personal Information retained by Connect Now, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible, (7) the categories of third parties with whom Connect Now shares your Personal Information, (8) the categories of Personal Information which we share with third parties, and the contact information for such affiliates and/or third parties, and (9) a list of all third parties that have received your Personal Information from Connect Now. We will respond to all such requests within 45 days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information be deleted, we reserve the right to terminate and/or limit your access to the Services. If we do not have your Personal Information, have not collected your Personal Information, or have not disclosed or transferred your Personal Information to another party, we will inform you in response to a request regarding your Personal Information. Any of the above requests may be made by contacting us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900

When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Withdrawal of Consent:

You may withdraw your consent at any time by contacting us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Please be aware that such withdrawal does not affect the lawfulness of Connect Now’s use of your Personal Information before such withdrawal. We reserve the right to terminate and/or limit your access to the Services in the event that you withdraw your consent.

Do Not Track

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked. At this time, Connect Now does not track your online activities outside of the Services. Therefore, setting or releasing your Do Not Track signal will not affect how the Services operate. For clarity, this is just our Do Not Track Policy. Connect Now does not make any promises about how third parties react when you set Do Not Track signals on your browser. In addition, the Do Not Track signal does not impact the use of information collected prior to such request.

Object or Challenge:

You may object, on grounds relating to your particular situation, at any time to the collection and use of your Personal Information based on Connect Now’s legitimate interests or based on public interests, or otherwise challenge our compliance with the Privacy Laws, by contacting us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Connect Now shall respond within 45 days. Where such objection is received from an individual whose Personal Information Connect Now collects and uses as the processor for a controller (as those terms are defined in the GDPR), Connect Now shall inform the controller of the objection within 45 days.

Filing a Complaint:

Regulatory authorities that oversee the Privacy Laws advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with Connect Now’s response to an objection or challenge filed under Section VII.C above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:

Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada.

Under GDPR: You may file a complaint with a supervisory authority in the relevant European Union member state.

Under PII Laws: You may file a complaint with the relevant state’s Attorney General’s office.

Under the CCPA: You may file a complaint with the California Attorney General’s Office, although please note that the CCPA is not effective as of the date of this Privacy Policy and that the rules governing the CCPA and the formal complaint mechanism have yet to be established.

Please note that the links above are subject to change by the relevant regulatory authorities and that you may need to go to another site or contact the relevant authority in another way in order to properly file a complaint.

Unsubscribe to Subscription Communications

Subscription communications include email newsletters, software updates, etc., that may be expressly requested by you or which you consented to receive. After you request such communications, you may opt out of receiving them by using one of the following methods:

  1. Select the email “opt out” or “unsubscribe” link, or follow the opt-out instructions included in each email subscription communication. To unsubscribe from messages delivered on any supported device, reply to the message with the word “UNSUBSCRIBE.”
  2. You may also return to the webpage(s) where you originally registered your preferences and follow the opt-out instructions.
  3. You may contact Connect Now directly at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Be sure to provide your name, relevant contact information, and specific relevant information about the Connect Now subscriptions that you no longer wish to receive.

Please be aware that when you opt out of receiving certain subscription communications, it may affect other services you have chosen to receive from Connect Now where accepting the communications is a condition of receiving the services.

Upon receipt of your request we will unsubscribe you from such messages within seven days.

Prohibit Automated Processing:

At your request, Connect Now will terminate any automated decision making, including profiling. Please see Section XII for an explanation of the automated decision making Connect Now utilizes.

Is Personal Information About Me Secure?

We employ appropriate administrative, organizational, technical, and physical measures to protect your Personal Information, which we regularly review and update as necessary. Further information follows.

We store your Personal Information in a cloud-based infrastructure that is hosted and managed within Amazon’s secure data centers, utilizing the Amazon Web Service (AWS) technology. Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Amazon’s data center operations have been accredited under:

  • ISO 27001;
  • SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II);
  • PCI Level 1;
  • FISMA Moderate; and
  • Sarbanes-Oxley (SOX).

We endeavor to protect the privacy of your Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time.

At times, your access to the Services is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser.

You may have accessed the Services from sites that we do not control. Additionally, the Services may contain links to sites we do not control. We are not responsible for the privacy policies and/or practices on sites we do not control. When viewing or following a link to another site you should read that site’s privacy policy.

Children’s Privacy

Except as otherwise stated in a Service-Specific Policy, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to participate in the Services. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, telephone number, or email address. No one under age 18 may provide any Personal Information to us or through the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible, except as provided below. If you believe that we might have any information from a child under age 18, please contact us at:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900
privacy@connectnowinc.com

Upon request, we will provide a parent or guardian who has provided proper identification with the following: (1) a description of the specific types of Personal Information collected from the child, (2) the opportunity to refuse or permit Connect Now’s further collection and use of Personal Information from the child, and (3) a reasonable means for the parent or guardian to obtain any Personal Information collected from the child. If a parent or guardian does not permit Connect Now’s continued collection and use of Personal Information from a child, Connect Now will delete the child’s Personal Information and terminate the account of the child, as applicable.

Contractual or Statutory Requirement

Except as noted in this Privacy Policy or in a Service-Specific Policy, Connect Now’s collection and use of Personal Information is not a contractual or statutory requirement or a requirement necessary to enter into a contract.

Failure to Provide Personal Information

You can always opt not to disclose information to us, but keep in mind some information may be needed to use the Services or to communicate with an agent, broker, or sales representative.

Automated Decision Making

Per Article 4(4) of the GDPR, profiling is defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.” Connect Now does not rely on automated decision making, including profiling, that will produce legal effects concerning you or similarly significantly affect you. We use automated decision making to evaluate real estate renters and buyers, however, we do not use those evaluations to make any decisions. We provide these evaluations to our real estate brokerage clients, but have no control over how they use that information. Please consult with those parties to determine the extent to which they rely on automated decision making.

Transfer of Data

When we transfer personal information from a country of origin to the United States, we do so in compliance with all laws of the originating country. Consistent with the GDPR, we comply with the EU-US Privacy Shield Framework.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Privacy Policy when you use any Service after such changes have been first posted.

Questions or Concerns; Contact Information

If you have any questions or concerns regarding our privacy policies, please contact our data protection officer by sending a detailed message to privacy@connectnowinc.com. Alternatively, you may contact us by telephone or postal service as follows:

Attn: Data Protection Officer
Connect Now Inc.
One Commercial Wharf North, 3rd Floor
Boston, MA 02210
844-675-0900

We will make every effort to resolve your concerns.

Translations

This Privacy Policy was originally published in English and has been translated into other languages. The content of the English original shall prevail in case of differences in the content or context of other language versions.

Effective Date: June 7, 2019

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