Last Modified: November 23, 2020.
FGP, LLC. (“Forbes Global Properties,” “we,” “us,” or “our”), including our members and affiliates, respect your privacy and understand that you care about your personal information and how it is used. We value your trust in sharing your personal information with us and are dedicated to protecting your privacy. This Privacy Notice describes in detail the types of information we collect about you; how we use your information and with whom we share it; the choices and rights you have with regard to your information; how we protect your information; and how you can contact us about our privacy practices.
This Privacy Notice applies to the use of the Services (as defined below), including by both consumers and Professionals. “Professional(s)” means individuals, companies and other organizations or persons acting as real estate professionals or otherwise engaged in a business related to Forbes Global Properties’ Services, including, without limitation, REALTORS®, agents, providers of moving-related services, products or information, homebuilders, lenders, brokers, real estate professionals, re-modelers, seniors-related housing, product or service providers, home service professionals, and other service professionals. Except as otherwise indicated, Professionals, consumers, and other persons using the Services are individually and collectively referred to as “you.”
This Privacy Notice applies to personal information collected by Forbes Global Properties website, and mobile apps, mobile-optimized websites, and other applications and/or electronic media (such as emails we send) (collectively, the “Services”).
2. INFORMATION WE COLLECT AND OBTAIN
We obtain personal information about you from a variety of sources. This includes personal information you provide to us directly, information we obtain from other sources, and information we gather through automated means.
Information you provide to us. When you register for or participate in certain services, seek access to certain content or features, or directly correspond with us, we may collect certain types of information from you:
- Contact information (such as name, postal address, email address and telephone and/or mobile numbers);
- Username and password when you register through our Services;
- Your payment information, when needed to facilitate certain transactions;
- Reviews, comments, and/or surveys; and
- Other information you may provide to us, such as through our “Submit a Request” or “Contact Us” feature.
If you are a Professional, we may also ask for additional information, such as relevant professional licensing numbers or an MLS ID#.
Information obtained from other sources. We may obtain personal information about you in connection with the Services from publicly and commercially available sources and from our Forbes Global Properties members and/or business partners (such as advertising networks or social networking services), including:
- Demographic data (such as gender, age range, educational level, household income range, number of children in household, ethnicity to the extent permitted);
- Purchasing data, including information about advertisements you have seen or acted upon and information about your interaction with advertisers’ products and services;
- Occupational data (such as profession, position, title, industry; and business address);
- If you log in with a third-party account with the Services (e.g., Google), we may obtain information about you, such as your user ID and/or user name and other information you have permitted those services to share with us consistent with your privacy settings for that third-party account.
- Your Internet Protocol (IP) address;
- Device information, including unique identifiers and connection information, including mobile device advertising IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;
- Your device type and settings, software used, browser type and operating system;
- Websites or other services you visited before and after visiting the Services (referring URL);
- Web pages and advertisements you view and links you click on within, and what search queries you may have run on, the Services (clickstream);
- Viewing behavior, including the content you view, how long you view content, the quality of the service you receive, and advertisements you have been shown or interacted with;
- Dates and times you access or use the Services;
- Location information, including the city, state and zip code associated with your IP Address, information derived through WiFi triangulation, and precise location information from GPS-based functionality on your mobile apps, with your consent;
- Your phone number and mobile carrier details in connection with our mobile app.
3. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small files that we or others send to and store on or with your computer so that your computer, browser, mobile app or other application can be recognized as unique the next time you access, visit, use or otherwise take advantage of the Services or other media. Cookies may also reflect demographic data pertaining to you or other data linked to information you submit. One use or consequence of cookies is to enable you to receive customized ads, alerts, content, services or information. You are always free to decline any cookies we use by adjusting the settings of your browser, as your browser may permit; however, some products, services or features might not be available or operate properly if cookies are not enabled. Some of our advertisers and third-party service providers may also utilize their own cookies.
In addition, we, our service providers and others sometimes use data-gathering mechanisms on the Services, including without limitation “web beacons”, “clear GIFs”, “pixels” and/or “tags”. These perform statistical and administrative functions, such as measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or IP address) and positioning images, and typically do so without detracting from your online experience. Such mechanisms are not necessarily designed to collect Personal Information. In addition, if you have provided your email address, we might use a non-human unreadable form (or “hash”) of your email address to deliver, or facilitate delivery of, relevant advertisements and information to you on or by way of the Services or on or by way of other websites or media, including, for example, popular social media sites and features.
4. HOW WE USE THE INFORMATION WE OBTAIN
We, or service providers acting on our behalf, may use the information collected from and about you to:
- Provide our products and services, including authorizing a purchase, or completing a transaction that you requested;
- Create and manage online accounts;
- Send promotional materials, alerts regarding available offers and other communications, including text/SMS messages if you provided your mobile number and opted in to receive such messages (for information on our text messaging program, please see our Text/SMS Messaging Program Terms);
- Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
- Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
- Anonymize or de-identify personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
- Provide technical support;
- Generate suggestions about the type of content you may enjoy;
- Supplement your personal information collected directly from you and/or from automated means with additional information from publicly and commercially available sources, and/or information from Forbes Global Property affiliates and our business partners;
- Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes;
- Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);
- Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; and
- In other ways for which we provide specific notice at the time of collection.
5. INTEREST-BASED ADVERTISING
As described in this Privacy Notice we, as well as our third-party service providers, may obtain information about your online activities to provide you with advertising about products and services tailored to your individual interests. We and our third-party service providers also may obtain information for this purpose from third-party websites and apps. We also use third parties (including third-party ad servers) to serve ads on our Services. We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means.
Through these ad networks, we can track your online activities (such as your visits to websites and your use of apps that serve our advertisements, including the pages or ads your view and actions you take on those sites or apps) over time and across third-party websites and apps by obtaining information through automated means, as described above. This data collection takes place both on our sites, apps and emails and on third-party websites and apps that participate in these ad networks. Our third-party advertisers and/or ad networks may also gather data relating to you in connection with your interactions with the advertisements they place on our Services. The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. This information also helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
6. INFORMATION WE SHARE
We may share your personal information with:
- With our Members or Business Partners. With our third-party members/clients or business partners, such as realtors, landlords, and other Professionals to facilitate your transactions, and other third parties for their own commercial or marketing purposes, such as to serve targeted advertisements.
- With our Service Providers. With third parties who perform services on our behalf.
- For Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.
- To Protect our Services and Users. We may disclose information to protect and defend the rights, interests and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss.
- For Business Transfers. In the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
- Non-personal Information. When the information collected from or about you is not defined as personal information under applicable law, we may share such non-personal, de-identified information or aggregated information with third parties at our discretion.
7. YOUR CHOICES AND RIGHTS
We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.
You can choose to use Forbes Global Properties without providing any information about yourself to us directly, but some information may be collected automatically or be requested by us so that you can take advantage of certain features on our Services.
To ask us to remove your information from our marketing mailing lists, please contact us as outlined in the HOW TO CONTACT US Section below. You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of the Services, such as service announcements where you are using our Service.
You also have choices about whether cookies and other similar technologies are placed on your computer or mobile device. For more information, see our section on Cookies and Other Technologies, above.
We may use third-party analytics services on our Services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and similar technologies to help us analyze your use of the Services.
You may also choose to opt out of use of data that we or our third-party service providers collect about your activities to provide you with tailored advertising about products and services of interest to you. We and our third-party service providers also may obtain information for this purpose from third-party websites or apps.
ACCESSING, CORRECTING, AND DELETING YOUR PERSONAL INFORMATION
Consumers and Professionals may access, review, update, and/or correct inaccuracies in your personal information in our custody and control as described below. Please note that any change you request regarding personal information may affect or otherwise change the availability, deliverability or quality for you of information, features, products or services in which you are interested or your experience on or relating to the Services.
- Consumers may access and edit their personal information by following the instructions found in the “My Profile” or “Edit Your Profile” area of the Services where you registered or submitted personal information. If you would like us to no longer use information about you or share it with our affiliates, partners or other service providers, for their marketing purposes, please send a request to email@example.com
- Professionals may edit their personal information by returning to the members site (CRM) and updating their profile.
CALIFORNIA PRIVACY RIGHTS
For additional information for residents of the State of California see section titled “CALIFORNIA PRIVACY RIGHTS” below.
INFORMATION FOR VISITORS FROM CANADA
The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) provides certain rights to Canadian residents. Under Canadian law, you have a right to access your personal information held by us, subject to applicable exceptions. You may contact us or write to us at the address below to ask us to access and/or correct your information. We may require you to send us proof of your identity before providing you with access to your personal information. If you send us a request to access or correct information, then we will contact you within 30 days (although it may take us longer to fully respond to your request).
Our Privacy Notice clearly states how we collect, use and share your personal information. We may share information with third parties, such as subsidiaries, affiliates, business partners and authorized third parties. However, we will only share your information with such parties where we have your explicit consent to do so or, in some cases, where we may infer consent from your actions or behavior. Please contact us at any time to let us know (1) if you do not wish to receive marketing communications (such as emails) from us or our third-party partners, or you otherwise object to our sharing your information with those partners, (2) if you have any questions, or complaints, regarding the collection or use of your personal information or the content of this notice, or (3) if you wish to withdraw your consent to us using your data.
If you are not satisfied with our response to your query or complaint, you may also contact the Office of the Information and Privacy Commissioner of Canada.
8. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect the personal information we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.
9. TRANSFERS OF INFORMATION
The Services are hosted in and managed from the United States. We may transfer the information we collect about you to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the information. Applicable laws in the United States and/or other countries may allow the courts, law enforcement and national security authorities to access your personal information when in such country.
If you are a user located outside the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal information processed in the United States and/or such country. When we transfer your information, we will protect that information as described in this Privacy Notice.
10. LINKS TO THIRD-PARTY SITES, APPS AND SERVICES
For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with Forbes Global Properties. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any sites, apps or services not operated by Forbes Global Properties.
11. CHANGES TO OUR PRIVACY NOTICE
From time to time, we may change our Privacy Notice to reflect changes to our privacy practices and Services. If we modify the Privacy Notice, we will update the “Last Modified Date” and the changes will be effective as of the date we post such Notice. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Notice when it was most recently updated or by other appropriate means, such as email through the email address you most recently provided to us.
12. HOW TO CONTACT US
If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal information, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:
257 N Canon Dr, 2nd Floor
Beverly Hills, CA 90210
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the above Privacy Notice. Certain terms used below have the meanings given to them in the CCPA.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information collected by Forbes Global Properties:
Categories of Personal Information We Collect About You
The categories of personal information we may have collected about you or your use of our Services are:
- Identifiers (such as your contact information (name, email address), government identifiers (social security numbers and MLS ID# or similar professional licensing numbers) or unique personal identifiers (device ID, cookies, IP address);
- Commercial information (such as transaction data or purchase history);
- Financial information (such as credit card information);
- Internet or other network or device activity (such as browsing history or app usage);
- Geo-location information;
- Professional or employment related information;
- Education information;
- Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes);
- Information that identifies or can be reasonably associated with you.
Categories of Sources from Which We Collected Personal Information
The sources from which we may have collected personal information about you or your use of the Services are:
- Directly from you;
- From other sources (such as Company affiliates and/or business partners);
- Through your use of the Services; and
- Publicly available records.
Business or Commercial Purposes for Which We Collected or Sold the Personal Information
The business or commercial purposes, as defined under the CCPA, for which we collected or sold the personal information are:
- performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;
- auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- debugging to identify and repair errors that impair existing intended functionality;
- undertaking internal research for technological development and demonstration; and
- undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
More details concerning the business and commercial purposes are set forth in the How We Use the Information We Obtain above. We may disclose the categories of personal information identified in this California Privacy Notice about our California consumers for our operational purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.
Categories of Third Parties with Whom We Shared the Personal Information
The categories of third parties, as defined by the CCPA, with whom we share personal information include our subsidiaries and affiliates; business partners, data analytics provers and third-party marketers (who may combine your personal information with their own records and records available from other sources), for their own business or direct marketing purposes, and the direct marketing purposes of other third-party marketers.
Your California Privacy Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
California customers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third-parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
You also have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior, to deliver targeted advertising
If you would like to exercise any of these rights, please contact us at
257 N Canon Dr, 2nd Floor
Beverly Hills, CA 90210
You will be required to verify your identify before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.