Effective Date: January 1, 2023
Century 21 Real Estate LLC and our affiliate and subsidiary companies (such as Anywhere Real Estate Inc., Guaranteed Rate Affinity, Anywhere Integrated Services, Anywhere Advisors, Realogy Insurance Agency, and Anywhere Leads Inc.) (collectively, "Century 21 Real Estate LLC," "we," "our," or "us") are committed to privacy and to transparency in our information practices. This Privacy Policy describes how we collect, use, disclose, and otherwise process the personal information described in this Privacy Policy, as well as the rights and choices individuals have regarding such personal information. This Privacy Policy applies to the extent we process personal data on our own behalf, as a controller or business.
If you are a California resident, please be sure to review Section 17B. California Residents for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws.
Table of Contents
- Scope of This Privacy Policy
- Our Collection of Personal Information
- Purposes and Legal Basis for Our Processing
- Disclosure of Personal Information
- Aggregate and Non-identifiable Data
- Cookies, Tracking, and Analytics
- Interest-Based Advertising
- Social Features and Third-Party Plug-Ins
- International Transfers of Personal Information
- Security
- Data Retention
- Your Rights and Choices
- Children
- Third-Party Websites
- Changes to This Privacy Policy
- Contact Us
- Additional Information for Certain Jurisdictions
1. Scope of This Privacy Policy
This Privacy Policy applies to our collection, use, disclosure, and other processing of personal information related to:
- Our websites (each, a "Website") and mobile applications (each, an "App") that display or link to this Privacy Policy and our other services, products, and technology solutions (collectively, the "Services").
- Former, current, and prospective clients, brokers, independent agents, and customers.
- Other individuals who use our Services, whose personal information we receive related to the Services, or who otherwise interact or communicate with us related to our Services or our business.
Our collection, use, disclosure, and processing of personal information about individuals will vary depending upon the circumstances. This Privacy Policy is intended to describe our overall privacy and data protection practices.
Not covered by this Privacy Policy. This Privacy Policy does not apply to our employees and non-employee workers.
Additional privacy notices. In some cases, different or additional notices about our data collection and processing practices may be provided and apply to our processing of certain personal information. The additional notice will control to the extent there is a conflict with this Privacy Policy, with respect to your personal information that is subject to that notice.
2. Our Collection of Personal Information
Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services or we may be unable to fully respond to your inquiry.
We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third-party services that we use).
Information we collect directly. We collect information that you provide to us, such as when you create an account, provide contact information, complete or submit a form through our Services, participate in surveys or contests, submit orders or requests, or register for or use our Services.
Information we collect from third parties. We may collect or receive personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms, brokers and affiliated agents, and other real estate professionals, and third parties.
3. Purposes and Legal Basis for Our Processing
Certain laws, including the EU General Data Protection Regulation ("GDPR"), UK and Brazil data protection law, and similar laws require that we inform applicable individuals of the legal basis for our use and other processing of their personal information.
Legal bases under certain privacy laws:
- Performance of contract: as necessary to enter into or carry out the performance of our contract with you.
- Compliance with laws: for compliance with legal obligations and/or defense against legal claims.
- Our legitimate interests: in furtherance of our legitimate business interests including customer relationship management, marketing, fraud prevention, security, and internal investigations.
- With your consent: in some cases, we rely on your consent to collect and process your personal information.
Purposes of processing include: providing support and services, analyzing and improving our business, personalizing content and experiences, advertising and marketing, securing and protecting our business, defending our legal rights, planning and facilitating business transactions, auditing and corporate governance, and complying with legal obligations.
4. Disclosure of Personal Information
We may disclose the personal information we collect to third parties, as reasonably necessary for the purposes described above and as otherwise directed or consented to by you, including:
- Service providers: third-party service providers who perform services for us.
- Subsidiaries and affiliates: our subsidiary and affiliated companies.
- Third parties: independent real estate professionals, brokerage companies, and other third parties to provide services you request.
- Business transfers: as part of any actual or contemplated merger, sale, or transfer of our assets.
- Legally required: where we are required to do so by law or legal process.
- Protect our rights: where we believe it necessary to respond to claims, comply with legal process, or protect our rights and safety.
5. Aggregate and Non-identifiable Data
We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data, we will maintain and use the information in deidentified form and not attempt to reidentify the information, except as permitted by applicable privacy laws.
6. Cookies, Tracking, and Analytics
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. We use the information for security purposes, to facilitate navigation, to improve, analyze and optimize our Services and their functionality, to personalize and improve your experience, and to improve and measure our advertising campaigns.
Cookies. Cookies are small text files that a website transfers to your hard drive. You can control cookies through your browser settings. Click "Cookie Preferences" in the footer of our Website for more information.
Pixel tags and similar technologies. Pixel tags may be used to track actions of users, measure the success of marketing campaigns, and compile statistics about usage.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version.
Third party analytics tools. Our Websites use tools such as Google Analytics. You can learn about Google's practices at https://tools.google.com/dlpage/gaoptout.
Browser signals. Please note that our Websites do not recognize or respond to browser "do-not-track" requests or other browser privacy signals.
7. Interest-Based Advertising
We may work with third-party ad networks, analytics companies, measurement services and others to display advertising on our Services and to manage our advertising on third-party sites, mobile apps and online services. You may obtain more information about targeted advertising and opt-out at:
8. Social Features and Third-Party Plug-Ins
The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Please refer to the privacy policies of those social sharing services for more information.
9. International Transfers of Personal Information
Century 21 is headquartered in the United States and has affiliates and service providers in multiple jurisdictions. Your personal information may be transferred to the United States and other jurisdictions where we or our service providers have operations. Some of these jurisdictions may not provide the same level of data protection as your home country. In such cases, we rely on suitable personal information transfer safeguards.
10. Security
We use technical, administrative, and physical controls to help protect personal information from unauthorized access, use, and disclosure. Even so, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us.
11. Data Retention
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights.
12. Your Rights and Choices
We provide several ways for you to exercise certain privacy choices regarding your personal information:
- Marketing: You may opt out from receiving marketing-related communications by using the unsubscribe mechanism in each email.
- Cookies preferences: Click "Cookie Preferences" in the footer of our Website.
- Deactivation: You can deactivate your account at any time by contacting us.
- Access, amendment and deletion: You may submit a request by emailing dataprivacy@anywhere.re or calling (888) 778-6995 (toll free).
13. Children
The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, we will take appropriate steps to try and delete such personal information.
14. Third-Party Websites
The Services may contain links to third-party services. We do not own, operate, or control the websites of third parties, including those of independently owned and operated franchisees. We are not responsible for the privacy practices of other services.
15. Changes to This Privacy Policy
We may amend this Privacy Policy at any time. Any material changes will be effective 10 days after our posting of the updated Privacy Policy or as otherwise required by applicable law.
16. Contact Us
If you have any questions or concerns about this Privacy Policy, please use the following contact information:
17. Additional Information for Certain Jurisdictions
Residents of certain states have additional rights under applicable privacy laws, as described in this section.
A. EEA and the United Kingdom
The GDPR and UK data protection laws give data subjects the following rights regarding their personal information:
- Right of access: You have the right to obtain confirmation and access to your personal information.
- Right to rectify: You can request the rectification of inaccurate data and the completion of incomplete data.
- Right to erasure: You have the right to obtain erasure of personal information in limited circumstances.
- Right to restriction of processing: You have the right to obtain restriction of processing your personal information.
- Right to data portability: You have the right to receive your personal information in a structured, commonly used format.
- Right to object: You have the right to object at any time to processing based on legitimate interests.
- Right to object to direct marketing: You can request that we change the manner in which we contact you for marketing purposes.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right to lodge a complaint: You have a right to lodge a complaint with your local supervisory authority.
You may submit your GDPR request via our online webform or by phone at (888) 778-6995 (toll free).
B. California Residents
This section provides California residents with additional information regarding our collection, use and disclosure of their personal information under the California Consumer Privacy Act ("CCPA").
Categories of personal information we may collect include: Identifiers, Customer records, Characteristics of protected classifications, Commercial information, Usage data, Location data, Audio/Video/Electronic data, Employment history, Education information, Profiles and inferences, and Sensitive personal information.
Rights of California Residents under the CCPA include:
- Opt out of sales and sharing
- Limit uses and disclosures of sensitive personal information
- Deletion of personal information
- Right to know/access
- Correction of inaccurate personal information
- Non-discrimination
California residents may exercise their CCPA privacy rights via our online webform or by phone at (888) 778-6995 (toll free).
Requests to Opt Out. Our website responds to global privacy control (GPC) signals. More information about GPC is available at globalprivacycontrol.org.
C. Residents of Other U.S. States
Residents of certain U.S. states (including Virginia) may have additional rights under applicable privacy laws, including:
- Correction: to correct inaccuracies in personal information.
- Deletion: to delete personal information.
- Access: to confirm processing and obtain a copy.
- Opt-Out: to opt out of sale, targeted advertising, or automated decision-making.
You may submit a request via our online webform or by phone at (888) 778-6995 (toll free).