PRIVACY POLICY
PRIVACY POLICY FOR INDIVIDUALS INTERACTING WITH
Higman Private Collection
This Privacy Notice describes how we collect, use, disclose, retain, and transfer personal information, in connection with the operation of our businesses, which include, real estate, insurance, relocation, mortgage, and other related services. It also describes your rights and choices regarding use, access and correction of your personal information. Personal information may be requested/collected to enable the delivery of our services, to operate our business and to make the experience of using our websites faster and more effective. This Privacy Notice applies to the extend we process personal information on our own behalf, as a controller, processor or business.
By using our website(s), you consent to the terms of this Privacy Notice and to Our processing of personal information for the purposes stated in this Privacy Notice, as well as those explained where We collect personal information on the web. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, YOU CANNOT USE OUR SERVICES.
If you are a California resident, please be sure to review
Section 17.B California Residents
for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws.
Scope of this Privacy Notice
This Privacy Notice 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 Notice, Cartus’ relocation services, our other services, products, and technology solutions (collectively, the “Services”).Former, current, and prospective clients, brokers, independent agents, real estate professionals, 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 Notice is intended to describe our overall privacy and data protection practices.
Not covered by this Privacy Notice:
This Privacy Notice does not apply to job applicants and candidates who apply for employment with us, or 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 Notice, with respect to your personal information that is subject to that notice.
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 Services, and in some cases, from third parties (such as a relocating employee’s employer, social networks, platform providers, payment processers, data providers, and operators of certain third-party services that we use). In some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.
Information we collect directly:
We collect information that you provide to us such as:
When you create an account, submit a webform to us, register for events, or otherwise provide contact information, and share other personal information with us.
When you complete or submit a form through our Services, for example, in CartusOnline or via “Contact Us” or “More Information” forms.
Contact information and profile data: such as your name, address, email and other contact information, as well as any personal data you post or submit, such as demographics, preferences, or that you otherwise submit to us through your account.Real estate and property information: information about past and present property purchases sales and listings (such as address, price, photos, and property details) and other information you provide such as real estate searches and preferences, whether you plan on buying or selling real estate, home search criteria and preferences, language preferences, household members, information about financing for the purchase of real estate, co-owners, and other information related to the purchase or sale of real estate.Payment and purchase information: in some circumstances, we may collect purchase and payment information in order to process payments to or from you, such as your credit card number, direct deposit or financial account number, billing address, and other account information.Communications and interactions: when you email, call, or otherwise communicate with us and with members of our team, we collect and maintain a record of your contact details, communications and our responses. We also maintain records, communications and information that you post in chat sessions, forums and in other areas of the Services, as well as on our social media channels, and information you provide to us related to any customer support requests.Surveys and promotions: When you participate in surveys, contests or promotions that we offer, we will collect your name, age, email address, and other registration information, as well as your responses to any survey questions or other requests. Events and other requests: if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event, including name, contact information, and professional affiliations, as well as any dietary restrictions or other requested accommodations. When you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.Other information: in some cases, we may collect personal information, such as driver’s license, SSN, tax IDs, and other government identifiers. For example, where necessary or verify your identity, complete a transaction or comply with a legal obligation. This information is considered sensitive personal information under certain privacy laws. Additionally, we may need to collect special category information, which could include racial/ethnic origin, health data, biometric data or sexual origination in connection with our services. We will obtain your explicit consent to collect any special category data when required by applicable law. We do not sell or share this information or use it for marketing purposes.
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 (including from people with whom you are friends or otherwise connected), brokers and affiliated real estate agents, and other real estate professionals, and third parties. Cartus may also collect or receive information from a relocating employee’s employer and from other third parties. For example, without limitation, if you choose to link, create, or log in to your Services account with a social media service (e.g., Twitter, Facebook, Instagram, etc.), or if you engage with a separate app or website that communicates with the Services, we may receive personal information about you or your connections from that service. In many cases you can control what personal information you share with us through privacy settings available on those third-party social media services
Information from social media and third-party platforms: If you post information about us or engage with us on third party platforms, or choose to link to or log in to our Services with a third-party account, we may collect personal information about you from that third party platform or account. We may also collect other information about you from that third party platform or account. We may also collect other information that you share or make public on your account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy notices.Listing, search and other real estate information: if you interact or list a property with a broker, independent real estate agent, or other real estate professional associated with one of our Anywhere brands, we may receive personal information about you and your property from them, such as your name and property address, property and listing details, contact information, search criteria and preferences, household members, and co-owners, among other things. These real estate professionals may be affiliated with independently owned and operated brokerages, or with an Anywhere company. Property records: we may collect information about individuals and real estate property through public databases, such as property ownership, purchase and sale transactions and data (including purchase/sale price) buyer and seller names and contact information, and tax records maintained by state, local and county agencies.
Information we collect automatically or derive about you:
We automatically collect personal data related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:
Device and browsing information: we automatically collect information when you visit a Website or user our Services, such as IP address, general location information, domain name, page vies, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, seeSection 6. Cookies, Tracking, and Analyticsbelow.Activities and usage: we also automatically collect activity information related to your use of the Services, such as information about the links clicked, searches, properties viewed, features used, items viewed, time spent within the Services.Location information: We may collect or derive location information about you such as through your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.Profiling and characteristics: we may also derive information about you based upon the other information we have collected, such as whether you may be interested in purchasing.
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. In this section, we describe the purposes for which We will collect, use, disclose and otherwise process personal information, as well as the legal basis for such processing under certain privacy laws.
Legal bases under certain privacy laws:
Pursuant to the GDPR, UK, and Brazil data protection law, and similar laws, we collect, use, and otherwise process personal information for the following legal bases:
Performance of contract: as necessary to enter into or carry out the performance of a contract with you.Compliance with laws: for compliance with legal obligations and/or defense against legal claims, including those in the area of labor and employment law, social security, and data protection, tax, and corporate compliance laws.Our or our clients’ legitimate interests: in furtherance of Our or our clients’ legitimate business interests including, for example:Performance of contracts, including for relocation services, with franchisees or othersImplementation and operation of global support (e.g., IT) services for our business operationsCustomer relationship management and improving our Services, including marketing and analyticsMarketing and advertisingFraud prevention, including misuse of company IT systems or money launderingPhysical, IT, and network perimeter securityInternal investigationsMergers, acquisitions, and reorganization, and other business transactionsWith your consent: in some cases where We need and obtain your consent to collect and process your personal information. (SeeSection 17.Abelow for information about withdrawing your consent.)
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes of processing:
Relocation Services: Cartus processes your personal information described above as necessary for Cartus to provide relocation services under the terms of its contract with your employer or membership group consistent with legitimate interests of your employer or membership group (i.e., our corporate or government entity client). If you provide Cartus with sensitive personal information or special category data, Cartus will process it based on your consent when required by applicable law. In general, Cartus will collect, use, disclose, retain and transfer personal information for the purposes of managing and facilitating your move from one location to a new location (the “Relocation Purpose”), including the following to the extent authorized by your employer or membership group: (a) arranging for your physical move and the storage of your property; (b) tracking and processing expense reimbursements and other benefits, such as lump sum payments; (c) home sales, purchases, and rentals, including financing arrangements; (d) explaining various employer-sponsored benefits; (e) immigration and other customs related purposes; (f) referring you to third parties who provide cultural assistance and/or language training; and (g) other activities relating to the delivery and improvement of relocation services. Any access to your personal information is restricted to those individuals that have a need to know to fulfill their job responsibilities. Cartus will not use personal information for any other purpose incompatible with the Relocation Purpose outlined in this Privacy Notice, unless it is required or authorized by laws that apply to Cartus or otherwise authorized by you.
In addition to the Relocation purpose, we also collect, use, disclose and otherwise process personal information for the purposes set forth below, as well as the legal basis for such processing, as applicable under relevant laws (see above for further explanation of these legal bases).
Real Estate Services: In general, we use the personal information we collect in order to respond to your request and provide you with the Services or information about property listings or to be connected with buyer or seller agents to assist you with home searches and real estate transactions, we may collect and disclose information about you and your request in order to facilitate communications among you, independent real estate professionals, our affiliated entities, and other users of the Services. If you express an interest in a listing or request information, we may send you information in response to your request and we may share your information so that a broker or agent can respond to your request.
We may also process the personal information (described above) that we collect, for the following general business and commercial purposes:
Providing support and services: including, for example, to send or facilitate communications with you, your employer or membership group, to provide the Services, provide products and services you or your employer request (and send related information), operate our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your requests and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you or your employer or membership group; and our and our clients’ legitimate interests).Analyzing and improving our business: including to better understand how users’ access and use our Services, to evaluate and improve our Services and business operations, and to develop new features, offerings, and services; to conduct surveys, and other evaluations, such as customer satisfactions surveys; and for other research and analytical purposes. (Legal basis: our legitimate interests).Personalizing content and experiences: including to provide or recommend features, content, social connections, and referrals; tailor content we send or display on our Services; to offer location customization and personalized help and instructions; and to other wise personalize your experiences. (Legal basis: our legitimate interests and/or with your consent).Advertising, marketing and promotional purposes: including to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; and to contact you about our Services or information we think may interest you; to administer surveys, promotions and contests; to share information of new home sales and enable other businesses to contact you about products and services you may be interested in, such as home warranties. (Legal basis: our legitimate interests and/or with your consent).Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to rights or safety of any person or third party, or other unauthorized activities or misconduct. (Legal basis: our legitimate interests and/or compliance with laws).Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate interests and/or compliance with laws).Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations; privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate interest and/or compliance with laws).Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests. (Legal basis: our legitimate interests and/or compliance with laws).
Disclosure of personal information
We may disclose the personal information that we collect to third parties, as reasonably necessary for the purposes described above or as otherwise directed or consented to by you, including:
Service providers: We may disclose personal information to third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers.Subsidiaries and affiliates: We may share your personal information with our affiliated companies (i.e., companies under common ownership, control or management with us), as defined in the beginning of this Privacy Notice, who will process your personal information in accordance with the principles of this Privacy Notice. Where required by applicable law, we will obtain your consent to such sharing.Third Parties: we may share transaction information about property sales (most of which is also recorded in and publicly available through public records) with certain partners and companies with which we work; these third parties and others they work with may contact you about products and services you may be interested in. We may also disclose your personal information to third parties in order to provide our Services, facilitate your requests, and/or with your acknowledgement and consent, including to:independent real estate professionals and owners and operators of real estate brokerage companies, moving services providers, immigration and visa service providers to enable them to provide services you request through the Services.third parties to provide you a service you or your employer requested.the public if you submit information, such as comments, social media posts, or other features viewable by the public.third parties with whom you choose to let us share information, for example, other apps or websites that integrate with the Services, or those with Services with which we integrate.third parties we work with to provide you with more personalized content, and to track the effectiveness of campaigns and our Services.Business transfers: We may disclose or transfer personal information as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.Legally required: We may disclose personal information if we are required to do so by law or legal process (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).Protect our rights: We may disclose personal information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of us, our clients and customers or others, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
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 (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our deidentification processes are reasonable and adequate).
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 Websites. For instance, when you visit our Websites, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associated with your activities on our Services.
We use the information for security purposes, to facilitate navigation, to improve, analyze and optimize our Services and functionality, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns, and to better reach users.
Click “Cookie Preferences” link in the footer of our Website for more information about cookies on that Website, and to review and update your preferences for most types of cookies (other than those that are necessary to the functionality of that Website).
Cookies:
Cookies are small text files that a website transfers to your hard drive to store and sometimes collect information about your usage of websites, such as time spent on the websites, pages visited, language preferences, and other anonymous traffic data. You can control the way in which cookies are used by altering your browser settings. You may refuse to accept cookies by activating the setting on your browser that allows you to reject cookies. However, if you select such a setting, this may affect the functioning of our sites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or log on to our Service.
If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.
Pixel tags and other similar technologies:
Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users on Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.
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. This information is gathered automatically and stored in log files.
Third party analytics tools:
Our Websites use automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about sue of the Websites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices and opt out of collections of your browsing data by Google Analytics
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. However, you can review and update your cookie preferences on our Websites as discussed above.
Interest-based advertising
On some of our Websites, we may work with third-party ad networks, analytics companies, measurement services and others (“third-party ad companies”) to display advertising of our Services and to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixels tags and other tools to collect information on our Websites (and on third-party sites and services), such as browsing history, IP address, device ID, cookie and advertising IDs, and other identifiers, general location information and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.
You can review and manage your preference for targeting cookies and get information about targeting cookies in use on our Websites by clicking “Cookie Settings” in the footer of the Website.
You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks at the industry websites below:
Canada: www.youradchoices.ca
UK: www.youronlinechoices.com/uk/
U.S.: www.aboutads.info
Social features and third-party plug ins
Some of our 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. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not receive or store passwords to your third-party social media accounts in this context.
International transfers and personal information
Our Websites are hosted on servers located in the United States or European Union. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions, including the United States and possibly to other jurisdictions (e.g., to your relocation departure and destination location) where we, our affiliates and service providers have operations), which may not provide the same level of protection under your local data protection laws. If you are located, for example, in European Economic Area or Switzerland (collectively, “EEA”) or United Kingdom (“UK”), and we process your personal information in a jurisdiction that has been deemed to not provide an adequate level of data protection (a “third country”), we will implement suitable personal information transfer safeguards.
A. CARTUS CUSTOMERS ONLY – DATA PRIVACY FRAMEWORK
Data Privacy Framework
. Cartus Corporation complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (‘UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Cartus has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal information received from individuals located in the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Cartus has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/
.
The Federal Trade Commission has jurisdiction over Cartus’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Collection, Use, Disclosure and Processing of EEA and/ or Swiss Personal Information
. Cartus collects and processes personal information about current and prospective clients, business partners, suppliers or vendors, service providers or independent contractors, consultants, consumers, website visitors, and other individuals that interact with us. We will process such personal information in accordance with the EU-U.S. DPF Principles, the UK Extension, and Swiss-U.S. DPF Principles (as relevant) and will continue to apply the Principles to personal information received under the application of the DPF. Cartus collects, uses and processes the personal information as explained further above in more detail for the following purposes: the Relocation Purposes; providing support and services; analyzing and improving our business; personalizing content and experiences; advertising, marketing and promotional purposes; securing and protecting our business: defending our legal rights; planning and facilitating business transactions; auditing, reporting, corporate governance, and internal operations; and complying with our legal obligations. Cartus discloses the personal information for the foregoing purposes to the following categories of third party recipients: our service providers, subsidiaries and affiliates; third parties such as independent real estate professionals, moving services providers, immigration and visa service providers to enable them to provide services you request; other third parties to provide you a service you or your employer requested; third parties with whom you choose to let us share information; third parties we work with to provide you with more personalized content, and to track the effectiveness of campaigns and our Services; to other parties as part of any actual or contemplated merger, sale, and transfer of our assets, acquisition, financing or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event; as legally required; or to protect our rights.
Notice and Choice
. Cartus collects personal information directly from individuals in the EEA and UK, and will in accordance with the EU-U.S. DPF Principles, the UK Extension, and Swiss-U.S. DPF Principles (as relevant) provide these individuals with a clear, conspicuous, and readily available notice prior to the collection and processing of the personal information. Further Cartus will provide a clear and readily available mechanism for requesting that their personal information not be used for purposes other than the purposes for which it was originally collected or subsequently consented to by the individual, or disclosed to certain third parties acting outside of a service provider role. With respect to the processing of sensitive personal information or special category data, Cartus will obtain affirmative express consent for the disclosure of such to a third party or the use for purpose other than those for which it was originally collected or subsequently consented to.
Access
. Upon request, and subject to applicable laws, Cartus will grant individuals reasonable access to personal information that it holds about them. In addition, Cartus will take reasonable steps to permit individuals to delete or correct personal information that is inaccurate or processed in violation of the EU-U.S. DPF Principles, the UK Extension, and Swiss-U.S. DPF Principles (as relevant).
Onward Transfers
. To the extent we transfer your personal information to our third party service providers and vendors (as explained in this Privacy Notice), we will do so for limited and specific purposes and obtain contractual assurances from these third parties that they will safeguard your personal information consistent with this Privacy Notice and provide an equivalent level of protection as is required by the Principles. Further we require these third party recipients to notify us, if they make a determination that they can no longer meet these obligations. Cartus recognizes its responsibility and potential liability for onward transfers to its third-party service providers and vendors, and remains liable under the DPF for actions or omissions of its service providers in violation of the Principles, unless it is not responsible for the event giving rise to the damage. Where we have knowledge that a service provider is using or disclosing personal information in a manner contrary to the Principles, we will take reasonable steps to prevent, remedy or stop such use or disclosure.
Data retention
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice 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 and interests or those of others. With respect to the data and files we handle as a processor, we retain this personal information in accordance with applicable law and our clients’ instructions.
Children
Our Websites are not directed to children under the age of 16 (“Children”), and we do not knowingly collect any information, including personal information from Children.
Changes to this Privacy Notice
We may amend this Privacy Notice at any time. If we make any material change in how we collect, use, disclose, or otherwise process personal information, we will prominently post a notice regarding such change on our Websites or by other means we deem appropriate. Any material changes to this Privacy Notice will be effective 10 days after our posting of the updated Privacy Notice or as otherwise required by applicable law. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Notice.