Turnover Intelligence Privacy Policy
Effective Date: March 21, 2019

This Privacy Policy applies to Personal Information processed by Turnover Intelligence in the course of our business, including, TurnoverIntelligence.com, Turnover Intelligence Applications (each a “Site“) and the services provided through the Sites (collectively with the Sites, the “Services“). The terms “Turnover Intelligence,” “we,” “us,” and “our” includes Turnover Intelligence LLC and our affiliates and subsidiaries.

Please note that unless we define a term in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use.

This Privacy Policy contains the following sections:

1. Information Collection and Use
2. Information Sharing
3. Your Choices
4. Individual Rights in Personal Information
5. Information Retention
6. Information Storage and Security
7. Other Important Information

1. Information Collection and Use

This Privacy Policy covers our use of Personal Information. When we say “Personal Information,” we mean information that relates to you and can – either on its own or in combination with other information – identify you as an individual. Personal information does not include information that has been de-identified or aggregated such that you can no longer be identified.

The types of information we collect depend on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services. This Section explains how we collect and use information based on your level of engagement with the Services.

A. All Users of the Turnover Intelligence Sites
From registered and unregistered users of the Sites, we automatically receive and record information whenever you interact with the Sites. This includes IP address data from our server logs, cookie information, browser information, information about your activity while on the Sites (such as the pages you request, properties that you view or save, and property that you claim), and the URL of the site you came to the Sites from. We also may collect the mobile device ID (such as the ID for Advertising on iOS and Android ID on Android) from users of the Turnover Intelligence Applications. If permitted by the settings on your device and with your consent, we will also collect your geo-location information. We use this to provide you with location specific information, such as homes for sale near your current location as determined by your geolocation, and information about listing your home for sale based on your geolocation, or commute recommendations. We may also approximate your location based off your IP address.

We may also use the information listed above to help diagnose problems and performance with the Services, analyze trends, customize your experience, and administer the Services. We may provide IP addresses to third-parties to help us analyze website user survey data. We may also use the information described in this section to better target information about Turnover Intelligence’s Sites and Services, for example, by displaying more accurate or relevant information on our Sites, matching you to a public record listing of a property, tailoring the advertising we display on third party websites and platforms, and sending better targeted and tailored messages, including via email and/or push notifications.

B. Registered Users of the Turnover Intelligence Sites
We may be required to collect certain information, including your name, email address, and/or phone number as a condition of our affiliates’licenses with the multiple real estate listing services (the “MLSs”) in order to allow you to access the full MLS listings. You give us this information when you create your Turnover Intelligence account. When you give us this information at one of our events, or upon your request, we will create a Turnover Intelligence account for you and you agree that this Privacy Policy and our Terms of Use shall apply. In addition, when you are signed in to your Turnover Intelligence account and using Turnover Intelligence through Facebook, Twitter, or any other third-party authorization service, we may make use of the information that they provide us to further customize your Turnover Intelligence experience. We may share Personal Information with such third parties to deliver tailored content both on our Services and on third party sites (e.g., social media sites).

– My CloserSuite™: My CloserSuite™is a feature that allows you to take surveys under the product names: PreferCloser™, FindCloser™ and AffordCloser™, upload residential and commute preferences, needs, wants, and related details about voluntary relocation, save home searches, add favorites and x-outs, and otherwise organize homes that may interest you. We save all of this information for your use later. It is stored with your Turnover Intelligence account information and Service use profile.
– Account Password Security: Your Turnover Intelligence account password is encrypted on our server. It is your responsibility not to disclose your password to other people, and to ensure you maintain its security.
– Account Updates: You can correct, amend, add or delete Personal Information associated with your account. However, even after you update information, we may maintain a copy of the original information in our records.

C. PreferCloser™, FindCloser™, AffordCloser™, Home Tours, Real Estate Classes, and other In-Person Meetings and Consultations
When you submit a PreferCloser™, FindCloser™, AffordCloser™, Consultation orhome tour request, we will ask for your tour date and time preferences, as well as your phone number. We may ask for similar information when you request or attend a home buying or selling class, consultation, or when you request or attend a strategy session or similar in-person meeting with a Turnover Intelligence representative or partner. We may also ask some questions so that our agent can verify your identity, and such information will be used to register you for a Turnover Intelligence account. When you meet up with one of our staff, representatives or agents, they may ask you to verify your identity, and may even ask to see a photo ID.

D. Turnover Intelligence Clients
When you are getting ready to buy or sell a home and you start working with our coordinators, representative, partner and agents, you become a Turnover Intelligence client. As part of the home purchase or sale process, you will need to provide a lot of information as is customary for a home purchase or sale transaction. This information can include, without limitation, your name, address, phone number, email address, commute information, financial or payment information, including without limitation, buyer loan pre-approval documentation and seller property information. We ask you, as a buyer, for loan pre-approvals from a mortgage broker or lender to determine which homes are in your price range, and to help you make an offer more quickly when you do find a home. You, as a seller, may be legally required to disclose certain information about your property to prospective buyers. Once you sign a referral agreement, listing agreement or buyer agreement with us, your relationship with Turnover Intelligence is governed by that agreement, as well as our online Terms of Use and this Privacy Policy.

E. Communications with Turnover Intelligence
Turnover Intelligence may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

F. Marketing
We may send marketing materials to Turnover Intelligence account holders and clients using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. Individuals may also subscribe to Listing Alert Emails or other notifications with information such as customized summaries of homes for sale. If you opt-in to also receive marketing messages, Turnover Intelligence may send you Turnover Intelligence-related news and surveys.

G. Call Recording
We may record any telephone calls between you and our agents or other representatives for training and quality assurance purposes.

H. Surveys
Turnover Intelligence may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information that may include Personal Information.

I. Sharing with Friends or Colleagues
Turnover Intelligence’s Services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request.

J. Interactive Features
Turnover Intelligence may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered “public” and will not be subject to the privacy protections referenced herein. Any content you provide on employer specific channels will be considered confidential unless you authorize it to be considered otherwise.K. De-Identified and Aggregated Information
We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Sites and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purpose.

L. Conferences, Corporate Events, and Trade Shows
We may attend conferences and trade shows where we collect Personal Information from individuals who interact with or express an interest in Turnover Intelligence and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

M. Information We Collect Automatically
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

N. Cookies and Pixel Tags/Web Beacons
We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Sites and Services.

– Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
– Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Sites that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.

O. Information from Other Sources We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

P. Other Uses of Information
We may use any of the Personal Information we collect for the following purposes:

to operate our Sites and provide our Services in accordance with our Terms of Use and/or any other agreement you may have with us;
to respond to your questions or inquiries;
to conduct promotional activities, including contests;
to undertake internal research for technological development and demonstration;
to improve, upgrade or enhance our Sites and Services;
to send you informational or promotional communications that you have agreed to receive;
to carry out other purposes that are disclosed to you and to which you consent;
to detect security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
to identify and repair errors that impair existing intended functionality;
to undertake activities to verify or maintain the quality or safety of a Service;
to pursue our legitimate interests where your rights and freedoms do not outweigh these interests; and
to carry out automated decision making and/or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to do so.

2. Information Sharing

We may share your Personal Information as set forth below:

A. Public Record Information
Please be aware that home sales and purchases may be a matter of public record, and your name and address, others with whom you share a title such as a spouse, the price you paid, your property taxes, and other information may be available from public sites regardless of the brokerage(s), if any, who assist in the transaction. We post on our Sites some information that typically becomes part of the public record of a home sale or purchase.

B. Non-Public Record Information
We share information obtained from you, MLSs and other third party sources that is not on the public record to facilitate your home purchase or sale transaction. This includes:

Service Providers to all Turnover Intelligence Clients: Our agents work with third parties to process your home search and sale transaction, and must share your information with those third parties. Examples include MLSs and providers of software used for document preparation and electronic signing.

Partner Agents: A Partner Agent is employed by or works with another brokerage and is not a representative or employee of Turnover Intelligence. Partner Agents have contracted with us to provide Turnover Intelligence-quality service to a wider range of customers. We’ll refer you to a Partner Agent in our discretion. If you are referred to a Partner Agent for your home purchase or sale transaction, we share your information with that Partner Agent so they can assist you. Turnover Intelligence is not responsible for the work performed or the services provided by Partner Agents in any manner. Notwithstanding, we may give them support and information that we deem in our soul discretional appropriate for them to help you.
Home Seller Service Providers: As is customary as your home sales agent, we share your listing information with MLSs and other listing websites, such as Realtor.com, Trulia.com and Zillow.com. As a result, your listing may appear on more than one website. We may also share your listing and contact information with listing vendors such as photographers, home staging experts and home repair professionals like plumbers and electricians, as needed.
Home Buyer Service Providers: As is customary, your home purchase agent may share your buying information with inspectors, title companies, escrow agents, closing attorneys, lenders, and other third parties as needed to process your transaction. Potential Buyers: By law, we may be required to disclose certain information about your property to potential buyers.

C. Negotiations
Your agent may also post price offers and counteroffers on real estate sites. We do not post your name on our Sites without your permission but if your sale is closed, the price and the fact that you bought or sold your house at that price may be a matter of public record.

D. Turnover Intelligence Corporate Family
We may share your information with members of the Turnover Intelligence family of entities for various purposes, including to: (i) provide the Services to you; (ii) help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; (iii) help with marketing initiatives; and (iii) manage and improve Turnover Intelligence products, Sites, Services and tools.

E. Turnover Intelligence Requests
Through the Services, you can make a request to tour a home, get in contact with a real estate agent, receive help selling or buying a home, or submit other requests. When you make such a request through Turnover Intelligence, you authorize Turnover Intelligence to share your Personal Information including your contact information, home search history, favorites and saved searches, with a real estate professional (a Turnover Intelligence Agent or staff member, or a Partner Agent) for the purpose of responding to your request.

F. Service Providers
We may share your Personal Information with third-party service providers that assist us in providing the Services. We use reasonable efforts do so with the appropriate contractual protection in place to ensure that your Personal Information is protected and used only in accordance with this Privacy Policy.

G. Business Partners
We may provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services.

H. Third-Party Cookies and Information Used to Target Ads to You
We may share the information that we collect about you with others (including advertising networks and service providers) to tailor and serve you ads on our Services, as well as other websites and social media networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” These advertising networks track your online activities over time by collecting information through automated means, including through the use of Technologies (e.g., cookies, web-beacons and other methods). This allows Turnover Intelligence to target our advertising to you through demographic, behavioral and contextual means. As a result, you may see ads for Turnover Intelligence on other websites and social media.

I. APIs and SDKs
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

J. Information Disclosed in Connection with Business Transactions
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. K. Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.

L. Other Purposes
Turnover Intelligence may share your Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

3. Your Choices

A. General
You may have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use Personal Information regarding your activities on our Sites, Services and/or information from the advertisements on third party websites for other legal purposes as described above.

B. Electronic Messages, Phone Calls and other Communications
If you receive an unwanted email from Turnover Intelligence, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Use or this Privacy Policy).

C. Opting-Out of Technologies and Tracking

– Turnover Intelligence Cookies: We put Turnover Intelligence cookies on your device’s browser to help us keep track of when you were last on the Sites, and what you last searched on the Sites. While you are free to disable cookies on your browser, we recommend that you leave cookies activated to use some of the most useful Turnover Intelligence features.
– Third-Party Cookies for Analytics: We may use third parties such as Inspectlet, comScore and Google to help us analyze how people are using the Services, and those third parties are authorized to use Technologies to access Personal Information regarding visitors to the Sites.

Inspectlet. Inspectlet’s access to and use of your Personal Information is governed by Inspectlet’s Privacy Policy.

Google Analytics. We use the Google Analytics service to provide us with demographic data about our users on a de-identified basis. This Google service uses a cookie that can be recognized by Google or its affiliate DoubleClick when you visit other websites. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

– Opting Out of Turnover Intelligence’s Interest-Based Advertising: If you do not want Turnover Intelligence to collect, use and share information about you to deliver interest-based advertising, please follow the opt-out instructions in correspondence you receive. Please note that most opt-out mechanisms are cookie-based and will only affect the specific computer (including mobile device) and browser that is used to submit an opt-out request. If you have multiple computers or change computers, or use multiple browsers, you will need to submit opt-out requests for each such computer or browser. In addition, if you delete, block or otherwise restrict cookies, you will need to renew your opt-out choices to ensure that any opt-out cookies remain effective.
– Opting Out of Interest-Based Advertising Generally: The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. Please note you must separately opt out in each browser and on each device.
– Opting Out of Mobile Device ID Tracking : Mobile device users may opt-out of receiving some interest-based advertising in their mobile apps by following the instructions for Android and iOS. Please note that precise instructions may vary by device.
– Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
– Flash Cookies Flash Cookies:Turnover Intelligencedoes not currently use flash cookies, but we may in the future. To control flash cookies, click here. Please note that flash cookies do not reside in your browser, so your browser settings will not affect them.

D. Mobile Devices
We may send you push notifications through the Turnover Intelligence mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Turnover Intelligence may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

E. Delete your Account
You may delete your Turnover Intelligence account using our “Close Account” links in correspondence with you. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. Turnover Intelligence may be required to keep a copy of your Personal Information in accordance with Section 5 below.

4. Individual Rights in Personal Information

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by Turnover Intelligence, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Turnover Intelligence may take steps to verify your identity before fulfilling your request.

5. Information Retention

Turnover Intelligence retains the information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

6. Information Storage and Security

Turnover Intelligence is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

7. Other Important Information

A. Children
The Sites and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us at the email address below with the subject line “COPPA Child Information Request.” If we learn that we have collected any Personal Information from a child in violation of applicable law, we will promptly take steps to delete such information.

B. Supervisory Authority
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

C. Links to Third Party Sites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Sites or other Services. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. Turnover Intelligence does not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

D. Changes to this Privacy Policy
Turnover Intelligence may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

E. Contact Us
If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

Attn: Legal Dept.
Turnover Intelligence LLC
921 North J Str, Ste. 1000
Tacoma, WA 98403

webmaster@TurnoverIntelligence.com

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