190marshall.com Privacy Notice for United States and EU Residents
Last modified: May 24, 2018.
'Personal data' means any information relating to an identified or identifiable natural person ('data subject'). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Categories of Data Obtained Directly from You
190marshall.com obtains personal data from you during signup including your name, email address, property addresses, telephone numbers, and payment card information. We collect name, email and phone number from visitors to the real estate websites you create using our platform if these visitors choose to enter it into our online lead collection forms. We collect this information when you or the visitors to your websites:
Register for an 190marshall.com account, or subscribe to any 190marshall.com email newsletter.
Email, text or otherwise share a property from any of the Services.
Contact us for information or ask a question.
Post, upload, or otherwise submit any data from our web forms, or other content ("User Materials") to 190marshall.com.
If you choose to participate in a survey, we may ask you to provide your date of birth, gender, education level, information about your employment, income level and other information.
Information Obtained Automatically Through Technology
Depending on which Services you use and how you access them, the information collected automatically through technology, such as access logs, cookies, pixels and other tracking technologies, may include:
Purposes for Processing of Personal Data
190marshall.com processes your data in order to:
Manage, administer, promote, analyze and improve the Services and our communications, including measuring and analyzing user traffic and usage patterns. Respond to your questions or messages and fulfill your requests for services. Customize the content you see and hear on our Services.
Sharing Your Personal Data190marshall.com may share your personal data with the following categories of recipients:
190marshall.com's authorized service providers to provide services on our behalf. 190marshall.com's authorized third-party applications to provide certain Services to you on the third-party applications. 190marshall.com's analytics partners such as Google Universal Analytics, Google Analytics Demographics and Interest Reporting, DoubleClick for Publishers and others. If we sell a Service or in the unlikely event of bankruptcy.
190marshall.com is required to demonstrate a lawful basis for the processing of personal data. 190marshall.com relies on legitimate interest to process data for the following purposes:
Your personal data is retained no longer than is reasonably necessary to perform the processing described in this Notice and in case of any legal claims or complaints, or as required by law.
Subject to exemptions under applicable law (which may include, depending on the circumstances, U.S. law protecting the rights to free speech and free press or EU law protecting the rights to freedom of expression or information, including processing for journalistic purposes), you have the following rights with respect to your personal data:
To request a copy of your personal data which 190marshall.com holds; To request that 190marshall.com provide you access to and/or rectify personal data that is inaccurate or out of date; To request erasure of your personal data where it is no longer necessary for 190marshall.com to retain it; If you have consented to processing, the right to withdraw consent at any time; To request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable. This right of portability only applies where the processing is based on consent or is necessary for the performance of a contract and if 190marshall.com processes the data by automated means; To request a restriction on further processing where applicable; The right to object to processing if the processing is based on legitimate interest, is for direct marketing, or is for scientific/historical research and statistics; To lodge a complaint with a supervisory authority. You may exercise these rights by contacting 190marshall.com at email@example.com, providing the email address you used to register with 190marshall.com, and stating your specific request in writing. 190marshall.com reserves the right to verify your identity and confirm your right to the information. The following options are also available:
Transfer of Data Abroad
If you reside outside the US: 190marshall.com operates the Services from the US, your personal data may be transferred to the US and/or to countries or territories outside the EEA or Switzerland not recognized by the European Commission as ensuring an adequate level of protection pursuant to the GDPR. Where required, data transfers will be made subject to the terms of the applicable EU Standard Contractual Clauses or with your consent. 190marshall.com will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Privacy Notice in respect of such transfer.
190marshall.com employs physical, technical and organizational safeguards to ensure an appropriate level of security for personal data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and security for the rights and freedoms of natural persons,
Automated Decision Making and Analysis
190marshall.com and its data analytics and sponsorship vendors analyze user interactions with the Services to deliver personalized content to users and to serve personalized sponsorship messages. This includes tracking user preferences with respect to listening data, websites visited, Member station chosen, and search terms in order to derive a user's interests and preferences. The consequences of such processing for the data subject are that the data subject receives content that may be of interest to him or her, as well as email, online and in-app messages from 190marshall.com and 190marshall.com's sponsors that are geared towards the interests and preferences of the data subject.
You must be at least 18 years of age to submit any User Materials or Personal Data on or through the Services, create a public profile, or participate in any online contests. If your child is under age 16 and has provided personal data to the Services, please contact us at firstname.lastname@example.org for deletion of the data.
If 190marshall.com plans to use personal data for a new purpose, it will update this Notice and communicate the changes to individuals before starting any new processing.
Statement Regarding Cookies and Other Tracking Technologies
We use the following types of cookies for the purposes set out below:
These cookies allow our Services to remember choices you make when you use them, such as remembering your Member preferences and remembering your account details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the 190marshall.com Services.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Services and how users interact with the 190marshall.com Services. The information collected includes the number of visitors to the 190marshall.com Services, the websites that referred visitors to the 190marshall.com Services, the pages that they visited on the 190marshall.com Services, what time of day they visited the 190marshall.com Services, whether they have visited the 190marshall.com Services before, and other similar information. We use this information to help operate the 190marshall.com Services more efficiently, to gather broad demographic information and to monitor the level of activity on the 190marshall.com Services.
Targeted and Sponsor Cookies
These cookies track your browsing habits or other information, such as location, to enable us to show sponsorship credits which are more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, sponsors can place cookies to enable them to show sponsorship credits and other messages that we think will be relevant to your interests while you are using third-party services.
Social Networking Service Cookies
These cookies are used when you share information using a social media sharing button or you link your account or engage with our content on or through a social networking service such as Facebook, Twitter or Google+. The social networking service will record that you have done this.
Additionally, we use these technologies:
190marshall.com and its service providers also may use pixel tags, alone or in conjunction with cookies. A pixel tag, also known as a web beacon or clear GIF, is an electronic image that can be used to recognize certain information on your device, such as cookies, the time and date a web page is viewed, or a description of where API content is placed. Cookies and these other tracking technologies enable us to assign a unique number to a user's device, and relate information about a user's use of the 190marshall.com Services to other information about the user, including personal information. These technologies also enable 190marshall.com and its service providers to recognize you when you access the 190marshall.com Services using different computers, devices or browsers.
We also may use Flash cookies (which are also known as Flash LSOs) on the 190marshall.com Services to collect and store information about your use of the 190marshall.com Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with certain of the 190marshall.com Services.
Web Accessibility Policy
190marshall.com is committed to making websites built by our platform accessible to all users, including those with disabilities. Our goal is to provide an accessible website that conforms to Section 508 Guidelines and the World Wide Web Consortium’s Accessibility Guidelines (WCAG) 2.0 Level AA. Some existing content may not be in compliance, and some content may meet only the minimum required compliance standards. 190marshall.com customers must notify us of any accessibility issues they discover on their existing websites and continue efforts to monitor and notify us of any unacceptable compliance levels. While every effort will be made, it is understood that creating accessible formats for some website content and graphical renderings maintained by 190marshall.com may be technologically unfeasible, impractical, or creates an undue hardship to 190marshall.com’s operations.
We continue to make every effort to test the websites created by the 190marshall.com platform and to remove barriers that prevent persons with disabilities from interacting with or accessing information made available on our websites. If we become aware of content that does not conform to the WCAG 2.0 Level AA standards, we will make reasonable good faith efforts to make the content conform to the standards. 190marshall.com customers must let us know if they encounter difficulty with 3rd party sites we link to so we can pass the information along to the owners of those websites. 190marshall.com customers should also contact owners of any 3rd party websites to address concerns directly to these third parties.
While this policy does provide the standard for individuals with disabilities to access Web-based information, this policy cannot anticipate every accessibility need, due to known limitations of existing technology. There may be other circumstances, independent of technology that may limit the accessibility of 190marshall.com's websites.
Adobe Acrobat is required to view and print PDF documents that appear on 190marshall.com websites. Download the latest free version of Adobe Reader in order to improve the viewing of these files. 190marshall.com customers must notify us if they believe any PDF content does not meet web accessibility standards.
While we strive to adhere to the accepted guidelines and standards for accessibility and usability, it is not always possible to do so in all areas of the website, particularly as it relates to content by third parties. 190marshall.com are not responsible for ensuring that third-party content, software/tools, widgets, Add-ins, APIs, etc., which are not owned by 190marshall.com but are otherwise located on or linked to 190marshall.com and any websites created by the 190marshall.com platform, conform to WCAG 2.0 Level AA, and shall not be liable if they are inaccessible to individuals with disabilities.