Last Updated December 2nd, 2020
LISTTRAC provides analytics services for the benefit of our business customers, giving them the ability to understand Internet users and consumers who are interested in their real estate listings. LISTTRAC provides these services to customers such as real estate brokers and multiple listing organizations (“Partners”).
When a user visits one of our Partner’s websites (“Partner Sites”), views an email from a Partner with a LISTTRAC tag, or uses an app with the LISTTRAC SDK installed, we associate a pseudonymous identifier (a random, unique string of characters) with the user, such as through cookies, tags and resettable mobile advertising identifiers or mobile device IDs. A cookie is a small data file that is sent to your computer when you visit a website as an example. Tags (also known as pixel tags or web beacons) are tiny graphics that are embedded invisibly on web pages and emails. Tags are typically used in conjunction with cookies to collect information about user activity. Mobile device IDs are user-resettable advertising identifiers such as Apple’s IDFA and Google’s Android Advertising ID. When a cookie expires, we no longer use that cookie to collect new information, but we may keep and continue to use the information previously collected. Our tags do not collect your name, user name, email address or physical address, but we may store and associate a hashed email address or a mobile device ID with the tag data we collect. Through these identifiers, we can collect information about what the user does on the Partner website or application, and which Partner sites or apps the user visits. LISTTRAC may engage in cross-device data collection and targeting, when the relevant data is collected.
The information we collect may serve to identify a user’s computer or device or browser, and we may associate that information with other data we receive from our Partners and our Partner websites and apps about the user, including the following:
LISTTRAC does not use this information to identify you directly. We may also aggregate and anonymize information.
We do not knowingly collect or categorize consumers based upon sensitive information, such as racial or ethnic origins, political or religious beliefs, financial information, precise information about health conditions or treatments or other similar or related information.
We neither intentionally collect information from, nor target any services to, children under 13 years of age. If we learn that we have collected information of a child under 13, we delete that information as soon as possible.
We use the information to create analytics around real estate listing trends or the effectiveness of media and content marketing. For example, we may provide analytics on home buyer interest in different regions of the country. We also use the information we receive from our Partners to allow advertisers to present advertisements or other personalized content that might be interesting to a consumer. For example, if any pseudonymous identifier is associated to viewing homes on a golf course on a website run by one of our Partners, we may predict that the identifier might belong to a person interested in golfing equipment.
We may share collected information that we receive from our Partners’ websites with the Partner that permitted us to collect the information.
We sometimes make our collected data available, in aggregated or anonymized format, to our advertising clients, business customers and business partners, and other third parties, for data analysis purposes.
We reserve the right to disclose information we receive to government or law enforcement officials or to private parties as we, in our sole discretion, believe necessary to (i) to satisfy or comply with any applicable law, regulation or legal process; (ii) to respond to lawful requests, including subpoenas, warrants or court orders; (iii) to protect our property, rights, and safety and the rights, property and safety of third parties or of the public in general; and (iv) to prevent or stop activity we consider to be illegal or unethical.
If you provide information such as your name, address, and email address to us, whether by contacting us through one of the LISTTRAC Sites, or by sending it to one of our contact email addresses, we will store that information in our database and will use that information only for replying to you. We will not use your information for marketing purposes, unless you specifically authorize it. You may opt out of receiving such emails by clicking on the “unsubscribe” link contained in our marketing emails.
We may also keep track of basic log data for visitors to our sites, like the IP address, operating system, browser type, website visited prior and other collected information. We do not permit third parties to collect any information from you through our site. If you would like more information about this practice and how to control how this information could be used by third parties, please follow one or both of these links: NAI opt out; and DAA opt out.
LISTTRAC cares about your privacy and employs administrative, physical and electronic measures designed to protect your information from unauthorized access. These measures may include encryption of information you provide and employment of information storage security technologies to block access from outside our network. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. Please also be mindful that we are not responsible for the security measures of third parties, e.g. our Partners. As noted above, for more information about their information collection and usage practices, please see their respective privacy policies.
We do not use any collected information we obtain through cookies to identify you. We do not link the information we store in cookies on LISTTRAC Partner sites to any collected information you submit while on one of the LISTTRAC Sites. LISTTRAC may obtain data from third-parties and combine it with data collected from LISTTRAC Partner sites.
In addition, to the extent permitted by applicable law, we retain the respective sets of information received through the LISTTRAC Partner Sites and through the LISTTRAC Sites for as long as needed to fulfill a legitimate business need. We retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Anyone who has provided information to us through the LISTTRAC websites may email us at firstname.lastname@example.org to request that we update, delete, and/or correct his or her information. We will respond to each such request within a reasonable time. Even after a deletion, some information may remain temporarily in back-up copies until the next back-up rotation or overwriting cycle.
We participate in the Network Advertising Initiative (NAI) and the Digital Advertising Alliance’s (DAA) Self-Regulatory Program. Each of these programs provides an opt-out feature where consumers can choose not to receive targeted advertising from NAI or DAA affiliates. These links will take you to the NAI opt out and the DAA opt out.
We also participate in the DAA’s Ad Choices program, which enables you to control whether, and if so, to what extent, you receive interest-based advertising. You can exert such control by clicking on the AdChoices Icon on a Web page or near a Web banner ad. To learn more, visit the AdChoices FAQ page.
Remember that opting out is browser-specific. So, if you have multiple browsers or multiple devices you use to access the internet, you’ll need to opt out from each device or browser.
For Android Devices (version 8.0 and higher): Open the Settings app, Select Google, Select Ads, and enable the “Opt Out of Ads Personalization” setting.
For Apple Devices: Devices with iOS 6 and above use Apple’s Advertising Identifier. To learn more about limiting ad tracking using this identifier, visit the Settings menu on your device as follows: Go to Settings, Select Privacy, Select Advertising, and enable the “Limit Ad Tracking” setting. For more information about different iOS versions, please see: https://support.apple.com/en-ie/HT202074.
When you have opted out using this setting on a device, and when ListTrac receives this signal, ListTrac will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.
Note: The specific opt-out instructions for each device may differ slightly depending on which version of the operating software you are running.
As required by applicable law, including the U.S.-E.U. Privacy Shield Framework, upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may request this information by emailing us at email@example.com. If you are our partner or customer and your information changes, or if you no longer desire our service, you may correct, update, amend or remove information by contacting us at firstname.lastname@example.org. We will respond to these requests within a reasonable timeframe.
Our use of information collected through our service shall be limited to the purpose of providing the marketing or analytics services for which our Partner has engaged LISTTRAC. LISTTRAC collects and processes information under the direction of its Partners, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Partners and would no longer like to be contacted by one of our Partners that use our service, please contact the Partner that you interact with directly.
Your information may be kept on computers located outside of your state or country, where the privacy laws may not be as protective as those where you live. If you’re located outside the United States and choose to provide your data to us, we may transfer your data to the United States and process it there. If you reside in the EU, please review EU-U.S. Privacy Shield sections below.
LISTTRAC is also a participant in the Digital Advertising Alliance’s (DAA) Self-Regulatory Program for Online Behavioral Advertising and follows the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. The DAA also provides a global opt-out feature that lets users choose not to receive cookies from companies that are DAA members.
LISTTRAC adheres to the Internet Advertising Bureau (“IAB”) Europe’s Good Practise Principals for Online Behavioural Advertising as well as the European Interactive Digital Advertising Alliance’s (“EDAA”) principles.
LISTTRAC (which shall include entities and subsidiaries covered by LISTTRAC’s privacy shield certification) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. LISTTRAC has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Privacy Shield Framework or view LISTTRAC’s certification, visit the U.S. Department of Commerce’s Privacy Shield website at [https://www.privacyshield.gov/list].
LISTTRAC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. LISTTRAC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU. LISTTRAC remains liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such personal data on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, LISTTRAC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, LISTTRAC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and use our Services. This notice supplements the information in the above Privacy Notice. Certain terms used below have the meanings given to them in the CCPA.
The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information collected by LISTTRAC:
Categories of Personal Information We Collect About You
The categories of personal information we may have collected about you or your use of our Services are:
More details on the personal information we may collect are set forth in Information Collected From LISTTRAC Sites
Categories of Sources from Which We Collected Personal Information
The sources from which we may have collected personal information about you or your use of the Services are:
and as described in more detail in Information Collected From LISTTRAC Sites
Business or Commercial Purposes for Which We Collected or Sold the Personal Information
The business or commercial purposes, as defined under the CCPA, for which we collected or sold the personal information are:
More details concerning the business and commercial purposes are set forth in How Information Is Shared . We may disclose the categories of personal information identified in this California Privacy Notice about our California consumers for our operational purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.
Categories of Third Parties with Whom We Shared the Personal Information
The categories of third parties, as defined by the CCPA, with whom we share personal information include our subsidiaries and affiliates; business partners, data analytics providers and third-party marketers (who may combine your personal information with their own records and records available from other sources), for their own business or direct marketing purposes, and the direct marketing purposes of other third-party marketers.
Categories of Personal Information Sold, Shared or Disclosed for a Business Purpose We may sell or disclose for a business purpose (each as defined under CCPA) any or all of the personal information collected from and about you as set forth in Information We Collect From LISTTRAC Sites .
Your California Privacy Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
California customers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third-parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
If you would like to exercise any of these rights, please email us at email@example.com You will be required to verify your identify before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
You also have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior, to deliver targeted advertising. If you would like to opt out, you may email us at firstname.lastname@example.org