Cartus Corporation Global Relocation Products & Services Resource Hub Blog Contact Us Login s Privacy Policy Privacy Statement Last modified 28 Jul 2016 We at Cartus Corporation recognize the importance of protecting the privacy of personal data ("Information") collected by us. This Privacy Statement discloses what Information we gather, how we use it, and how to correct or change it. Information obtained and shared with you through this web site is our confidential information unless expressly indicated otherwise. Information may be requested/collected to enable the delivery of our services, to operate our business and to make the experience of using this site faster and more effective. By using this web site, you consent to the terms of our Privacy Statement and to Cartus’ processing of Information for the purposes stated above, as well as those explained where Cartus collects Personal Information on the web. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT, YOU CANNOT USE THE SITE. Should our Privacy Statement change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on our web site for a reasonable period of time. Scope of this Privacy Statement This Privacy Statement applies to the following sites only: www.cartus.com, online.cartus.com, www.cartusnetworks.com, www.cartusvirtualresources.com, www.cartusmoves.com, and www.myaffinityservices.com. We do not own, operate or control the web sites of our third party service providers. Accordingly, this Statement does not apply to a third party web site or to a third party service provider’s collection, use, storage and disclosure of your personal Information. The site contains links to third-party web sites. When you click on those links, you will go to a third-party site where you will be subject to that site’s privacy statement and we encourage you to read that policy statement. Please be aware that we are not responsible for the privacy practices of those other web sites and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information by those third parties. Cartus has in the past received TRUSTe’s Privacy Seal signifying that our Privacy Statement and our practices had been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. Cartus has submitted this revised Privacy Statement for review by TRUSTe in order to ensure compliance with the TRUSTe program. The TRUSTe program covers only information that is collected through these web sites: www.cartus.com, online.cartus.com, www.cartusnetworks.com, www.cartusvirtualresources.com, www.cartusmoves.com, and www.myaffinityservices.com and does not cover Information collected through our mobile application and downloadable software. The use of Information collected through our service shall be limited to the purpose of providing the service for which our Client has engaged Cartus. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request. Cartus collects Information in order to operate our business of providing relocation, assignment management and real estate related services. We may transfer Information to companies, which may include our affiliated companies listed below, and others that help us to provide our services. In some cases, Cartus acts solely as a processor of the Information at the direction of our client. In those instances, an individual who seeks access to, or who seeks to correct, amend, or delete inaccurate Information should direct his query to Cartus, and Cartus will review with the client (the data controller) and respond within a reasonable timeframe. We will retain Information for as long as needed to provide our services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 1. What is Personal Information? Personal Information is information collected by Cartus that identifies the person to whom such information pertains, including without limitation: name, address, telephone number, and e-mail address. 2. Collection and Use of Your Information 2(a). Personal Information While most of the Information collected by Cartus is supplied by our clients, our suppliers, and our customers as part of the relocation process, we may, at times, ask you to (or you may voluntarily in CartusOnline) update or confirm a subset of that Information on this web site. To do this, you may be asked to register to use this site. Additionally, your Information may be shared with our affiliates listed below, and third party suppliers (e.g. home inspectors, moving companies) where necessary to support the services we deliver. This Information will be used solely for the purposes of providing services in accordance with our contracts with our clients, which may include making Information available to your employer or membership group. In addition, we may collect Personal Information from our suppliers and from client and potential client contacts. That Information may be used by Cartus to market and/or provide our services to those clients and potential clients. We will share your personal Information with our affiliates listed below and with third parties only in the ways that are described in this Privacy Statement. We remain responsible for the handling of your personal Information by those affiliates and third parties as provided in the U.S.-EU Privacy Shield Framework Principles, including the Supplemental Principles. Cartus may disclose personal Information about you in special cases when we have reason to believe that disclosing this Information is necessary to identify, contact or bring legal action against someone who may be violating Cartus' terms of use or terms of service, or may be causing injury to or interference (either intentionally or unintentionally) with any of Cartus' rights or property, other Cartus Customers, or anyone else. Cartus may disclose or access a Customer's personal Information when we believe in good faith that the law permits it, as required by law, such as to comply with a subpoena and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services. Our Affiliates Our affiliates who may receive personal Information for the purposes described above are CARTUS RELOCATION CANADA LIMITED, CARTUS SARL, CARTUS BRASIL SERVIÇOS DE RELOCAÇĂO LTDA, CARTUS SAS, CARTUS LIMITED, CARTUS B.V., CARTUS CORPORATION PTE. LTD., CARTUS RELOCATION HONG KONG LIMITED, CARTUS INDIA PRIVATE LIMITED and CARTUS REAL ESTATE CONSULTANCY (SHANGHAI) CO., LTD. Each of those affiliates is committed to complying with the U.S.-EU Privacy Shield Framework Principles, including the Supplemental Principles Data Retention We will retain your information for as long as your account is active and thereafter in accordance with our data retention policies. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us as specified in Contacting Us/Correction/Updating personal Information. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. Registration for Personalized Services If you wish to use Cartus’ personalized services, you may be asked to create an account or enroll as a delegate authorized by an existing account holder. The process of creating this account or enrolling as a delegate necessitates that you provide personal Information about yourself. If you choose to provide us with your personal Information on the web, we may transfer that personal Information within Cartus or to Cartus’ third-party service providers, including locations across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Cartus strives to comply with all applicable laws worldwide that are designed to protect your privacy. Although legal requirements may vary from country to country, Cartus intends to adhere to the principles set forth in this Privacy Statement even if, in connection with the above, we transfer your personal Information from your country to countries that may not require an "adequate" level of protection for your personal Information. In other words, our goal is to provide protection for your personal Information no matter where that personal Information is collected, transferred, or retained. Requests for Periodic Industry Updates If you request Periodic Industry Updates, we collect Personal Information, which is submitted directly to our web hosting services vendor’s system to create automatic e-mails to people who choose to subscribe. The information we collect is not used in any other way and is not retained once you end your subscription to Periodic Industry Updates. Requests to Find or List a Property and to Find a Sales Associate If you submit a request through this site to find or list a property or to find a real estate agent, you will be asked to provide personal Information and we refer this information to real estate agents to respond to your request. For example, if you ask that we list your property or if you ask to see more listings in a given area, you will be directed to a real estate agent in that area. Voice Recording In addition, telephone calls to or from Cartus may be recorded. Phone call participants are advised at the commencement of services that their participation in telephone calls to or from Cartus, whether or not an announcement is made at the time of the call, grants all rights of permission of the participant(s) to Cartus to record calls and utilize such recordings for its business purposes. The participant is advised to notify and obtain recording consent from any family members or others who may communicate with Cartus as part of a relocation or other parties that participant conferences in or requests Cartus to conference in to any telephone calls with Cartus. 2(b). Non-Personal Information Even if you do not send us any personal Information, we collect information about how you use our site (“Non-Personal Information”). This information cannot be used to identify you personally and is explained in more detail below. What is Non-Personal Information? Like many sites, we obtain Non-Personal Information automatically and store it in log files, such as: IP (internet protocol) addresses, browser types, the name of a user’s ISP (internet service provider), information about where a user comes from before arriving at our site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor performs this service for us by sending a cookie to gather this information, compiling it, and reporting to us. We may combine this automatically collected log information with other information that you voluntarily provide. We do this to improve the services we offer you, to improve marketing, analytics or site functionality. Use of Non-Personal Information We use Non-Personal Information to improve our services, conduct research, and provide anonymous aggregated reporting for internal audits and third-parties. Tracking Technologies Technologies such as: cookies are used by Cartus and our marketing partners and analytics providers. These technologies are used in analyzing trends, administering the site, tracking users’ use of the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies for session control and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. Behavioral Targeting / Re-Targeting Our third party partner may use technologies such as cookies to gather information about our site visitors in order to collect information on their browsing activities and interests. Local Storage (HTML5) Third parties with whom we partner to provide analytics or tracking may use Local Storage such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML 5. 2(c). Use of Information With Respect to Third Parties We reserve the right to share your personal Information with our clients, affiliates listed above and third party service providers, as permitted by law, in order to help us deliver our services. Cartus may also disclose Customer’s personal Information if Cartus is involved in a merger, acquisition, or sale of all or a portion of its assets, in such case, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal Information, as well as any choices you may have regarding your personal Information. Service providers are also an important means by which Cartus maintains its web site and mailing lists. Cartus will take reasonable steps to ensure that these third-party service providers are obligated to protect personal Information on Cartus’ behalf. Cartus does not intend, without your consent, to transfer personal Information to third parties who are not bound to act on Cartus’ behalf unless such transfer is legally required. Similarly, it is against Cartus’ policy to sell, without consent, personal Information collected online. Social Media Widgets Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing it. 3. Location of Servers and Transfer of Information to the United States The site is hosted by servers in the United States, and, as such, the site is governed by United States law. If you are located outside of the United States, your personal Information will be transferred to the United States. By submitting your personal Information, you consent to its transfer to the United States and to its storage, processing, and use there in accordance with this Privacy Statement and United States law. 4. Compliance with Privacy Shield and Independent Recourse Mechanism; Federal Trade Commission Jurisdiction Cartus complies with the U.S.-EU Privacy Shield Framework Principles, including the Supplemental Principles and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce (collectively, the “principles”). Cartus has certified that it adheres to the Principles. To learn more about the Principles and to view Cartus’ certification, please visit: http://www.commerce.gov/privacyshield/ If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request. This is a free, US based resolution method. Where applicable for employee matters, Cartus commits to cooperation with the panel of the EU Data Protection Authorities (DPAs), the state or national data protection authority where the employee works or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, to investigate unresolved complaints. Cartus is subject to the investigatory and enforcement powers of the Federal Trade Commission and agreed to binding arbitration at the option of an individual with an unresolved privacy or data use concern. Once arbitration is invoked, in some cases the individual may lose the option to seek relief for the same claimed violation in another forum. For more information about binding arbitration please visit: http://www.commerce.gov/privacyshield/. 5. Security Cartus maintains its systems in accordance with reasonable industry standards to reasonably secure the Information of its customers against unauthorized access, accidental or intentional manipulation, and loss. However, no data transmission over the Internet can be guaranteed to be 100% secure, and you use the site at your own risk. Blogs www.cartus.com/en/blog offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at InformationProtection@cartus.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. 6. Children This site is not directed to children under the age of 13 (“Children”), and we do not knowingly collect any information, including personal Information, from Children. 7. Changes in this Privacy Statement If we decide to change our Privacy Statement, we will post those changes to this Privacy Statement here, and any other places we deem appropriate so that you can be aware of what Information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Statement at any time, so please review it frequently. If we make material changes to this Statement, we will notify you here or by other means we deem appropriate, prior to the change becoming effective. 8. Contacting Us/Correction/Updating Personal Information A Customer may contact us through the methods stated below for a number of purposes, including: (1) if you no longer wish to use the site; (2) to opt-out of communications or unsubscribe from any industry updates as described in “Requests for Periodic Industry Updates”; (3) to receive information or special offers; (4) to provide feedback and comments on this Statement; (5) to request access to, deletion of incorrect information or correction of the Customer’s Personal Information; and (6) to make inquiries or complaints regarding our Privacy Statement and/or privacy practices. By email to: InformationProtection@cartus.com By mail: Privacy Officer, Cartus, 40 Apple Ridge Road, Danbury, CT 06810. By phone: (203) 205-1540 We will respond to your request within a reasonable timeframe, but in no event later than 45 days. 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