Last modified 09 October 2020
OVERVIEW OF OUR COLLECTION AND USE OF PERSONAL INFORMATION
Categories of Personal Information Collected. Generally, we collect the following types of personal information:
- Identifiers: includes direct identifiers such as a real name, alias, address, user ID, username, account number; phone number, unique personal identifier, online identifier, IP address, app ID, email address, account name, social security number, social insurance number, driver's license number, passport number, or other similar identifiers.
- Customer records: includes personal information that individuals provide us in order to obtain our products and services, such as name, account name and number, signature, contact information, employment information, social security number, social insurance number, passport number, driver's license and other government identifiers, insurance information and financial information. For example, this may include information collected when an individual registers for our services.
- Commercial information: includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
- Usage Data: includes browsing history, clickstream data, search history, and information regarding a resident's interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.
- Geolocation data: includes precise location information about a particular individual or device.
- Audio, video and other electronic data: includes audio, electronic, visual, thermal, olfactory, or similar information such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices), photographs you provide to us, and call recordings (e.g., of customer support calls).
- Professional Information: includes professional or employment-related information.
- Education information: includes information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).
- Inferences: includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, behavior, or other characteristics. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers who participate in our loyalty programs, so that we can better reach them with relevant offers and ads.
Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:
- Providing support and services
- Safety, recall and warranty
- Analyzing and improving our business
- Personalizing content and experiences
- Advertising, marketing and promotional purposes
- Securing and protecting our business
- Defending our legal rights
- Auditing, reporting, corporate governance, and internal operations
- Complying with legal obligations
Individual rights. Please see the Individual Rights and Choices section below for a description of the choices we provide and the rights you have regarding your personal information. If you are a California resident, please refer to the California Residents’ Rights section below for important information about the categories of personal information we collect and disclose and your rights under California privacy laws.
Cartus collects Personal Information in order to operate our business of providing relocation, assignment management and real estate related services. We may transfer Personal Information to companies, which may include our affiliated companies listed below, and others that help us to provide our services.
In most cases, Cartus acts solely as a processor/service provider at the direction of our client. In those instances and except to the extent we are required by applicable law to respond to the individual, an individual who seeks access to, or who seeks to correct, amend, or delete inaccurate Personal Information should direct the query to the client. If such a query is directed to Cartus, we respond to you where required by applicable law or otherwise will review with our client and Cartus or the client will respond to you within a reasonable timeframe.
We will retain Personal 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.
2. What is Personal Information?
Personal Information means any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with you, any designee you appoint to manage your CartusOnline account or a member of your household, including name, address, mobile or other telephone number, professional and employment-related information, e-mail address, government identification number, date of birth, photograph, financial account, services we provide to you, or other similar data elements that may be created or made available in connection with your relocation. We ask that you refrain from providing us with sensitive personal information about you or members of your family, such as your ethnicity, religion, health condition, and/or sexual orientation, as these data elements are not usually needed for your relocation.
3. Collection, Use, Transfer and Protection of Your Personal Information
3 (a). Use of Personal Information
In addition to Relocation Purposes, we may also use and disclose your personal information for the following purposes:
- Providing support and services: including, for example, to send or facilitate communications among you, independent real estate professionals and their affiliated entities, and other users of the Services, provide products and services you 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.
- 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 satisfaction surveys; and for other research and analytical purposes.
- 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 otherwise personalize your experiences.
- Advertising, marketing and promotional purposes: including, if you are a client contact, to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions.
- 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 the rights or safety of any person or third party, or other unauthorized activities or misconduct.
- 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.
- 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.
- Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.
Aggregate and de-identified information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes.
While most of the Personal Information collected by Cartus is supplied by you and our clients and suppliers as part of the Relocation Purpose, we may, at times, ask you to (or you may voluntarily in CartusOnline) update or confirm a subset of that Personal Information on this web site. To do this, you may be asked to register to use this site. Additionally, your Personal Information may be shared with our affiliates listed below, and third-party suppliers (e.g. home inspectors, moving companies) where necessary to support and solely for the Relocation Purpose, which may include making Personal 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 Personal Information may be used by Cartus to market and/or provide our services to those clients and potential clients, subject to applicable laws.
Transfer of Personal Information
Cartus has withdrawn our certifications under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework meaning that we no longer participate in or comply with those frameworks. For more information, please see “Privacy Shield Withdrawal” below. We will work with clients to implement additional adequacy measures where necessary under applicable data protection laws in the European Economic Area (EEA), Switzerland, and the United Kingdom (UK), such as the EU standard contractual clauses for the transfer of personal data to processors established in third countries (“Standard Contractual Clauses”).
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, CARTUS FINANCIAL CORPORATION, CARTUS PUERTO RICO CORPORATION and CARTUS REAL ESTATE CONSULTANCY (SHANGHAI) CO., LTD.
We retain your Personal Information only to the extent necessary to perform our contractual obligations and to meet the compliance obligations that apply to our multi-jurisdictional business, as reflected in our record retention policy. When we no longer need your Personal Information, we will securely remove, deactivate, or de-identify your Personal Information from our systems. If you wish to request that we no longer use your Personal Information for the Relocation Purpose, contact us as specified below in Contacting Us/Correction/Updating Personal Information/Exercising Your Rights, or if you are a resident of California, as specified below in "Additional Information for other Jurisdictions". 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 and its affiliates 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.
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. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at InformationProtection@cartus.com.
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.
In addition, telephone calls to or from Cartus in the United States 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 participate in conference calls in or request Cartus to conference in to any telephone calls with Cartus.
3 (b). Passive Collection
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to conduct research, analyze trends in the aggregate for internal audits and third-parties, generally to improve our services, and administer the site.
Technologies such as cookies or similar technologies 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.
Behavioral Targeting / Re-Targeting
3 (c). Disclosure of Information to Third Parties
We reserve the right to share your Personal Information with our clients, affiliates listed above and third-party service providers, as described herein, in order to help us deliver our services. As authorized by you, your employer or membership group we may also share your Personal Information with third parties who offer or provide you with other services related to the Relocation Purpose. Those third parties (for example, landlords, schools and lenders) will offer and/or enter into direct relationships with you and will not be subject to our control. We encourage you to read their privacy policies/statements. Please be aware that we are not responsible for the privacy practices of those third parties.
Cartus may also disclose 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 or requested by you, your employer or membership group as part of the Relocation Purpose. Similarly, it is against Cartus' policy to sell, without your consent, your Personal Information collected online.
Social Media Widgets
4. Location of Servers and Transfer of Personal Information to the United States
5. Privacy Shield Withdrawal
Cartus has withdrawn our certifications under the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”), meaning that we no longer participate in Privacy Shield or comply with the Privacy Shield . In accordance with Privacy Shield requirements, with respect to personal data that we previously collected pursuant to Privacy Shield and are retaining, we will continue to apply the Privacy Shield Principles, and annually confirm to the U.S. Department of Commerce our commitment to apply those principles to such data. For more information about Privacy Shield, please visit https://www.privacyshield.gov/.
The security of your Personal Information is important to us. Cartus maintains its systems in accordance with reasonable industry standards to reasonably secure the Personal Information of its customers against unauthorized access, accidental or intentional manipulation, and loss, both during transmission and once it is received. However, no data transmission over the Internet can be guaranteed to be 100% secure, and you use the site at your own risk. If you have any questions about the security of your personal information, you can contact us using the addresses noted in the "Contact Us" section below.
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.
This site is not directed to children under the age of 16 (“Children”), and we do not knowingly collect any information, including Personal Information, from Children.
10. Contacting Us/Correction/Updating Personal Information/Exercising Your Rights
|By e-mail to:||InformationProtection@cartus.com|
Privacy Officer, Cartus, 40 Apple Ridge Road, Danbury, CT 06810
Or if your relocation is being handled by our UK affiliate, or you are a Cartus employee located in the EU:
Director of Legal Services, Cartus Limited, Frankland Road, Blagrove, Swindon, Wiltshire SN5 8RS
|Toll free U.S. phone:||(877) 651-7356|
|By phone (Singapore):||+65 6880 5804|
We will respond to your request within a reasonable timeframe, but in no event later than 45 days, or such lesser period prescribed by applicable law.
11. ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN JURISDICTIONS
11 (a). European Union/European Economic Area/United Kingdom:
If you are a resident of the EU, European Union or United Kingdom you may have the following rights that you should exercise through the contacts listed above or directly through your employer or membership group. Cartus will respond to you or aid your employer when you exercise the following rights:
- The right to require a copy of your personal data;
- The right to require that inaccurate or out of date personal data be corrected;
- The right to request that personal data is erased when it is no longer necessary to be retained;
- If consent it the basis for processing, the right to withdraw your consent;
- The right to data portability, if applicable;
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;
- The right to object to processing, if applicable; and
- You also have the right to lodge a complaint with your applicable data protection authority.
11 (b). California Residents (Last Updated 09 October 2020):
In this section we provide information for California residents, as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"), which requires that we provide California residents certain specific information about how we handle their personal information, whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under CCPA.
Categories of personal information that we collect and disclose. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, sell, and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the "Collection of Personal Information" section above, and for the purposes described in the "Use of Personal Information" section above.
|Categories of personal information||May We Disclose this Information?||Categories of Third Parties to Whom We May Disclose this Information|
|Identifiers: includes direct identifiers such as a real name, alias, address, user ID, username, account number; phone number, unique personal identifier, online identifier, IP address, app ID, email address, account name, social security number, social insurance number, driver's license number, passport number, or other similar identifiers..||Yes||
Usage Data: includes browsing history, clickstream data, search history, and information regarding a resident's interaction with an internet website, application, or advertisement, including access logs and other usage data related to your use of any company websites, applications or other online services.
Geolocation data: includes precise location information about a particular individual or device.
|Professional Information: includes professional or employment-related information.||Yes||
|Education information: includes information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates).||Yes||
Do We “Sell” Personal Information? The CCPA defines a "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration. While we do not disclose personal information to third parties in exchange for monetary compensation, as defined by the CCPA, we may “sell” Identifiers, Usage Data and Inferences to ad networks and data analytics providers, via cookies and tags on certain of our websites (e.g., in order to improve and measure our advertising and marketing campaigns).
Sources of Personal Information. As further described in the Collection of Personal Information section above, we may collect personal information from the following sources:
- directly from the individual
- advertising networks
- social networks
- internet service providers
- operating systems and platforms
- our business clients
Rights of California Residents. California law grants California residents certain rights and imposes restrictions on particular practices as set forth below.
- Do-not-sell (opt-out): California consumers have the right to opt-out of our sale of their personal information.
- Request to Delete: California residents have the right to request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
- Request to Know: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting their personal information;
- categories of third parties/with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose;
- categories of personal information collected; and
- categories of third parties to whom the residents' personal information has been sold and the specific categories of personal information sold to each category of third party.
California residents may make a Request to Know up to twice every 12 months. We will respond to verifiable requests received from California residents as required by law.
Financial Incentives. We may make available certain programs or offerings that are considered “financial incentives” under the CCPA as described below. We will provide you with notice and obtain your consent prior to your participation in any such program.
Submitting Requests. Requests to opt-out of sales, requests to know, and requests to delete may be submitted:
- By email to InformationProtection@cartus.com
- All requests: By contacting us at (877) 651-7356 (toll free)
When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must provide us with any requested information or otherwise provide us with this information via the above toll-free number to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual [by contacting us at InformationProtection@cartus.com; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Rights Under California Shine the Light Law. California residents may request from businesses with whom they have an established business relationship (1) a list of categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes and (2) the names and addresses of all such third parties. Cartus does not provide Personal Data to third parties for direct marketing purposes.