Privacy Policy

Last modified 09 October 2020

We at Cartus (collectively, “Cartus”, “we”, “us”, or “our”) recognize the importance of protecting the privacy of personal data (as defined below, "Personal Information") collected by us. This Privacy Policy describes how Cartus collects, uses, discloses, retains, and transfers Personal Information in performing relocation services. It also describes your choices regarding use, access and correction of your Personal Information. Personal 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 this Privacy Policy and to Cartus’ processing of Personal Information for the purposes stated in this Privacy Policy, as well as those explained where Cartus collects Personal Information on the web. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU CANNOT USE OUR SERVICES.

OVERVIEW OF OUR COLLECTION AND USE OF PERSONAL INFORMATION

We think transparency is important. In this overview, we summarize the personal information we collect and how we use it, which is further explained in our Privacy Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain 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.

1. Scope of this Privacy Policy

This Privacy Policy applies to the following sites ‎only: www.cartus.com, www.online.cartus.com, www.cartusnetworks.com, www.cartusvirtualresources.com, www.cartusmoves.com, www.myaffinityservices.com, www.homerewards.cartus.com, ‎and Cartus Mobile, owned and operated by Cartus (collectively, “Cartus”, “We”, “Us”, or “Our”).‎

Each 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 policy 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 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

We process your Personal Information described above as necessary for Cartus to provide ‎relocation services under the terms of its contractual obligations with your employer or ‎membership group consistent with the legitimate interests of your employer or membership ‎group (i.e., our corporate or government entity client). If you provide us with sensitive Personal ‎Information, we will process it based on your consent. In general, we collect, use, disclose, retain ‎and transfer Personal Information for the purposes of managing and facilitating your move from ‎one location to a new location (the "Relocation Purpose"), including the following to the extent ‎authorized by your employer or membership group: (a) arranging for your physical move and the ‎storage of your property; (b) tracking and processing expense reimbursements and other ‎benefits, such as lump sum payments; (c) home sales, purchases, and rentals, including ‎financing arrangements; (d) explaining various employer-sponsored benefits; (e) immigration ‎and other customs related purposes; (f) referring you to third parties who provide cultural ‎assistance and/or language training; and (g) other activities relating to the delivery and ‎improvement of relocation services. Any access to your Personal Information is restricted to ‎those individuals that have a need to know to fulfill their job responsibilities. We will not use ‎Personal Information for any other purpose incompatible with the Relocation Purpose outlined in ‎this Privacy Policy, unless it is required or authorized by laws that apply to Cartus or otherwise ‎authorized by you. We do not sell your Personal Information to third parties.‎

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

We will share your Personal Information with our affiliates listed below and with third parties for ‎any legitimate reason related to the Relocation Purpose and only in the ways that are described ‎in this Privacy Policy. In addition, your information may be stored and secured in databases ‎outside of your home country, including the United States of America. For example, we may ‎disclose Personal Information (a) to local subcontractors of Cartus who provide relocation ‎services in countries in which Cartus does not have offices; (b) to a third party service provider ‎with facilities in India which processes Personal Information for the Relocation Purpose (e.g., ‎freight forwarder invoices may be audited in India); or (c) to governmental authorities, courts, ‎external advisors, or other similar parties located in or outside out of your home country. Each ‎affiliate and third party will receive only those categories of Personal Information needed to ‎provide their services. For example, a freight forwarder would need your address at departure ‎and destination, contact information and your visa information. A real estate broker would need ‎your address at destination or departure and contact information. Some of those countries where ‎Personal Information is transferred may have different data protection standards than your home ‎country and, thus, your Personal Information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws in such jurisdictions. We exercise appropriate due diligence in selecting our third-party service providers, and ‎contractually require them to treat your Personal Information confidentially, and implement ‎appropriate technical, organizational, and administrative controls to safeguard it against ‎unauthorized access, use, or disclosure.‎

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”).

Cartus may disclose Personal Information about you in special cases when we have reason to ‎believe that disclosing this Personal 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 ‎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, CARTUS FINANCIAL CORPORATION, CARTUS PUERTO RICO CORPORATION and CARTUS REAL ESTATE CONSULTANCY (SHANGHAI) CO., LTD.

Data Retention

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.‎

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 Policy 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. 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. ‎

Voice Recording

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.‎

Tracking Technologies

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.

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

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

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

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 policy of the company providing it.‎

4. Location of Servers and Transfer of Personal 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 acknowledge our ‎legitimate business interest or consent, as applicable to your jurisdiction, in making the transfer to ‎the United States and to its storage, processing, and use there in accordance with this Privacy ‎Policy and United States law.‎

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/.

6. Security

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.‎

7. 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.

8. Children

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.

9. Changes in this Privacy Policy

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy here, and any other places we deem appropriate so that you can be aware of what Personal Information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you here or by other means we deem appropriate, prior to the change becoming effective.

10. Contacting Us/Correction/Updating Personal Information/Exercising Your Rights

You 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 your Personal Information, deletion of your incorrect Personal Information or correction of your Personal Information; and (6) to make inquiries whether we hold or process on behalf of a third party, any of your Personal Information or complaints/objections regarding our Privacy Policy and/or privacy practices.

By e-mail to: InformationProtection@cartus.com
By mail:

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

By phone:

(203) 205-1540

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
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • your general location to data analytics providers
  • internet service providers
  • business customer/client


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.

Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • internet service providers may collect your IP address as a function of using our services
  • operating systems and platforms
  • business customer/client


Commercial information: includes records of personal property, products or ‎services purchased, ‎obtained, or considered, or other purchasing or use ‎histories or tendencies.‎

Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • your general location to data analytics providers
  • business customer/client

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.‎

Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • internet service providers may collect your IP address as a function of using our services
  • business customer/client

Geolocation data: includes precise location information about a particular individual or ‎device.‎

Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries


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).

Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
Professional Information: includes professional or employment-related information. Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • business customer/client
Education information: includes information about an individual’s educational history (such as the schools attended, degrees you were awarded, and associated dates). Yes
  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • business customer/client

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:‎

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.