PRIVACY POLICY
Effective: December 8, 2010

Privacy Statement:
We have developed this Privacy Policy to inform you of the data gathering and dissemination practices applicable to our web site (Site). By visiting, registering or using services obtained through our Site, you agree to the terms of this Privacy Policy.  If you do not agree with any terms of this Policy, please do not use or submit any personal information to this Site.

WhereForeclosures.com Privacy Pledge:
We do not collect any personal information from you that you do not volunteer, and we are the sole owner of all information collected on this site. We fully disclose our privacy policy in this document. If you have any questions or comments, you are invited to contact us.

Information We Collect:
We collect Personally Identifiable Information when you register to use this Site; when you use, participate or purchase products and services through this Site; and when you ask to be provided additional services. The type of personal information that we collect may include full name, email, telephone number, address, payment information, profession, company name, company website address, business telephone number and photo. This personal information is generally required if you wish to enroll or participate in our services. We may use, sell or distribute certain individual personal information to other companies, including related interests or vendors so as to provide you with important offers. We may keep all information collected in accordance with this Privacy Policy indefinitely.

Personally Identifiable Information:
Personally Identifiable Information refers to any information that can be used to identify you as an individual in any way. Enrollment in any WhereForeclosures.com service is contingent upon your agreeing to the Terms and Conditions of membership and providing Personally Identifiable Information as described above.

Anti-SPAM Policy:
The WhereForeclosures.com marketing program has a strict policy regarding unsolicited email. Because email is an integral part of our services, your signup ensures that you'll receive information relative to your interests at the time of your enrollment from WhereForeclosures.com. If you later wish to cease participation in this portion of our services, you may do so at any time by clicking the unsubscribe link or button found within such message. Please note that opting not to receive email does not exempt you from receiving administrative and informational emails from us, which include but are not limited to, notices about membership status changes and alterations to our Terms.

Aggregate Data:
We may, from time to time, contact you regarding opportunities that may be of interest to you. In that process, we may use a third party service provider to manage our database and communication system in order to send that correspondence to you on our behalf. If you respond to a communication to take advantage of an offer you may see or receive, you share your Personally Identifiable Information with a third party. From time to time, we do share non-personally identifiable information collected in aggregate, anonymous form with third parties so that they may better evaluate what products and services are most appealing to different segments of our member base.

Automatically Collected Information:
When you log on to our Site, our server may automatically recognize you by an encrypted member key, also referred to as a "cookie." This cookie acts as a unique identifier. We may use third party cookies and clear pixels (also referred to as "web beacons") to measure page views and email responses. These devices allow us to identify unique visitors to our Site and act as a counter for ongoing monitoring of Site, email and corresponding future transaction activity related to a specific offer.

Third-Party Websites and Services:
We are not responsible or liable for the content or data practices of any third-party site, including those of our advertisers, affiliates, partners, or vendors. We recommend that you read the privacy policy of all third-party sites carefully before sharing your Personally Identifiable Information with them. Occasionally, you may be offered the opportunity to participate in an offer or service that, by its very terms, will require us to forward your Personally Identifiable Information to the advertiser or partner so that they can provide the service to you. As always, it is your choice to participate. We do not guarantee the content or information practices of any third-party site. You alone are responsible for determining the appropriateness of sharing your Personally Identifiable Information with our advertisers. We have your consent to share collected personally identifiable information (including email addresses) with third parties for commercial purposes, such as advertising. We will not rent or sell your mobile telephone number to other companies or individuals, unless we have your consent. We may use or disclose such information in any of the following limited circumstances:
  • We have your consent.
  • We need to enforce our Terms of Use.
  • We provide such information to a company controlled by, or under common control with, WhereForeclosures.com for any purpose permitted by this Policy.
  • We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • We believe it is necessary to share Personal Information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of WhereForeclosures.com’s Terms of Use, or as otherwise required by law.
  • We transfer Personal Information about you if WhereForeclosures.com is, or its assets are, acquired by or merged with another company.
Communication:
We are available to you during normal business hours to answer any privacy-related questions or concerns you might have. Simply contact us and we will respond in a timely manner. You sign up for our marketing program when you submit the information on the first page of our sign-up process, and our marketing partners or we may contact you via email with offers we think you will like. We have a strict Anti-SPAM policy, and you may unsubscribe at any time while still participating in our services. We do not collect or use any information about you for marketing purposes, except for information that you have provided to us or authorize us to obtain, or is publicly available, and this information is used solely to make our programs and services more relevant to your interests.

Security:
WhereForeclosures.com has established company-wide security policies and practices designed to protect your and others information from unauthorized intrusion. These practices include, but are not limited to, firewall security, the use of appropriate encryption technology, and the use of multiple levels of password security. All WhereForeclosures.com employees are required to familiarize themselves with, and abide by, these safeguards.   However, please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. Our policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond our control, and is not to be applied in any manner contrary to applicable law or governmental regulation.

A Special Note Regarding Individuals Under 18 Years Old:
The Site is not directed to individuals under the age of eighteen (18), and we request that such individuals not provide personal information through the Site. If you are under 18 years of age, you may browse our Site; however, you may not provide personal information to us such as name, address, or email address, and you may not register for, enroll in, and/or make product purchases.

Change In Business Operations:
Please note that if WhereForeclosures.com or any lines of its business are sold or disposed of as a going concern, whether by merger, liquidation, sale of assets or otherwise, its customer database could, in whole or in part, be sold or otherwise transferred to a third party as part of that transaction. There may be instances when we may disclose your information without providing you with a choice in order to protect our legal rights or those of our affiliates, or those of our or our affiliates' employees, agents and contractors; to protect the safety and security of visitors to our web sites; to protect against fraud or for risk management purposes; or to comply with the law or legal process.

International Visitors:
Your information may be transferred to, stored and processed in the United States or any other country where we have facilities, and by providing us with your information, you consent to the transfer, storage and processing of such information outside of your country.

Your California Privacy Rights:
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by US Mail at 402 West Broadway, Suite 400, San Diego, California 92101 United States of America Please include your name and the address to which you would like us to respond.

Thank you for becoming familiar with the WhereForeclosures.com privacy policy. You can always contact us with any questions.

PRIVACY POLICY FOR CALIFORNIA RESIDENTS ONLY

This PRIVACY POLICY IS FOR CALIFORNIA RESIDENTS ONLY and it supplements the information contained in the general Privacy Policy shown above. This Privacy Policy applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act ("CCPA") and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

  1. Understanding Your Rights and Choices Under the CCPA

  2. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

    1. Access to Specific Information and Data Portability Rights

    2. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

      1. The categories of personal information we collected about you.
      2. The categories of sources for the personal information we collected about you.
      3. Our business or commercial purpose for collecting or selling that personal information.
      4. The categories of third parties with whom we share that personal information.
      5. The specific pieces of personal information we collected about you (also called Data Portability)

    3. Deletion Request Rights

    4. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

      We may deny your deletion request if retaining the information is necessary for us or our service providers to:

      1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
      2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      3. Debug products to identify and repair errors that impair existing intended functionality.
      4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 seq.).
      6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
      7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      8. Comply with a legal obligation.
      9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

    5. Exercising Access, Data Portability, and Deletion Rights

      1. To exercise the access, data portability, and deletion rights described above, please call us (800) 932-8210.
      2. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
      3. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

        1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
        2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
        3. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

    6. Right to Opt Out of Sale of Personal Information to Third Parties.

    7. You have the right to know if your personal information may be sold and the right to opt out of such sale. In our efforts to comply with this right to opt out, you may visit this link & provide us your email address and zip code so we can verify and process your requests. See section 5 below for more details ("Sharing Personal Information").

    8. Response Timing and Format

      1. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the email address associated with that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
      2. For consumer requests to opt out of sale of personal information, we will review, verify and process your request within 10 days of receiving this request.
      3. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your Request.

  3. Non-Discrimination

    1. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

      1. Deny you goods or services.
      2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
      3. Provide you a different level or quality of goods or services.
      4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

  4. Information We Collect

    1. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected categories of personal information from consumers within the last twelve (12) months that include the following:

      1. Identifiers,
      2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)),
      3. Commercial information,
      4. Internet or other electronic network activity &
      5. Geolocation data.

    2. Personal information does not include:

      1. Publicly available information from government records.
      2. De-identified or aggregated consumer information.
      3. Information excluded from the CCPA's scope, like:

        1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
        2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

    3. We obtain the categories of personal information listed above from the following categories of sources:

      1. Directly from our consumers or their agents. For example, from information that our customers provide to us related to the services for which they engage us.
      2. Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing services to them.
      3. Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
      4. From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

  5. Use of Personal Information

    1. We may use or disclose the personal information we collect for one or more of the following business purposes:

      1. To fulfill or meet the reason for which the information is provided.
      2. To provide you with information, products or services that you request from us.
      3. To provide you with email alerts and other notices concerning our products or services that may be of interest to you.
      4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
      5. To improve our website and present its contents to you.
      6. For testing, research, analysis and product development.
      7. As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
      8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
      9. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
      10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

    2. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Notice will be provided by amending this California specific Privacy Policy.

  6. Sharing Personal Information

    1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we describe the purpose to the recipient and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

    2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

      1. Identifiers,
      2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)),
      3. Commercial information,
      4. Internet or other electronic network activity &
      5. Geolocation data.

    3. We disclose your personal information for a business purpose to the following categories of third parties:

      1. Our partners.
      2. Service providers.
      3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
      4. In the preceding twelve (12) months, we have sold personal information.

  7. Changes to Our Privacy Notice

  8. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

  9. Contact Information

  10. If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Phone: (800) 932-8210
    Email: support@whereforeclosures.com