Effective Date: January 1, 2023
If you are a California resident, please be sure to review Section 17B. California Residents for important information about the categories of personal information we collect and disclose as well as your rights under California privacy laws.
2.	OUR COLLECTION OF PERSONAL INFORMATION
Generally, we collect your personal information on a voluntary basis. However, if you decline to provide certain personal information that is marked mandatory, you may not be able to access certain Services or we may be unable to fully respond to your inquiry.
We may collect personal information directly from individuals, automatically related to the use of the Services, and in some cases, from third parties (such as social networks, platform providers, payment processors, data providers, and operators of certain third- party services that we use). 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.
Information we collect directly. We collect information that you provide to us, such as:
Information we collect from third parties. We may collect or receive personal information about you and your property from third party sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected), brokers and affiliated agents, and other real estate professionals, and third parties. For example:
3.	PURPOSES AND LEGAL BASIS FOR OUR PROCESSING
Certain laws, including the EU General Data Protection Regulation (“GDPR”), UK and Brazil data protection law, and similar laws require that we inform applicable individuals of the legal basis for our use and other processing of their personal information. In this section, we described the purposes for which will collect, use, disclose and otherwise process personal information, as well as the legal bases for such processing, generally, under such privacy laws.
Legal bases under certain privacy laws. Pursuant to the GDPR, UK and Brazil data protection law, and similar laws we collect, use and otherwise process personal information for the following legal bases:
In addition, we may process your personal information where necessary to protect the vital interests of any individual.
Purposes of processing. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we collect, use, disclose and otherwise process personal information for the purposes set forth below, as well as the legal basis for such processing, as applicable under relevant laws (see above for further explanation of these legal bases):
4.	DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect to third parties, as reasonably necessary for the purposes described above and as otherwise directed or consented to by you, including:
5.	AGGREGATE AND NON-IDENTIFIABLE DATA
We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except as permitted by applicable privacy laws (such as to confirm whether our deidentification processes are reasonable and adequate).
6.	COOKIES, TRACKING, AND ANALYTICS
Our Services may use first party and third-party cookies, pixel tags, plugins, and other tools to gather device, usage and browsing information when users visit our Services. For instance, when you visit our Services, our server may record your IP address (and associated location information) and other information such as the type of your internet browser, your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, and the pages you view and links you select on the Services, as well as date and time stamps associated with your usage of and activities on our Services.
We use the information for security purposes, to facilitate navigation, to improve, analyze and optimize our Services and their functionality, to personalize and improve your experience while using the Services, to improve and measure our advertising campaigns, and to better reach users with relevant advertising both on our Services and on third party websites.
Click “Cookie Preferences” link in the footer of our Website for more information about cookies on that Website, and to review and update your preferences for most types of cookies (other than those that are necessary to the functionality of that Website).
If you have disabled one or more cookies, we may still use information collected from cookies before your disabled preference was set. However, we will stop using the disabled cookie to collect any further information.
Pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Websites to, among other things, track the actions of users of the Websites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Websites and response rates. We and our service providers may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, track whether our emails are forwarded, and conduct analytics.
Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.
Browser signals. Please note that our Websites do not recognize or respond to browser “do-not-track” requests or other browser privacy signals. However, you can review and update your cookie preferences on our Websites as discussed above.
7.	INTEREST-BASED ADVERTISING
You can review and manage your preferences for targeting cookies and get information about to targeting cookies in use on one of our Websites by clicking “Cookie Settings” in the footer of our website.
You may also obtain more information about targeted or “interest-based advertising” and opt-out of many ad networks at the industry websites below:
8.	SOCIAL FEATURES AND THIRD-PARTY PLUG INS
The Services may integrate with social sharing features and other related tools which let you log in to the Services or share actions you take on the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
9.	INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
BHGRE is headquartered in the United States and has affiliates and service providers in multiple jurisdictions. As such your personal information may be transferred to the United States and other jurisdictions where we or our service providers have operations, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such of these jurisdictions upon transfer. Some of these jurisdictions—including the United States—may not provide the same level of data protection as your home country. In such cases, we rely on suitable personal information transfer safeguards. You may request a copy or information about those safeguards by contacting us as detailed below.
We use technical, administrative, and physical controls in place to help protect personal information from unauthorized access, use, and disclosure. Even so, despite our efforts, no security measure is ever perfect or impenetrable. In the event that the security of your account has been compromised, please immediately notify us in accordance with Section 16. Contact Us.
11.	DATA RETENTION
12.	YOUR RIGHTS AND CHOICES
Marketing. You may opt out from receiving marketing-related communications from us on a going-forward basis by contacting us or by using the unsubscribe mechanism contained in each email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
Cookies preferences. To review and update your preferences for most types of cookies (other than those that are necessary) for one of our Websites, Click “Cookie Preferences” link in the footer of that Website.
Deactivation. You can deactivate your account at any time by contacting us at the email address at the bottom of this page. However, you will not be able to access many of the services to deactivate your account. Please note that even if you request deactivation of your account, it may take some time to fulfill this request.
Access, amendment and deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted or otherwise exercise your rights over your personal information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your personal information:
We will process in accordance with and where required by applicable law, and with respect to your personal information that is linked or linkable to the email that you use to send us your request and the verifiable information provided by you as a part of your request. We will take steps to verify your identity before implementing your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
The Services are not intended or directed to children under the age of 16, and we do not knowingly collect any personal information, or knowingly track the use of our Services, from children. If we have actual knowledge that personal information about a child under 16 years old has been collected, then we will take appropriate steps to try and delete such personal information.
14.	THIRD-PARTY WEBSITES
16.	CONTACT US
Mailing address: 175 Park Ave., Madison, NJ 07940 Attn: Data Privacy
Phone number: (888) 778-6995
17.	ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS
Residents of certain states have additional rights under applicable privacy laws, as described in this section.
A.	EEA and the United Kingdom
The GDPR and UK data protection laws (where applicable), gives data subjects the following rights regarding their personal information:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation, or the establishment, exercise or defense of legal claims.
You may submit your GDPR request to us via:
B.	California Residents.
This section provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws.
In this section, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the 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. Below we describe the categories of personal information we may collect about California residents (including the categories of personal information that we have collected about California residents in the past 12 months):
Categories of third parties. Below we describe the third parties to whom we may disclose each category of personal information for a business or commercial purpose:
In addition, we may disclose any of the categories of personal information we collect about you to other third parties as directed by or consented to by you, or where necessary to fulfill your specific requests.
Sales and sharing. The CCPA defines a “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” (as defined by the CCPA): (i) identifiers, usage data, customer records, commercial information and profiles with our affiliates and subsidiary companies (e.g., so that they may improve or enhance their own records and for other purposes); and (ii) identifiers, usage data and commercial information to ad networks, social media platforms and data analytics providers (e.g., in order to improve and measure our ad and marketing campaigns).
Sources of Personal Information. We may collect personal information from the following sources:
Purposes of Collection, Use and Disclosure. As described in more detail in Section 3. Use of Personal Information and Section 4. Disclosures of Personal Information, we collect, use, disclose and otherwise process personal information (including sensitive personal information) for the following business or commercial purposes or as otherwise directed or consented to by you:
Rights of California Residents. In general, California residents have the following rights under the CCPA:
California residents’ rights. Under the CCPA, California residents have the following rights (subject to certain limitations) with respect to the personal information we collect and maintain about them:
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights to know/access, delate, correct, and limit use/disclosure of sensitive personal information by submitting a verifiable request to us via:
We will respond to verifiable requests received from California residents as required by law. 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 complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number) so that we can process and verify your request. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in 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 via email or phone; 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.
Requests to Opt Out. Our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. (You can also manage your preferences for targeting and other cookies on one of our Websites through the “Cookie Settings” link in the footer of the Website.) More information about GPC is available at: https://globalprivacycontrol.org/. You may also submit a request to opt out of other sharing and sales by submitting a request via:
Financial Incentives. We may make available certain programs or offerings that are considered “financial incentives” under the CCPA, and we will provide notice of the material terms of such incentives and obtain consent from individuals before including them in such incentive programs. You can opt out of such programs at any time through the opt out mechanism provided in the program information.
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. To request the above information please contact us by writing to us under the “Contact Us” section above. We will respond to such requests within 30 days of receipt.
For more information about our privacy practices, contact us as set forth in the Section 16. above.
C.	Residents of Other U.S. States
Residents of certain U.S. states (including Virginia) may have additional rights under applicable privacy laws, subject to certain limitations. These rights may include:
You may submit a request to exercise your privacy rights via:
You may also opt out of targeted advertising via on one of our Websites, by clicking the “Cookie Settings” link on our website and turning off targeting (advertising) cookies. (See Section 12. Your Rights and Choices, for additional information about the privacy choices we provide and how to exercise them.) We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal our decision by submitting a request through our webform.