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The Paul Kaplan Group, Inc. (PKG) is a Real Estate company providing online and in person real estate products and services, including website templates and web-delivered applications and plugins hosted on the Real Estate Webmaster (REW) server and online marketing and social media services.
We are committed to protecting your personal information in accordance with commercially reasonable standards and legal requirements.
Data Processors (or Service Providers)
Data Subject (or User)
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). We collect this information when you fill out a form, send us an email, enter information on our site, use the customer website or our mobile app. Depending on the area of the site or mobile app, personally identifiable information we may collect and store on our servers may include, but is not limited to:
We only collect Personal Data that you voluntarily provide. You may refuse to provide consent at any time. However, this may prevent you from accessing and using the Website, portions of the Website, or the Services.
We may also collect information about how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. Use of a Cookie is in no way linked to any personally identifiable information. Cookies are an industry standard used by most websites.
You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. To find out more about cookies, including how to see what Cookies have been set and how to manage and delete them, visit www.allaboutcookies.org/manage-cookies/.
Examples of Cookies we use:
We use Google Analytics to collect aggregated information regarding the access and use of the Website. Such aggregated information may include what pages Users' access or visit, when and how Users visit, and other information Users may volunteer.
We collect and use such information to improve the quality of the Website.
The information we collect is not shared with or sold to other organizations for commercial purposes but may be used where it is necessary to share 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, or as otherwise required by law.
If you are requesting that we refer you to an agent outside our typical market area, we may share your information with another Broker/Agent and collect a referral fee to be paid by referral recipient to The Paul Kaplan Group, Inc.
We log certain technical information from your computer's web browser when you access and use the Website. This information includes your IP address, the address of the website you are coming from, the amount of time you spend visiting the Website, the pages visited, date and time of access, and the operating system and web browser software used.
We use such information to analyze Website trends, administer the Website, track User movement in the aggregate and gather other information for aggregate use, such as demographic information.
This information is not generally used to link the logs to identifiable individuals. PKG will only attempt to link the logs to identifiable individuals if that is necessary because of a data security breach, a breach of contract, a violation of PKG policies and procedures, or as otherwise required by law.
Use of Data
PKG uses the data collected from Users for various purposes:
Additionally, we may periodically send promotional emails about our service, special offers or other information (company news, updates, etc.) which we think you may find interesting using the email address you provided. From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or mail.
Our products and services provide real estate related information and related information to Users that facilitate the collection of personal information from Users' customers ("End User Personal Information"). End User Personal Information is collected when a User's customers access products and services provided by PKG to the User. End User Personal Information is collected and stored by PKG on behalf of the User, but we maintain no rights in any End User Personal Information and do not use End User Personal Information.
PKG may act as either a Data Controller or a Data Processor in respect of your Personal Data, depending on the circumstances.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
The Paul Kaplan Group does not offer goods or services to data subjects in the EU or monitor behavior of EU residents taking place within the EU and thus is not a data controller under Article 3(2) of the GDPR. The European Commission has publicly said: “Provided your company doesn't specifically target its services at individuals in the EU, it is not subject to the rules of the GDPR.”
The Paul Kaplan Group, Inc. is a US-based company that does not solicit business or have a physical business presence within the EU. The Paul Kaplan Group, Inc provision of services to EU residents, if any, is initiated by the EU resident’s unilateral action of browsing a PKG website for properties within the United States or Canada. This limited relationship, originated by the EU resident, not as a result of PKG targeting of EU residents, does not fall within the scope of GDPR.
PKG can also rely on how the GDPR characterizes the offering of goods or services to EU residents for web-based services. Specifically, GDPR’s Recital 23 states “In order to determine whether such a controller or processor is offering goods or services to data subjects who are in the Union, it should be ascertained whether it is apparent that the controller or processor envisages offering services to data subjects in one or more Member States in the Union. Whereas the mere accessibility of the controller's, processor's or an intermediary's website in the Union, of an email address or of other contact details, or the use of a language generally used in the third country where the controller is established, is insufficient to ascertain such intention, factors such as the use of a language or a currency generally used in one or more Member States with the possibility of ordering goods and services in that other language, or the mentioning of customers or users who are in the Union, may make it apparent that the controller envisages offering goods or services to data subjects in the Union.”"
PKG may process your Personal Data because:
PKG will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, PKG may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
PKG may disclose your Personal Data in the good faith belief that such action is necessary to:
Agents, Consultants and Service Providers
We may share your Personal Data with our contractors and Service Providers, who process Personal Data on behalf of PKG to perform certain business-related functions. These companies include our marketing agencies, database service providers, email service providers and others. When we engage another company to perform such functions, we may provide them with information, including Personal Data, in connection with their performance of such functions.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links to Other Websites
The Website may contain links to other websites of interest that are not operated by us. If you click on a third party link, you will be directed to that third party's site. These third-party sites have separate and independent privacy policies. Please be aware that we are not responsible for the privacy policies of any third party websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services. Therefore, we have no responsibility or liability for the content and activities of these linked sites, or any information you provide while visiting those sites. We strongly advise you to be aware when you leave the Website and to read the privacy policies of each and every website that collects personally identifiable information.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. When you submit sensitive information via the Website, your information is protected both online and offline. In order to prevent unauthorized access or disclosure, we have put in place commercially reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect online. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its security. You are submitting information to us at your own risk. Where a password is needed to access areas of our site, you are responsible for the safety and confidentiality of the password you generate.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. PKG aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.
Controlling Your Personal Information
You can always ask to review any Personal Information that we have collected from you, have us update, correct or delete this information or instruct us not to use this information in the future. If you wish to exercise this right, simply contact us via telephone at 760-459-1396 or firstname.lastname@example.org. We do retain Personal Information in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our agreements, and take other actions otherwise permitted by law.
You may opt out of any future marketing contacts from us at any time by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. We may use your Personal Information to send you promotional information about third parties which we think you may find interesting unless you instruct us not to do so. However if you are requesting a referral of a real estate broker or agent outside of the typical market area serviced by PKG, you authorize PKG to share your information with a third party. PKG may collect a referral fee for the recipient of your information.
Any data collected from web forms completed on this site is considered as opt-in permission to be included in our marketing database.
Our Service does not address anyone under the age of 18.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.