Last Updated: August 31, 2020
- About individuals who visit, use, or interact with the Inland Empire Board of Real Estate (see “Privacy for the Inland Empire Board of Real Estate website and data” ).
If you are resident in the European Economic Area and want to find out more about your data protection rights, please see “Your Data Protection Rights“.
If you are resident of California, see “California Notice“ for a declaration of your data protection rights.
If you have any questions, you may contact us by email.
A reference to IE-RE “we” or “our” means “Inland Empire Board of Real Estate” (www.ie-re.com).
IE-RE provides curated headlines with links to prevailing stories about real estate news in the Inland Empire and California. We operate a website and mobile applications, each “Digital Properties“. We provide information to the public and digital advertising space to our “Media Buyers” who are advertisers and other ad partners looking to distribute relevant ad content on our Digital Properties. We display relevant online advertising to end users (“End Users”) who interact with our Digital Properties.
IE-RE may also share or license certain information about End Users collected in connection with our partners, agencies and other interested third parties, to help them better promote transparency and protect against fraud.
IE-RE also collects information from individuals when they visit, use, or interact with: (i) www.ie-re.com and other websites operated by us, including IE-RE’s client interfaces (the “Websites”); (ii) our software applications (the “Apps”); (collectively, our “IE-RE Properties”).
This Section covers the specific things that we promise not do to that you might be concerned about.
- We do not collect your email address, name, or telephone number(s) in order to use our web site.
- We do not collect your email address, name, or telephone number(s) when you use our news tip feedback form, unless you choose to include that information in the free form text field. Only your IP address is collected in order to limit abuse of the web form.
- We do not send marketing or sales emails to you.
This Section describes how we collect and use information when visitors interact with or use any of the IE-RE Properties (such as our Website and mobile apps).
Information that individuals provide voluntarily
Although our Website does not ask for this information, our mobile Apps may ask visitors to provide personal information voluntarily: for example, we may collect personal information when a visitor registers the app, or otherwise contacts us.
The personal information we collect may include contact information (such as name, address, telephone number, or email address) and contact preferences. It may also include professional information, such as job title, department or job role, and the nature of an individual’s request or communication. We may also collect information that visitors choose to provide to us when completing any ‘free text’ boxes in our forms (for example, for news tips). Please do not post any information that you do not want to reveal to the public at large. We do not collect any personal information from our news tips form, except the End User IP address which is only used to prevent abuse of the form.
Information we or our third-party partners collect automatically
When using the IE-RE Properties, we or our third-party partners may automatically collect certain information from an individual’s device. In some countries, including countries in the EU, this information may be considered personal data under applicable data protection laws.
We may use information collected from the IE-RE Properties for the following purposes:
- To send administrative information. For example, to send information regarding our services and changes to our terms, conditions, and policies.
- To manage accounts and provide customer support or other services. For example, we may use information to create or administer IE-RE accounts and to provide customer support or other requested services or information.
- To select content and improve quality. We may use information to help improve the IE-RE Properties and to ensure that content on the IE-RE Properties is presented in the most effective manner for your device.
- For legal purposes. We may use information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- For our business purposes. We may use information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.
3.4 USE OF IE-RE PROPERTIES BY MINORS
The IE-RE Properties are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws, and we request that such individuals do not provide information through any of the IE-RE Properties.
SECTION 4 – GENERAL INFORMATION
4.1 HOW DO WE SHARE YOUR INFORMATION?
Information we collect may be disclosed:
- To our affiliates: We may disclose your information to our affiliates (see “Who We Are“) for the purposes described in this Policy. IE-RE, Inc., is the party responsible for the management of your personal information jointly used by it and its affiliates.
- Media Buyers: If you are an End User, we may share information we collect Media Buyer Clients for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution, or fraud prevention and to allow them to make decisions regarding buying advertising inventory on our Digital Properties and other websites and applications, and to analyze the effectiveness and performance of their advertising campaigns via our services, including sharing your device’s physical location to enable our Media Buyer Clients to provide you with more personalized content and to study the effectiveness of advertising campaigns.
- Other Clients: If you are an End User, we may share certain information we collect in connection with our Ad Services with brands, agencies and other interested third parties to help them better identify and validate commercial opportunities, promote transparency and protect against fraud.
- Attribution and Analytics Partners: If you are an End User, we may share your information (such as your cookie ID, mobile device ID, or other unique identifier) with our (or our Publisher Client or Media Buyer’s) attribution and analytics partners to validate and measure the success and effectiveness of ads delivered via the Platform.
- With our vendors, consultants, and other service providers: We may share your information with our third-party service providers, vendors, contractors, or agents who perform functions required for the operation of the business. Examples include, to provide data storage and processing services, lead management, campaign management, technical support for our Platform and IE-RE Properties and fraud prevention.
- Website advertising partners: As noted above, we may partner with certain third parties to collect information on the IE-RE Properties to engage in analysis, auditing, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on the IE-RE Properties and other websites over time. We may share information with them for this purpose.
- Business transfers: We may share your information with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or sock (including in connection with any bankruptcy or similar proceedings).
- For legal purposes: We may share your information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- With consent: We may disclose an individual’s information to any other person with the individual’s consent to such disclosure.
Opting out of receiving electronic communications from us
We do not send marketing-related emails to anyone. Therefore it is not necessary to opt out of receiving any marketing-related emails from us, because that will not happen. If you receive marketing related emails claiming to be from IE-RE, they are fraudulent.
We are a member of the Network Advertising Initiative (NAI) and adhere to the 2018 NAI Code of Conduct. We also adhere to the Digital Advertising Alliance’s (DAA) Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data, the Application of Self-Regulatory Principles to the Mobile Environment, and the Application of the DAA Principles of Transparency and Control to Data Used Across Devices. If you go to optout.networkadvertising.org, or optout.aboutads.info, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, or applications for interest-based advertising purposes.
Some of our advertising networks have their own opt-out mechanisms that are linked from their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company, or multiple companies.
At this time, we do not honor “Do Not Track” headers and similar mechanisms.
Opting Out of Interest-Based Advertising in Mobile Applications
Our clients and partners may display interest-based advertising to you in mobile applications, based on your use of mobile applications over time and across non-affiliated apps. To learn more about these practices and how to opt out, please visit http://www.aboutads.info/appchoices, download the DAA’s AppChoices mobile app, and follow the instructions provided in the AppChoices mobile app. You can also adjust the advertising preferences on your mobile device (in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads).
Opting Out of Cross-Device Targeting
Our clients and partners may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices by our clients and partners, please follow the instructions above for opting out on each of your browsers and on each of your mobile devices, including:
- Opting Out of Interest-Based Advertising from Cookies
- Opting Out of Interest-Based Advertising for Mobile Advertising Identifiers
Please note that you will need to opt out separately on each of your browsers and on each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.
You have the following data protection rights:
- You have the right to request access to or that we change, update, or delete your personal information at any time. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be communicated to you.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- The right to opt out of receiving marketing communications from us. See “Your Opt-Out Choices” for further information.
- If you are a resident of the European Economic Area (EEA), you may also have the following rights:
- The right to object to processing of your personal information, restrict processing of your personal information, or request portability of your personal information. To exercise these rights email email@example.com; and
- The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are here.
Please note that because most of the information we store can only identify a particular browser or device, and cannot directly identify you personally, you may need to provide us with some additional information to enable us to identify the personal information we hold about you and ensure that we accurately fulfill your request and do not infringe on the privacy rights of other individuals. You can exercise your rights at any time by contacting us at firstname.lastname@example.org. We will respond to your request in accordance with our obligations under applicable privacy laws.
4.4 LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA END USERS AND VISITORS ONLY)If you are a resident of the EEA, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we normally rely on our (or our Clients) legitimate interests to collect personal information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your personal information, they include the interests described in the sections above with the heading “How Do We Use Your Information” and how we use it with the IE-RE Properties.
In some cases, we may rely on your consent or have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your personal information, we will obtain such consent in compliance with applicable laws.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.
4.5 THIRD PARTIES
This Policy does not address, and except as otherwise described in this Policy, we are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Ad Services or IE-RE Properties link. The inclusion of a link through the Ad Services or Online Property does not imply endorsement of the linked site or service by us or by our affiliates.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Ad Services or IE-RE Properties.
4.6 HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?
We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
4.7 RETENTION OF YOUR INFORMATION
We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law.
If you are an End User, we may retain information that we collect through the Ad Services (including the segment information that we receive from third parties) for up to 45 days from the last date that we received any of the End User’s data. We may retain ad impression information for up to 45 days. We may retain raw ad server logs for our mobile ad server business for up to 45 days. We use precise geolocation for the specific ad impression to which the geolocation relates, after which the geolocation information is aggregated with other geolocation data for use by us for analytical purposes. If we de-identify information we collect through the Ad Services, we may retain that information, in an aggregated format, indefinitely. In such cases, we commit to not re-identifying the information. If we are required to retain information to comply with a legal or audit obligation, we may store End User information for longer periods.
4.8 INTERNATIONAL DATA TRANSFERS
The IE-RE Properties and Ad Services are provided, supported, and hosted in the United States. If you are using these from outside the United States, be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations, including India, where we have offices or employees or engage service providers. These countries may have data protection laws that are different from the laws of your country of residence.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Policy. These include:
- Implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request; and
- Self-certifying to the EU-US and Swiss-US Privacy Shield Frameworks. See our Privacy Shield Notice below for further information.
4.9 PRIVACY SHIELD NOTICE
|EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Status|
IE-RE, Inc., located in the United States, participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal information received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the Department of Commerce and is available at: https://www.privacyshield.gov/list.
IE-RE is responsible for the processing of personal information it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider TRUSTe (free of charge to you) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Residents of the EU and Switzerland may also request our data processing agreements in addition to relying on IE-RE’s Privacy Shield certification.
4.10 SENSITIVE INFORMATION AND OUR USE OF NON-SENSITIVE HEALTH SEGMENTS
We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership) on or through the IE-RE Properties or otherwise to us.
We may receive the following non-sensitive health-related advertising segments that we use to target ads that may be of interest to End Users: diet and fitness; doctors; health care professionals; health conscious; health and medicine; health and well-being; interest in health insurance; and pregnancy.
4.11 UPDATES TO THIS POLICY
We will review and update this Policy periodically and will note the date of its most recent revision at the top of this Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how IE-RE is protecting your information.
If you have any questions about this Policy or IE-RE’s privacy practices, please contact us by email at email@example.com.
Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.
To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO). Our DPO is contactable at firstname.lastname@example.org or by mail using the details provided above.
Who is the controller of my data? For the purposes of EU data protection legislation, IE-RE is the controller of your personal information.
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