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El Towne LLC Privacy Notice

Last Updated: April 27, 2025

Understood. Here’s a revised El Towne LLC Privacy Notice, employing different phrasing while maintaining legal terminology:

El Towne LLC Privacy Notice

Date of Last Revision: April 27, 2025

El Towne LLC (“El Towne,” “we,” “us,” or “our”) values the privacy of your information. This Privacy Notice (“Notice”) articulates the modalities of processing Personal Information (as hereinafter defined) that is furnished, acquired, or divulged in the course of providing our services to you (“Services”) and across the websites, applications, and online interfaces that reference this Notice (collectively, the “Site”), including instances where you submit an application for employment with us. Furthermore, this Notice delineates the rights you may possess under extant legal frameworks. We urge you to peruse this Notice meticulously to comprehend our established policies and customary practices concerning your Personal Information and the manner in which we shall handle it.

Categorization of Personal Information Collected

We procure various classifications of Personal Information pertaining to users of our Site and Services. “Personal Information” denotes data that uniquely identifies, relates to, describes, or can be reasonably associated with or linked to you. The types of Personal Information we may collect encompass:

  • Contact Particulars: Should you submit an inquiry, establish an account, or furnish data on or through our Site or Services, we may gather your contact details, including your appellation, electronic mail address, and telephonic contact number.
  • Demographic Attributes: We may collect specific data concerning your age, gender, disability status, marital status, or status as a veteran.
  • Unique Identifiers: We may collect your driver’s license number, state identification number, passport number, or Social Security number.
  • Usage Metrics: During your interaction with our Site, we may automatically log information, such as your Internet Protocol (IP) address, the geographic location of your device, your browser specification, referring URLs (e.g., the preceding website you visited), domain names associated with your internet service provider, and other data regarding your engagement with our Site.
  • Employment-Related Data: In the event of your application for employment with us, we shall collect Personal Information pertinent to your potential employment, including your educational background, employment history, residential and contact information, demographic data, and any other information contained within your curriculum vitae or application dossier.
  • Financial Standing Information: We may collect financial details regarding your creditworthiness, personal financial affairs, and history related to real estate and rentals.
  • Communication Records: We may collect Personal Information contained within your communications with us via electronic mail, chat functionalities, social media platforms, telephone conversations, or other modalities, and in certain instances, we may engage third-party service providers for this purpose. Where permissible under applicable law, we may record and maintain logs of calls and chats with our agents, representatives, or employees via messaging, chat interfaces, posts, or similar features.

Mechanisms for Collecting Personal Information

  • Directly from You or Authorized Sources: We collect Personal Information that you directly provide to us, for instance, when you elect to contact us, request information from us, subscribe for updates, or otherwise utilize our Site or Services. Furthermore, you may instruct third parties, such as your real estate agent, broker, lender, escrow agent, or similar entities, to disclose Personal Information to us. Similarly, should you authorize us to procure a credit report or conduct a credit assessment, we may obtain Personal Information about you from such third parties, in accordance with relevant legal statutes.
  • From Third-Party Entities: We may acquire Personal Information from third parties, including but not limited to commercial partners, advertising networks, social media platforms, data analytics vendors, mobile device manufacturers, internet or mobile service providers, recruitment agencies and job application portals, and background verification services.
  • Via Online Tracking Technologies: We employ cookies and analogous technologies to automatically collect Personal Information as you navigate our Site. For supplementary details concerning our utilization of these technologies, please consult the “Cookies and Tracking Technologies” section infra.

Purposes for Utilizing Personal Information

To the extent sanctioned by applicable law, we utilize Personal Information for the following ends:

  • To furnish and personalize our Site and Services, such as delivering homebuyer assistance, fulfilling your requests for property acquisitions, processing or executing orders and transactions, managing payments, providing customer support, maintaining or servicing accounts, verifying customer credentials, creating and maintaining business records, confirming eligibility, and undertaking or supplying analogous services. We restrict our use of Personal Information obtained through directed disclosures to purposes consistent with the solicited disclosure or authorization.
  • To optimize, refine, and maintain our Site, including comprehending user interaction patterns, assessing user interest in specific Site functionalities, and resolving technical issues.
  • For internal research and development endeavors, such as testing, validation, and enhancement of our Site’s quality.
  • For marketing and advertising initiatives, including the use of your information to disseminate messages, notifications, newsletters, surveys, promotions, or invitations to events concerning our own or third parties’ goods and services that may be of interest to you. We also employ Personal Information for interest-based advertising, as detailed in the “Cookies and Other Tracking Technologies” section below. You retain the option to unsubscribe from any marketing emails or text messages we may send by adhering to the instructions provided within the email or text correspondence or by contacting us at privacy@eltownehome.com.
  • For communication purposes with you, such as responding to your inquiries and feedback or informing you of modifications to our Site or Services.
  • For legal, security, or safety imperatives, such as safeguarding our and our customers’ safety, property, or rights; adhering to legal mandates; enforcing our terms, conditions, and policies; detecting, preventing, and addressing security incidents; and protecting against malicious, deceptive, fraudulent, or unlawful activities.
  • As an integral part of a corporate transaction, such as in connection with the sale of a portion or all of our assets or business, the acquisition of a portion or all of another business or another business’ assets, or another corporate transaction, including bankruptcy proceedings.
  • To fulfill any other purpose for which you provide it, including purposes disclosed when you furnish the information or grant your consent.

In the context of your application for employment with us, we also utilize Personal Information to process your application, verify the information you have provided, conduct interviews, perform background and reference checks, communicate with you and address your queries, confirm your eligibility for employment, and improve our recruitment methodologies. We may also retain your Personal Information for consideration in future employment opportunities within our organization.

Modalities of Personal Information Disclosure

We may disclose aggregated information (i.e., information that does not identify any individual) without limitation. We may disclose your Personal Information with your explicit consent or under the following circumstances:

  • Employees and Personnel: We may share Personal Information with our employees and personnel (including contractors) who have a legitimate need to access the information for our business operations.
  • Affiliates and Subsidiaries: We may share Personal Information within our corporate family for their and our business and marketing objectives, including providing you with information about products or services we believe may be of interest to you.
  • Service Providers: We divulge your Personal Information to service providers who support our business functions, including but not limited to data analytics firms, website hosting services, and other technology vendors. For job applicants, this may include service providers such as background check agencies and human resource management platforms.
  • Business Partners: We may disclose Personal Information to trusted business partners. For instance, we may share your Personal Information with entities whose products or services we believe may be of interest to you or with whom we jointly sponsor promotions or services.
  • Ad Tech Companies and Other Providers: We may share or make accessible limited Personal Information (such as mobile device identifiers) with advertising technology companies and other online service providers. When we share your Personal Information in this context, we adhere to applicable legal requirements, which may necessitate the provision of opt-out rights or other individual rights.
  • Legal Obligations or Safety Imperatives: We may disclose Personal Information to a third party when we possess a good faith belief that such disclosure is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential breach of any agreement you have with us, (c) detect, prevent, or otherwise address fraud, security, or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of El Towne, its employees and clients, or the public against harm.  
  • Merger or Change of Control: We may disclose Personal Information to third parties as necessary in the event of a merger, acquisition, or any other transaction involving a change in the control of our business, including but not limited to bankruptcy or similar proceedings. Where legally mandated, we will provide you with prior notification of such disclosure.  
  • Other Circumstances: We may disclose Personal Information to third parties when explicitly requested or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of disclosure (or as was reasonably apparent at the time and point of disclosure).  

Cookies and Other Tracking Technologies

We and our service providers may utilize cookies and analogous technologies to gather usage and browser information concerning your interaction with our Site. The technologies we employ for this automated data collection may include cookies and web beacons, which enable us to verify system and server integrity and compile statistics regarding the popularity of specific content. We process the information collected through these technologies, which may include or be combined with Personal Information, to facilitate the operation of certain features of our Site, to enhance your experience through personalization, and to gain a deeper understanding of the aspects of our Site that you and other users find most engaging.

Website Delivery and Appearance: We may engage third-party providers to facilitate certain customer interaction opportunities, content delivery (such as audio or video), or other service functionalities. Examples include, but are not limited to, the following functionalities:

  • Content Delivery: We collaborate with service providers to host our Site and deliver specific content in support of our Services. For instance, we may utilize services to serve fonts on our Site, governed by their respective privacy policies. We may also partner with platforms like YouTube for specific content delivery, such as audio and video, and their data handling practices are detailed in their privacy policies.
  • Customer Interaction: We may enhance our customer interactions by offering features like mapping services to locate our establishments. These offerings are subject to the terms, conditions, and policies of the respective service providers.
  • Chat-based Support: We may implement a Live Chat feature powered by a third-party vendor to provide real-time customer service and technical assistance via our Site. When you engage with the live chat enabled by this provider, we will automatically collect and share certain information (such as personal identifiers, usage data, and message content) with the vendor to facilitate the customer service and technical support enabled by the chat tool. For further details on the specific information collected through this tool and its handling by the provider, please refer to their privacy policy.

Website Analytics: We utilize analytics services that employ cookies and other technologies to collect your Personal Information, assisting us in analyzing our Site traffic and usage patterns to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising strategies). These may include third-party services such as Google Analytics and Meta Pixels. To gain insights into how these services manage data, please consult their respective privacy policies. While you may have the option to download opt-out browser add-ons for certain analytics services, this action does not preclude the use of other analytics tools.

Interest-Based Advertising: We may also permit or enable third parties to collect Personal Information to deliver interest-based advertisements on behalf of our products and services, or their own offerings. Interest-based advertising occurs when you are shown advertisements predicated on information gathered from your online interactions over time and across various websites, devices, or online services you visit or utilize. Certain entities may engage in cross-context behavioral advertising to predict your preferences and present advertisements most likely to resonate with your interests or relevance. We do not exert control over these third parties’ collection or utilization of your information for these purposes, or the opt-out mechanisms they may independently offer through their terms, conditions, and privacy policies. Should you have any inquiries regarding an advertisement or other targeted content, you should directly contact the responsible provider. Examples of third-party service providers we may engage for interest-based advertising include Google Ads, Meta Ads, LinkedIn marketing solutions, Microsoft advertising, and Adobe Audience Manager. It is within this context that we may furnish advertising networks, data analytics providers, social media platforms, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information within the preceding twelve months.  

Sale of Personal Information: While we do not exchange Personal Information for monetary compensation, we may disclose Personal Information for other benefits that could be construed as a “sale” under various data protection laws, as this term is sometimes broadly defined to encompass activities such as the delivery of interest-based advertising on websites or allowing third parties to receive specific information, such as cookies, IP addresses, and/or browsing behavior.

Cookie Choices: To manage your preferences concerning these technologies, you may:

  • Visit our preferences portal or customize your browser settings to reject all or specific browser cookies or to receive alerts when websites attempt to set or access cookies. If you disable certain cookies, please be aware that some functionalities of our Site may not operate correctly. These settings may be lost and require reconfiguration if you subsequently delete your cookies.
  • Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt-out pages of the self-regulatory programs in which these companies participate: the National Advertising Initiative and the Digital Advertising Alliance (or the European Interactive Digital Advertising Alliance, if you are located within the European Economic Area). Please note that even if you opt out of interest-based advertising, you may still encounter “contextual” advertisements that are based on the content you are viewing on the websites and pages you visit.  
  • Review and implement any provider-specific instructions to customize your preferences or opt out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt out of this type of advertising by Google, adjust your ad preferences or limit Google’s collection or use of your data by visiting Google’s Safety Center and Google’s Ad Settings and following Google’s personalized ad opt-out instructions. To opt out of advertising under Adobe Audience Manager, please follow Adobe’s Experience Cloud opt-out instructions. Meta also provides an Ad Preferences center for customizing your settings, as well as a Privacy Policy with additional information on exercising your rights.  

Retention Period for Your Personal Information

We retain your Personal Information for the duration necessary: (i) to conduct our business relationship with you; (ii) to fulfill the purposes delineated in this Notice; and (iii) to comply with our legal obligations, resolve disputes, and enforce any contractual agreements. Criteria we will employ to determine the appropriate retention period for your Personal Information include the nature and duration of our business relationship with you; our legal entitlements, obligations, and retention mandates; and whether we have a continuing business rationale for retaining your Personal Information, such as ongoing communication regarding Services you have requested or may request in the future.

Links to External Websites

We bear no responsibility for the data handling practices of any websites or services linked to or from our Site, including the information or content contained therein. We advise you to conduct your own investigation and pose any necessary questions before disclosing Personal Information to third parties, as any Personal Information you disclose will be managed in accordance with the applicable third party’s privacy policy. In certain instances, we provide links to social media platforms (such as Facebook, LinkedIn, Instagram, Pinterest, X (formerly known as Twitter), and YouTube) that facilitate your direct connection with us or the sharing of information on social media. Any content you post through these social media pages is subject to the terms of use and privacy policies of those respective platforms. We may also integrate with other websites to offer enhanced services, technological capabilities, or resources for your benefit. These integrated services and functionalities are governed by the terms, conditions, and policies of the respective underlying companies. Some of the integrations we currently offer include the ability to view our business and/or provider profiles on platforms like Google and Facebook, including publicly posted customer reviews. This hyperlinked content (including any embedded customer reviews) is governed by the privacy policies of each platform, and the links to these external websites and services are provided for your convenience. We may also offer you the option to log in to El Towne platforms using third-party services such as Facebook, LinkedIn, or Google. If you choose to utilize this option to link your accounts, we will receive information associated with your account (such as your name and profile information) from that third-party service. The specific information received varies and is controlled by that service or as authorized by you through your privacy settings on that service. We recommend reviewing the service’s privacy policy beforehand and managing your privacy settings on an ongoing basis.  

International Data Transfers

If you are accessing our Site from a location outside of the United States, please be aware that our Site is hosted within the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be recognized as providing an equivalent level of data protection as your country of residence, as deemed necessary for the purposes articulated in this Policy.  

Measures to Protect Personal Information

We have implemented commercially reasonable measures designed to secure your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. Notwithstanding these efforts to maintain Personal Information in a secure environment, the transmission of information via the internet is inherently not entirely secure, and therefore, we cannot provide an absolute guarantee regarding the security of Personal Information during its transmission or its storage on our systems.  

Exercising Your Data Privacy Rights

Depending on your place of residence, you may possess the subsequent entitlements concerning your Personal Information under pertinent data protection statutes:

  • Right of Access: The prerogative to request and obtain a copy of any Personal Information pertaining to you that we may maintain.
  • Right to Erasure: The prerogative to demand the deletion of your Personal Information that we have collected or acquired, subject to certain statutory exceptions.
  • Right to Rectification: The prerogative to request that we amend any inaccuracies present within your Personal Information, subject to certain limitations stipulated by law.
  • Right to Object to Certain Processing: The prerogative to: (a) object to the processing of your Personal Information for the purposes of targeted advertising, (b) object to the sale or sharing of your Personal Information; (c) restrict the use of your sensitive Personal Information (if applicable), and (c) object to profiling in furtherance of decisions that produce legal or similarly significant effects. As we do not engage in the collection or processing of sensitive Personal Information beyond legally sanctioned purposes, we do not offer an option to limit its use. Furthermore, we do not profile you or other individuals in a manner that would engender legal or similarly significant effects, and thus, we do not provide an opt-out mechanism for such processing.
  • Right to Lodge a Complaint: The prerogative to file a grievance with a supervisory authority or other regulatory body if you hold the belief that we have contravened any of the rights afforded to you under applicable data protection laws. We encourage you to initially contact us to afford us the opportunity to directly address your concerns prior to such action.

To invoke any of the data privacy rights granted to you under applicable data protection laws, please direct your inquiry via electronic mail to privacy@eltownehome.com, by telephone to 1-844-242-7644, or by submitting a request through our designated Request Form. You may also exercise your opt-out rights by transmitting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We duly honor Opt-Out Preference Signals, including GPC. Should you elect to utilize an Opt-Out Preference Signal, it will be necessary to enable it for each supported browser or browser extension you employ.

You will not be subjected to discriminatory treatment of any kind by virtue of your exercise of the rights enumerated within this Notice. However, should you withdraw your consent or object to the processing of your Personal Information, or should you choose not to provide certain Personal Information, we may be constrained in our ability to provide some, or all, of our Services to you.

Only you, or an agent duly authorized by you to act on your behalf, may submit a request pertaining to your Personal Information. We are obligated to verify your identity prior to fulfilling your requests, and in the event that we are unable to authenticate your identity, we may solicit supplementary information from you. If you are an authorized agent acting on behalf of another individual, we will also be required to verify your identity, which may necessitate the provision of documentary evidence of your written authorization or a power of attorney. We endeavor to respond to requests within the timeframe mandated by applicable law. Should we require additional time, we will inform you of the reason for the delay and the extended response period in writing.

We do not impose a fee for processing or responding to your requests unless they are manifestly unfounded or repetitive. If we determine that a request warrants a fee, we will apprise you of the basis for this decision and furnish you with a cost estimate before proceeding with your request. We reserve the right to deny certain requests, or to fulfill them only in part, as permitted or required by law. If you are dissatisfied with the resolution of your request and you are afforded a right to appeal such a decision, you will be informed of our appeal process in our response to your request.

Children’s Privacy

We do not knowingly collect or solicit any Personal Information from individuals defined as children under applicable law without verified written consent from their legal guardian, and we possess no actual knowledge of selling the Personal Information of minors under the age of 16. Upon learning that we have inadvertently collected Personal Information from a child, we will undertake prompt measures to delete that information. If you have reason to believe that we may possess any information from or about a child, please contact us at privacy@eltownehome.com.

California Residents

This section furnishes supplementary disclosures regarding El Towne LLC’s practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), wherein “Personal Information” carries the definition ascribed to it in the CCPA.

Please refer to the subsequent matrix for detailed information concerning the categories of Personal Information we have collected from California residents during the twelve months preceding the date of the most recent update to this Notice, as well as the categories of third parties to whom we “Sell” or “Share” Personal Information (as those terms are defined under the CCPA). For each category of Personal Information listed in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are detailed in the “How We Disclose Personal Information” section above.

| Personal Information Category set forth in Cal. Civ. Code § 1798.140 – Do Not Sell or Share this category of Personal Information. | Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion. | – Do Not Sell or Share this category of Personal Information.

California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at privacy@eltownehome.com. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

Changes to this Notice

Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Site. You are responsible for periodically visiting our Site and this Notice to check for any changes.

Contact Us If you have any questions about our practices or this Notice, please contact us at privacy@eltownehome.com.