Effective Date: January 7, 2019.
- What Information We Collect
Information You Provide Directly:
When you use our Services, we collect a variety of information from you directly, including personally identifiable information. This information is obtained from your online registrations, searches, applications, surveys or other forms you may complete. For example, when you register to use our Services, you provide us with certain personal information, such as your name, work address, e-mail address, or phone number. If you register to purchase services through us, we may collect additional information from you, including financial and credit information, as well as details about the properties you may be interested in. You may also provide information about third parties, for example, if you share property listings with others via email. Further, we may collect information about your transactions with our affiliates or others, and may combine all information that is collected from your interactions with us, our affiliates, and others.
Information You Provide By Using Our Services:
In addition to the information that you provide directly, we collect and store information such as your unique device identifier, the page or subject areas you visit, your browser, Internet Protocol address, operating system and language, the state or country from which you access our Services, the information you request, the date and time of your visits, the websites you visited before and after visiting our websites, error logs, preferences expressed, settings are chosen, hardware and software information of your device. If you permit our Services to access location services through the permission system used by your mobile operating system, we may also collect the precise location of your device while you actively use it. We may also derive your approximate location based on your IP address. You may deactivate the location service on your mobile device but some of our Service features may be unavailable.
If you use any social networking functionality provided by us, we may access and use your social network profile information that you have made available to be shared.
- How We Collect Information
We may send cookies to your computer primarily to enhance your online experience. Cookies are small files that can identify you as a unique user and store your personal preferences or technical information (including click through and clickstream data). Cookies can either be permanent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, various features of our Services may not properly function without cookies.
We may also use tracking systems such as web beacons which monitor your use of our Services. This tracking system provides a method for delivering a graphic image on a web page for the purpose of transferring data, such as the Internet Protocol address of a computer, the Uniform Resource Locator of the page displaying the web beacon, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, web beacons let us know whether you received and opened our e-mail.
On their own, cookies or web beacons do not contain or reveal any personally identifiable information. However, if you choose to furnish personally identifiable information through our Services, this information can be linked to the data stored in the cookies/web beacons. Through your ongoing use of our Services, you specifically agree to our described methods of collecting data and information. You may adjust the privacy and security settings of your browser or mobile device to reject cookies from us or from any other site. Additionally, by setting your web browser to display HTML emails as text only, you may be able to prevent the use of some web beacons. Please consult the “Help” section of your browser for more information, or consult the instructions set forth by your mobile service provider or mobile device manufacturer. However, certain areas of our websites can only be accessed in conjunction with cookies or similar devices and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.
Unless you choose to opt-out, by using our Services, you consent that we may use or share information we have about you to enhance your user experience, determine your eligibility for a wider range of services or products available to you and provide you notification of same, customize and personalize the content provided to you through our Services, send you information about topics that may be of interest to you, perform research and analytics, provide you communications related to your account and present you with information regarding products and services from our affiliates.
Further, we may share your information with others in the following ways:
With Affiliates of Raven
Federal law gives you the opportunity to limit the sharing of “non-experience information” among affiliates of Raven. “Non-experience information” includes information that is used, expected to be used, or collected for the purpose of establishing your eligibility for consumer credit, insurance or deposit accounts, and is not related solely to your transactions or other experiences with us, including information:
- From your applications
- From a credit report, such as your credit history
- From sources used to verify representations made by you, such as your open lines of credit or employment history
We may share the customer information that we collect with our affiliated companies that provide financial and other services, such as mortgage lenders, insurance agencies, title/escrow, and other settlement services companies.
If you prefer that we not share non-experience information about you with an affiliate of Raven for marketing purposes, you may opt-out. That is, you may direct us not to share this information by emailing us at email@example.com. Federal law also gives you the option of limiting our affiliates’ use of your information that we share with them.
With Third Party Service Providers, Joint Marketers and As Otherwise Permitted by Law
We may work with non-affiliated companies or organizations to provide you with opportunities to buy products or services offered by us or jointly with other companies, including financial institutions. Consequently, we may disclose some or all of the information that we collect to the following:
- Companies that perform services on our behalf, such as data processing companies, customer/support services and other vendors; and
- Companies with whom we have joint marketing agreements.
For your protection, we require that these companies keep all personal information secure and confidential.
There may be additional times when it is necessary for us to use and share your information, and we may disclose some or all of the information that we collect as permitted by law.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including responding to any government or regulatory request
- To support compliance or audit requirements
- To detect, prevent or otherwise respond to fraud, security or technical concerns
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Services, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- In the event of a merger, acquisition or other transfer involving all or part of our business
With Other Third Parties
We may disclose some or all of the information that we collect with non-affiliated companies or other organizations, including:
- Financial service providers, such as mortgage bankers, title companies and insurance agents;
- Non-financial companies, such as retailers, direct marketers, membership clubs and publishers;
- Other companies and organizations, including non-profit organizations.
If you prefer that we not share information about you with non-affiliates of Raven, you may opt-out. That is, you may direct us not to share this information by sending us an email to firstname.lastname@example.org.
- Targeted Advertising
We may also use technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We believe that this online behavioral tracking helps to provide you with more relevant advertising based upon the websites you visit. Third parties may also use similar technologies to collect information about your online activities over time and across different third party sites, including your use of our Website.
- How We Protect Your Information
Keeping your personal information secure is one of our most important responsibilities. Only those persons who need it to perform their job responsibilities are authorized to access your information. We take commercially reasonable precautions to protect your information and limit disclosure by maintaining physical, electronic, and procedural safeguards.
- Maintenance of Accurate Information
We have established commercially reasonable procedures designed to ensure that your personal information is as accurate and complete as possible. If you believe that our records contain inaccurate or incomplete information about you, please notify us by sending us an email to email@example.com. We will take commercially reasonable steps to investigate your concerns and correct inaccurate information in a timely manner.
- Other Websites
- Children Under 13 Years of Age
- Nevada Residents Only
Through your registration, searches, applications, surveys, or other forms you may complete in the process of using our Services on Raven, we collect a variety of information from you directly, including, without limitation, name, physical address, telephone number(s) and an e-mail address. The information that we collect may be viewed, updated, and edited through your user profile available on https://admin.raven.re/settings. You may also contact firstname.lastname@example.org, per Section 5 above, should you have any questions or concerns regarding your personal information.
Your information may be shared with third parties and affiliates in accordance with Section 2 above. Additionally, third parties may look to collect information relative to your use of our Website or other sites you visit immediately prior to or after arriving at our Website, as further described in Section 3 above.
- California Residents Only
This Privacy Notice for California residents supplements the above privacy terms and applies solely to all 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 of 2018 (CCPA). This section describes the information we collect, how it may be used, how it may be shared, your rights, and how to exercise those rights. Any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
The Site collects 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, the Site has collected the following categories of personal information from its consumers within the last 12 months:
|A – Identifiers||Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.|
|B – Personal information defined in Cal. Civ. Code § 1798.80(e)||A name, address, telephone number, email address.
Some personal information included in this category may overlap with other categories.
|C – Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|D – Internet or similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|E – Geolocation data||Physical location.|
|F – Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as 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.
Raven obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Site.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
- To provide, support, personalize, and develop our Site, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Site experience.
- For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
Raven 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.
Sharing Personal Information
Raven may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
- Subsidiaries and affiliates.
- Contractors and service providers.
- Data aggregators.
- Third parties with whom we partner to offer products and services to you.
Disclosures of Personal Information For Business Purpose
In the preceding 12 months, Raven has disclosed the following categories of personal information for a business purpose to the parties identified above:
|A – Identifiers|
|B – Personal information defined in Cal. Civ. Code § 1798.80(e)|
|C – Commercial Information|
|D – Internet or similar network activity|
|E – Geolocation data|
|F – Inferences drawn from other personal information|
Sales of Personal Information
It is also important to note that Raven does not sell the personal information collected from you, including that of minors.
Your Rights and Choices
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.
Access to Specific Information – Data Portability Rights
You have the right to request that Raven 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 (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Raven 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 (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) to:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at email@example.com or by submitting a privacy inquiry.
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. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
- EU Residents
If you are a resident of the European Union, you have the following rights under the EU’s General Data Protection Regulation. Any requests you make may take up to 30 days to process. Please be sure to provide your identifying information when making the request.
- Access: You may request to access your personal information and obtain a copy of the personal information which is being processed by Raven. Such requests will be made by contacting us.
- Correction or update: You may ask us to change, update, or complete any missing data we process about you, by contacting us with the relevant updates.
- Erasure: We only process your personal information with your consent. You may withdraw your consent to our processing of your personal information at any time. Unless we believe we have a legitimate interest for continuing the processing of your personal information (e.g. to comply with our legal obligations, resolve disputes, enforce our agreements, etc.) and the personal information is no longer necessary in relation to the purpose for which it was originally collected, we will erase your data.
- Portability: You have the right to receive a copy of your personal information in a structured, machine-readable format.
To make any of these requests, please email us at firstname.lastname@example.org or submit a privacy inquiry.