Effective Date: February, 2019
Collection and Use
2. Information Sharing
3. Your Choices
4. Individual Rights in Personal Information
5. Information Retention
6. Information Storage and Security
7. Other Important Information
1. Information Collection and Use
The types of information we collect depends on your level of engagement with the Services. The more you interact with the Services, the more information we need to provide the Services. This Section explains how we collect and use information based on your level of engagement with the Services.
A. All Users of the Aillion Sites
From registered and unregistered users of the Sites, we automatically receive and record information whenever you interact with the Sites. This includes IP address data from our server logs, cookie information, browser information, information about your activity while on the Sites (such as the pages you request, properties that you view or save, and property that you claim), and the URL of the site you came to the Sites from. We also may collect the mobile device ID (such as the ID for Advertising on iOS and Android ID on Android) from users of the Aillion Applications. If permitted by the settings on your device and with your consent, we will also collect your geo-location information. We use this to provide you with location specific information, such as homes for sale near your current location as determined by your geolocation, and information about listing your home for sale based on your geolocation. We may also approximate your location based off your IP address.
We may also use the information listed above to help diagnose problems and performance with the Services, analyze trends, customize your experience, and administer the Services. We may provide IP addresses to third-parties to help us analyze website user survey data. We may also use the information described in this section to better target information about Aillion's Sites and Services, for example, by displaying more accurate or relevant information on our Sites, matching you to a public record listing of a property, tailoring the advertising we display on third party websites and platforms, and sending better targeted and tailored messages, including via email and/or push notifications.
B. Registered Users of the Aillion Sites
- My Aillion: My Aillion is a feature that allows you to upload notes and photos about a property, save searches, add favorites and x-outs, and otherwise organize homes that may interest you. We save all of this "My Aillion" information for your use later. It is stored with your Aillion account information.
- Account Password Security: Your Aillion account password is encrypted on our server. It is your responsibility not to disclose your password to other people, and to ensure you maintain its security.
- Account Updates: By visiting your My Aillion: Account Settings, you can correct, amend, add or delete Personal Information associated with your account. However, even after you update information, we may maintain a copy of the original information in our records.
C. Home Tours, Real Estate Classes, and other In-Person Meetings
When you submit a home tour request, we will ask for your tour date and time preferences, as well as your phone number. We may ask for similar information when you request or attend a home buying or selling class, or when you request or attend a strategy session or similar in-person meeting with a Aillion agent. We may also ask some questions so that our agent can verify your identity, and such information will be used to register you for a Aillion account. When you meet up with one of our agents, the agent may ask you to verify your identity, and may even ask to see a photo ID.
D. Aillion Clients
E. Communications with Aillion
Aillion may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
We may send marketing materials to Aillion account holders and clients using various communication channels, including without limitation, email, text messages/SMS, push notifications, telephone calls, and direct mail. Individuals may also subscribe to Listing Alert Emails or other notifications with information such as customized summaries of homes for sale. If you opt-in to also receive marketing messages, Aillion may send you Aillion-related news and surveys.
G. Call Recording
We may record any telephone calls between you and our agents or other representatives for training and quality assurance purposes.
Aillion may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
I. Sharing with Friends or Colleagues
Aillion's Services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request.
J. Interactive Features
Aillion may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered "public" and will not be subject to the privacy protections referenced herein.
K. De-Identified and Aggregated Information
We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Sites and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purpose.
L. Conferences and Trade Shows
We may attend conferences and trade shows where we collect Personal Information from individuals who interact with or express an interest in Aillion and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
M. Information We Collect Automatically
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
N. Cookies and Pixel Tags/Web Beacons
- Cookies. Cookies are small text files placed in visitors' device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Sites that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.
O. Information from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.
P. Other Uses of Information
We may use any of the Personal Information we collect for the following purposes:
- to respond to your questions or inquiries;
- to conduct promotional activities, including contests;
- to undertake internal research for technological development and demonstration;
- to improve, upgrade or enhance our Sites and Services;
- to send you informational or promotional communications that you have agreed to receive;
- to carry out other purposes that are disclosed to you and to which you consent;
- to detect security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
- to identify and repair errors that impair existing intended functionality;
- to undertake activities to verify or maintain the quality or safety of a Service;
- to pursue our legitimate interests where your rights and freedoms do not outweigh these interests; and
- to carry out automated decision making and/or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are required by law to do so.
2. Information Sharing
We may share your Personal Information as set forth below:
A. Public Record Information: Please be aware that home sales and purchases may be a matter of public record, and your name and address, the price you paid, your property taxes, and other information may be available from public sites regardless of the brokerage(s), if any, who assist in the transaction. We post on our Sites some information that typically becomes part of the public record of a home sale or purchase.
B. Non-Public Record Information: We share information obtained from you, MLSs and other third party sources that is not on the public record to facilitate your home purchase or sale transaction. This includes:
- Service Providers to all Aillion Clients: Our agents work with third parties to process your home search and sale transaction, and must share your information with those third parties. Examples include MLSs and providers of software used for document preparation and electronic signing.
- Partner Agents: A Partner Agent is employed by or works with another brokerage and is not a representative or employee of Aillion. Partner Agents have contracted with us to provide Aillion-quality service to a wider range of customers. We'll refer you to a Partner Agent in our discretion. If you are referred to a Partner Agent for your home purchase or sale transaction, we share your information with that Partner Agent so they can assist you. Aillion is not responsible for the work performed or the services provided by Partner Agents in any manner.
- Home Seller Service Providers: As is customary as your home sales agent, we share your listing information with MLSs and other listing websites, such as Realtor.com, Trulia.com and Zillow.com. As a result, your listing may appear on more than one website. We may also share your listing and contact information with listing vendors such as photographers, home staging experts and home repair professionals like plumbers and electricians, as needed.
- Home Buyer Service Providers: As is customary as your home purchase agent, we must share your buying information with inspectors, title companies, escrow agents, closing attorneys, lenders, and other third parties as needed to process your transaction.
- Potential Buyers: By law, we are required to disclose certain information about your property to potential buyers.
C. Negotiations: We also post price offers and counteroffers on our Sites. We do not post your name on our Sites without your permission but if the sale is closed, the price and the fact that you bought or sold your house at that price may be a matter of public record.
D. Aillion Corporate Family: We may share your information with members of the Aillion family of entities for various purposes, including to: (i) provide the Services to you; (ii) help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; (iii) help with marketing initiatives; and (iii) manage and improve Aillion products, Sites, Services and tools.
E. Aillion Requests: Through the Services, you can make a request to tour a home, get in contact with a real estate agent, receive help selling or buying a home, or submit other requests. When you make such a request through Aillion, you authorize Aillion to share your Personal Information including your contact information, home search history, favorites and saved searches, with a real estate professional (a Aillion Agent or staff member, or a Partner Agent) for the purpose of responding to your request.
G. Business Partners: We may provide Personal Information to business partners to provide you with a product or service you have requested. We may also provide Personal Information to business partners with whom we jointly offer products or services.
H. Third-Party Cookies and Information Used to Target Ads to You: We may share the information that we collect about you with others (including advertising networks and service providers) to tailor and serve you ads on our Services, as well as other websites and social media networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." These advertising networks track your online activities over time by collecting information through automated means, including through the use of Technologies (e.g., cookies, web-beacons and other methods). This allows Aillion to target our advertising to you through demographic, behavioral and contextual means. As a result, you may see ads for Aillion on other websites and social media.
I. APIs and SDKs: We may use third party APIs and software development kits ("SDKs") as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
J. Information Disclosed in Connection with Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
K. Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal processes (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable.
L. Other Purposes: Aillion may share your Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.
3. Your Choices
You may have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. Even if you opt out, we may still collect and use Personal Information regarding your activities on our Sites, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
B. Electronic Messages, Phone Calls and other Communications
C. Opting-Out of Technologies and Tracking
- Aillion Cookies: We put Aillion cookies on your device's browser to help us keep track of when you were last on the Sites, and what you last searched on the Sites. While you are free to disable cookies on your browser, we recommend that you leave cookies activated to use some of the most useful Aillion features.
D. Mobile Devices
We may send you push notifications through the Aillion mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Aillion may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
E. Delete your Account
You may delete your Aillion account on your My Aillion: Account Settings page under "Close Account" section. We retain Personal Information for as long as we have a valid business purpose to or to meet our legal obligations. Aillion may be required to keep a copy of your Personal Information in accordance with Section 5 below.
4. Individual Rights in Personal Information
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the "right of data portability"); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; and (vi) request erasure of Personal Information held about you by Aillion, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, Aillion may take steps to verify your identity before fulfilling your request.
5. Information Retention
6. Information Storage and Security
Aillion is headquartered in the United States. You agree that we may store and process the information we collect anywhere in the world, including but not limited to, the United States, the European Union, or other countries.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
7. Other Important Information
The Sites and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us at the email address below with the subject line "COPPA Child Information Request." If we learn that we have collected any Personal Information from a child in violation of applicable law, we will promptly take steps to delete such information.
B. Supervisory Authority
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.
C. Links to Third Party Sites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Sites or other Services. These other websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. Aillion does not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
E. Contact Us
Attn: Legal Dept
43046 Christy St
Fremont, CA 94538