Privacy Policy

Last Updated 1/1/2019.

NAI Global ("NAI Global", "us", "we" or "our") recognizes and respects its responsibility for protecting the online privacy of your personal information. As part of our commitment to privacy, we have adopted this Privacy Policy ("Privacy Policy"). We believe it is important that you understand how we collect, use, disclose and otherwise process personal information in connection with our websites, mobile apps and other services, and your rights and choices with respect to that information. For convenience, our websites and mobile apps are collectively referred to as the "Websites," and, together with our other products and services, collectively referred to as the "Services."

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

Individuals in the European Economic Arena ("EEA") should be sure to read the important information provided here, in addition to the other provisions in this Privacy Policy.

Important Information and Who We Are

Personal Information We Collect

How We Use Your Personal Information

How We Share Your Personal Information

Your Choices

Security

Sensitive Personal Information

Payment Information

International Transfer

Third Party Links

User Generated Content

Acceptance of Use

California Online Privacy Protection Act

Children

Changes to our Privacy Policy

Contact Us

Additional Information for European Economic Arena Users

Important Information and Who We Are

NAI Global is a subsidiary of C-III Capital Partners and, together with its member firms and affiliates, is a provider of commercial real estate services. This Privacy Policy governs any of the Websites on which the Privacy Policy is posted, but does not apply to the offline collection of data or to any third party or unaffiliated websites, mobile apps or online features that link to our Websites, such as those operated by our member firms or affiliates. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites.

Personal Information We Collect

Personal information means any information about an individual from which that person can be identified. NAI Global may collect, use, store and transfer personal information from our member firms, commercial real estate customers, users of our Websites and others. With a few exceptions, this information is limited to the kinds of information that can be found on a business card: first name, last name, job title, employer name, work address, work email, and work phone number.

Information you give us

You may give us your personal information when you use our Websites or correspond with us by mail, phone, email or otherwise. This may include when you fill out forms on our Websites, request specific information on a property, request information or documents we produce or distribute, or request information about our products and services. The categories of personal that you may provide to us includes:

·         Contact information, such as your first name, last name, address, telephone number and email address.

·         Profile information, such as your username and password, your photograph, occupation, industry information, professional interests, preferences and other information we may collect during the account or membership registration processes.

·         Feedback and correspondence, such as information you provide when you respond to surveys, participate in market research activities, report a problem with the Services, receive customer support or otherwise correspond with us.

·         Payment information, such as your credit card or other payment card details as described in the Payment Information section below.

·         Transaction information, such as billing details and information about products or services you have purchased from us.

·         Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Websites or otherwise submit to us through the Services.

·         Marketing information, such as your preferences for receiving marketing communications and your communication preferences.

·         Location information, such as information about your location based on technologies including GPS, IP address or connected or nearby Wi-Fi networks.

·         User content, such as blog posts, comments, questions, photographs, videos, digital media or other content you share by participating and posting content publicly through our Services.

The more information you provide, as well as the depth of its accuracy, allows us to better serve your real estate needs. Please note that, as explained in the User Generated Content section of this Privacy Policy, we ask you not to include personal information in any text you submit or files you upload to the Services or in the messages you exchange via the Services. If you choose to include personal information within those functionalities, we will not be able to limit the collection and use of that information by other users.

Information automatically collected

When you navigate through our Websites, we may automatically collect usage information about your equipment, device(s), browsing actions and patterns. We collect this information about you using cookies and other similar technologies. Please refer to our Cookies and Similar Technology Policy for more details.

Information we get from others

We may also receive personal information about you from third parties, including NAI member firms and other service providers or partners that provide information that is publicly or commercially available. For example, if you are on another website and you opt-in to receive information from us, the other website will forward your contact information to us so that we may contact you as requested. We may also collect information from public databases and other third-party sources.

Information from referrals

Existing users of our Services may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral's contact information to us.

How We Use Your Personal Information

To provide the Services

We may use your personal information to:

·         provide you with our products and services and related customer service;

·         process your account creation or other registrations, including verifying that your contact information is active and valid;

·         manage referrals;

·         respond to your requests and provide you with pertinent information regarding NAI Global products and services;

·         personalize your experience with the Websites, and to better understand your needs and interests;

·         operate, maintain, administer and improve our Services;

·         process and manage purchases and registrations you make through the Websites, including to administer a contest, promotion, survey or other site feature;

·         manage and communicate with you regarding your membership or account, including by sending you service-related messages; and

·         provide support and maintenance for the Services.

To communicate with you

If you request information from us (such as by signing up for our newsletter), register on the Websites, or participate in our promotions, surveys or other features, we may send you marketing material about NAI Global as permitted by law, unless you opt out of receiving this information.

To comply with law

We may use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to document real estate transactions or to respond to subpoenas or requests from government authorities.

With your consent

We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly.

To create anonymous data for analytics

We may create aggregated data from your personal information and other individuals whose personal information we collect. Aggregated data is anonymous and does not directly or indirectly reveal your identity, and we use that anonymous data for our lawful business purposes. For example, based on the information provided to us upon registration, NAI Global performs research on our users' demographics, interests and behavior in various phases such as: during a promotion, from our server log files or from surveys. This facilitates a better understanding of your interests and needs. The research is compiled and analyzed on an aggregated basis.

NAI Global may use and share aggregated data and other anonymous information in our discretion and without restriction.

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Your Personal Information

We may disclose the information we have collected about you, including personal information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, or in the circumstances explained below. As with all information, NAI Global will never rent or sell your personal and business-related information to third parties without your express permission.

Affiliates

We may share our personal information with our parent company, subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy, including for business, operational, and marketing purposes. NAI Global may, and reserves the right to, share your information with any other company that is not presently, but becomes, an NAI Global parent, subsidiary, or affiliate.

NAI Members, Clients and Alliance Partners

When you request information or other products and services from us, we may share your personal information with other NAI members or alliance partners for response, depending on the area of the inquiry.

In some cases consistent with this Privacy, we may share personal information in order to provide our services to clients and/or to maintain client relationships by informing our clients and prospective clients of properties and services that may be of interest to them.

Users of the Services/Visitors to the Websites

Content you submit to the Websites or through the Services may be viewable by other users of the Services. For example, other users may be able to see your NAI member profile, and your username may be associated with your comments. Please refer to the User Generated Content section for additional details.

Service Providers

We may employ third party companies and individuals to administer and provide the Services on our behalf (such as customer support, payment processing, hosting, email delivery and database management services). These third parties may use your information only as directed by NAI Global and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Social Media Networks and Connected Third Parties

Our Websites enable you to post content to social networking sites such as Facebook or Twitter. If you choose to do this, we will provide information to those websites in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy notices of the applicable social networking site(s). Please review those notices carefully, as NAI Global does not control and cannot be responsible for these providers' privacy or information security practices. See the Third Party Sites and Services section of this Privacy Policy for additional information.

Professional Advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

NAI Global may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Business Transfers

NAI Global may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, update, correct or delete your information

All NAI Global account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at privacy@naiglobal.com to request access, update, correct or delete personal information NAI Global maintains about you, or if you have additional requests or questions. Note, we may need to delete your user account in order to delete your personal information. In some cases, users may need to contact their NAI Member Firm office manager or administrator to access or update certain information, such as your email address.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain.

Marketing communications

NAI Global may periodically send you communications regarding our services and other offers or information about services that may be of interest to you. You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of marketing emails, or by contacting us at privacy@naiglobal.com. Please note, however, that you may continue to receive service-related and other non-marketing emails from NAI Global, including notices of any updates to our Terms of Use or Privacy Policy.

Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.

Security

Keeping your information private is vitally important to us. When we collect your personal information, we take a variety of security and other measures to protect that information. However, please note that no system can be 100% secure and NAI Global does not ensure or warrant the security of any information we collect.

Sensitive Personal Information

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, biometrics or genetic characteristics, criminal background or trade union membership) on the Websites, through the Services or otherwise to us.

If you send or disclose any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

Payment Information

Any payment card information you use to make a purchase on or through the Services is collected and processed directly by our payment processor, Authorize.net, and we never receive or store your full payment card information. Authorize.net commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Authorize.net may use your Payment Information in accordance with its own privacy policy, available here: https://www.authorize.net/about-us/privacy/.

International Transfer

NAI Global is headquartered in the United States and its members and partners have international sites and users all over the world. When you provide us with personal information, that information may be sent electronically to servers that lie outside the country or jurisdiction of where the information was entered originally. In addition, that information may potentially be used, stored and processed outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

Third Party Links

The Websites may contain links or connections to other websites and services, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites, applications or services (including those of our subsidiaries and affiliates), and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

User Generated Content

Whenever you submit or disclose user content and other information on our Websites - whether it be on message boards, through email or in chat rooms - that information can potentially be collected and used by others. Please do not embed personal information in the content you generate or share personal information online in public or community forums. Whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user content (including member files) or shared publicly. By posting personal information online that is accessible by the public, you may subsequently receive unsolicited messages from other parties in return.

Acceptance of Use

By visiting any part of our Websites, using our Services or otherwise providing NAI Global with personal information by any means, you accept and agree to the practices described in this Privacy Policy and your continued use of the Websites (following the posting of a revised privacy policy) means that you accept and agree to the terms of the revised privacy policy, so please check the policy periodically for updates.

California Online Privacy Protection Act

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the address provided below in the Contact Us section. 

Children

The Websites are not designed for, or directed to, children under the age of 16 and NAI Global does not intentionally collect information about anyone under the age of 16 on the Websites. If NAI Global discovers that it has inadvertently collected personal information from anyone younger than the age of 16, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 16, please contact us at privacy@naiglobal.com.

Changes to our Privacy Policy 

NAI Global reserves the right to make changes to this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or another manner through the Services that we believe reasonably likely to reach you (which may include posting a new privacy policy on our Site - or a specific announcement on this page).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have questions or comments about our Privacy Policy or privacy practices, please contact us at privacy@naiglobal.com.  We can also be contacted by mail at:

New America Network, Inc. a Delaware Corporation d/b/a NAI Global

Attn: President

717 Fifth Avenue, 15th Floor

New York, New York 10022

United States

Additional Information for European Economic Arena Users

Personal information

References to "personal information" in this Privacy Policy are equivalent to "personal data" governed by data protection legislation in the EEA. For more information on the EEA, click here.

Controller

NAI Global of New York City, Inc. is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details.

Our representative in the European Union is Alan Froggatt. You may contact our representative at

afrog@touchstoneadvisers.com

+ 44 (0) 1428 687 866

Legal bases for processing

We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at privacy@naiglobal.com.

Processing purpose (click link for details)

Legal basis

To provide the Services

Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for or interacting with the Services.

To communicate with you
To create anonymous data for analytics
For compliance, fraud prevention and safety

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with law

Processing is necessary to comply with our legal obligations

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at privacy@naiglobal.com.

To share your personal information as described in this Privacy Policy

This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

·         Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.

·         Access. Provide you with information about our processing of your personal information and give you access to your personal information.

·         Correct. Update or correct inaccuracies in your personal information.

·         Delete. Delete your personal information.

·         Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

·         Restrict. Restrict the processing of your personal information.

·         Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.

You can submit these requests by email to privacy@naiglobal.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Applicable law may also require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

 


Cookies and Similar Technology Policy

Last Updated: 1/1/2019

What are cookies?

We may use cookies to collect information and enhance your user experience. A cookie is a small amount of data sent from a web server to your browser and stored on your computer's hard drive. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to augment your online experience via the information you provide. We do not use them for tracking purposes - rather they are used mainly for statistical reasons, i.e., the date and time of access, the domain from which you access the Internet, the Internet address of the website from which you linked directly to our site. NAIglobal.com uses and stores this information to provide you with more personalized and customized on-line services and to make our site more convenient, useful, valuable and appealing to you.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Websites; and (2) third party cookies, which are served by service providers on our Websites, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Websites use the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with Services available through our Websites and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our Websites to remember choices you make when you use our Websites, such as remembering your language preferences, remembering your login details and remembering the changes you make on other parts of our Websites which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Websites or use our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Websites and how users use our Websites and Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. The information gathered may include the number of visitors to our Websites, the websites that referred them to our Websites, the pages they visited on our Websites, what time of day they visited our Websites, whether they have visited our Websites before, and other similar information. We use this information to help operate our Websites and Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Websites and Services.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

Targeted and Advertising Cookies

These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or "like" button on our Websites or Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies

If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can typically instruct your browser, by changing its settings, to remove or stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. In order to do this, consult your browser's technical information (instructions are usually located within the "settings," "help" "tools" or "edit" facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you do not accept our cookies, you may experience some inconvenience or not be able to use all portions of the Services or all functionality of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Websites.

Do not track signals

Some internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.