Sotheby’s International Realty® Online Privacy Statement
Last modified June 2018
Thank you for visiting Sotheby’s International Realty Affiliates LLC (“SIRA”). SIRA is committed to protecting the information that you share with us, and explaining how we collect, process, store and share that information. We provide you with the notice below in English only to avoid any misinterpretations caused by a language translation. If necessary, please seek the proper advice, or please avoid use of this website.
Scope and information that this Privacy Statement covers
This Privacy Statement applies to Personal Information (defined below) collected on our websites, mobile applications, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Privacy Statement (collectively, the “Site“). It covers how we collect, use, share, and otherwise process such Personal Information as of the date that this Privacy Statement is posted. It does not apply to any other information collected by SIRA through any other means. By “Personal Information,” we mean information that identifies or can identify you personally.
The Site contains links to third-party websites, including websites of our independent franchisees. We do not own, operate or control the websites of such third-parties, or of SIRA franchisees or sales associates which are independent third parties. Accordingly, this Privacy Statement does not apply to any websites maintained or operated by third-parties, or to a franchisee’s or sales associate’s website, collection, use, storage, disclosure, or other processing of your Personal Information. When you click on those links, you will go to a third-party website where you will be subject to that website’s privacy statement and we encourage you to read that policy statement. Please be aware that we are not responsible for the privacy practices of those other websites, including those of our independent franchisees, and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information by those third-parties.
1. Collection and Use of Your Personal Information
We collect your Personal Information on the Site to enhance the services we offer you, improve the Site, and inform you about other services and products that may be available through us, our affiliated companies, our franchisees and/or our marketing partners. We collect Personal Information about you when you interact with or utilize services offered on this Site, such as:
- Registrations for special communications, such as saving a search for you and, but only if you request it, sending you new listings that fit the profile of your saved search;
- Requests to find a property, to list your property, and to find a sales associate;
- Requests to contact us;
- Requests to receive periodic industry updates;
- Requests to email a listing to a friend; and
- Requests to Find or List a Property and to Find a Sales Associate
Personal Information includes:
- Postal or billing address;
- E-mail address;
- Telephone or mobile number;
- Location via IP address;
- Device being used (for our mobile site);
- Cookies and similar technologies;
- Other relevant data.
Even if you do not send us any Personal Information, we collect certain non-personal information about how you use our Site. This information cannot identify you, and is used for statistical purposes.
2. Use and sharing of Personal Information
Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. When we disclose Personal Information to external entities to perform support services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those support services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from offline or online sources, or information we already have. We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.
SIRA’s Business Activities. We generally process and may disclose your Personal Information to others to:
- Provide you with products and services, including authenticating authorized users, and marketing our products and services;
- Perform certain services or other transactions initiated by you;
- Respond to your questions, complaints, or reviews of our product or services;
- Send you communications about online transactions, product information, ads and promotions, electronic newsletters, or other notices you requested or offers tailored to you;
- Enable our advertisers to provide you with more personalized content, and track the effectiveness of certain advertising campaigns;
- Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
- Help us run our business; or
- For any other everyday business purposes, such as product development and Site administration.
Location of Servers and Transfer of Information to the United States. The Site is hosted by servers in the United States and we operate our business globally, some countries may not provide the same level of data protection as your home country. If you are located, for example, in European Economic Area or Switzerland (collectively, “Europe“), your Personal Information will be transferred to the United States and possibly to other jurisdictions (e.g., to the location of a property for which you have requested information), which are not considered to provide an adequate level of protection under your local data protection laws.
3. Legal grounds for the collection, use, sharing, and other processing of Personal Information
Certain jurisdictions, including those in Europe, require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. SIRA relies on the following legal grounds for its collection, use, sharing, and other processing of Personal Information as described in this Privacy Statement:
- Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
- Our legitimate interests, including:
- Performance of the contract with our franchisees;
- Implementation and operation of a group-wide matrix structure and group-wide information sharing;
- Customer relationship management and other forms of marketing and analytics;
- Fraud prevention, misuse of company IT systems, or money laundering;
- Whistleblower scheme operations;
- Physical, IT, and network perimeter security;
- Internal investigations; and
- Intended mergers and acquisitions;
- Compliance with legal obligations and/or defense against legal claims, including those in the area of labor law, social security, and data protection, tax, and corporate compliance laws.
- Protection of the vital interests of any individual;
- Performance of a task carried out in the public interest or in the exercise of official authority vested in SIRA ; and
- Consent, as permitted by applicable law.
4. Your rights concerning your Personal Information
You have the following choices regarding our use and disclosure of your Personal Information:
- Marketing Communications. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed or receive any other communication from SIRA, please follow the unsubscribe link in the relevant communications or contact us using the link at the bottom of the message. Even after you opt-out or update your marketing preferences, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, surveys or recalls, or any questions regarding a specific order.
- Cookies and Similar Technologies. Please review your browser or computer settings for certain cookies and see below to exercise certain choices regarding cookies.
You are not required to provide all Personal Information identified in this Privacy Statement to use our Site, but certain aspects of our Site will not be available to you. However, you can use our services without consenting to non-essential cookies or direct marketing emails; the only consequence is that our products and services will be less communicated, we may not be able to provide the support you seek, and you may miss out on attractive promotions and news about our products and services.
Europe and certain other non-US jurisdictions maintain local data protection regulations that confer certain data protection rights on individuals. SIRA will address those rights where required by applicable laws. Note that if you are a franchisee or an employee of a franchisee, and we obtain access or otherwise process your Personal Information in that context, you should contact your employer/franchisee which will be in the best position to respond to your inquiry. If applicable, and you wish to exercise any of these rights, please contact us as set out below.
- Right of access: You have the right to obtain from us confirmation as to whether or not Personal Information concerning you is processed, and, to request access to the Personal Information. The access information includes, among other things, the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of their Personal Information undergoing processing.
- Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
- Right to erasure (right to be forgotten): Under certain circumstances, you have the right to obtain from us the erasure of Personal Information concerning you, and we may be obligated to erase that Personal Information. Personal data may reside in backup archives that must be retained for a longer period of time, either because it is impractical to isolate individual data within the archive, or because it is required to be retained for contractual, legal, or compliance reasons. Personal Information will not be restored to production systems (except in certain rare circumstances, e.g., the need to recover from a natural disaster, etc.). In such cases, Personal Information may be restored from the backup, however, all necessary steps will be taken to honor the initial request and erase the primary instance of the data. Backup archives containing Personal Information is protected with strong encryption.
- Right to restriction of processing: Under certain circumstances, you have the right to obtain from us restriction of processing your Personal Information. In that case, your data will be marked and may only be processed by us for certain limited purposes. As SIRA processes and uses your Personal Information primarily for purposes of carrying out a contract for a services relationship with SIRA may have a legitimate interest for the processing which will override your restriction request, unless the restriction request relates to marketing activities.
- Right to data portability: Under certain circumstances, you have the right to receive the Personal Information about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another entity without hindrance from us.
- Right to object: Under certain circumstances, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by us, and we can be required to no longer process your Personal Information.
- Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies which are erased when you close your browser.
- Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Site and see how such users navigate through our Site. This helps to improve how our Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
- Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it. These cookies are session cookies which are erased when you close your browser.
- Targeting Cookies: These record your visit to our Site, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Site and other websites you visit. These cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Site. You can delete these cookies via your browser settings. We will not collect these cookies from individuals in Europe without proper consent.