This Privacy Policy explains how we collect, use, disclose and retain personal information through your use of www.anasofiasada.com and any other Zarco Properties’-owned website that is controlled by Zarco Properties, LLC (collectively, the “Site”) and the services, products, platforms, features, content or Applications (as defined in the Terms of Service) offered by Zarco Properties, LLC d/b/a Zarco Properties and its affiliates (collectively, “Zarco Properties,” “we,” “us,” or “our”) (collectively with the Site, the “Services”). Our Services are intended for U.S. residents only.

“Affiliates” include companies, real estate brokerages and various title and escrow companies. For more information on the terms and conditions of some of our Affiliates, please review their Privacy Policies.

“Agents” are people and other entities we contract with, including our independent contractor licensed real estate salespersons and brokers, that may offer or provide services to you. Please note that although Agents may elect to use Zarco Properties designated email addresses or marketing materials, Agents are independent contractors who are not employed or controlled by Zarco Properties. This Privacy Policy does not govern your interaction with Agents outside of the Site, and you will be governed by other privacy terms, if any, of the websites or services through which you are interacting with those Agents.

1. What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“PII”) and other information collected in connection with your use of, or access to, the Services. This Privacy Policy also covers our treatment of any PII that we collect outside the Services and are combined with such PII collected in connection with your use of, or access to, the Services. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any landlords, renters, owners, buyers, and third-party websites, services and applications (“Third Party Services”) that you elect to access through the Services or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy or that you request through your use of the Services, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access, including without limitation those of our Agents.

2. What Information Do We Collect?

In connection with certain aspects of the Services, we may request and collect PII as well as other information in connection with your use of, and access to, the Services. We collect the following types of information from our users.

• Information You Provide Us: You may choose to provide us with certain information that could include, without limitation, PII, such as your name, date of birth, age, email address, mailing address, phone number, geolocation data, employment information, social security number, demographic information, electronic network activity information, rental listing information, financial information, credit card or other payment information, background check information, rental application information, information contained in any lease or purchase agreement you are negotiating or entering into, photo identification, reference letters, bank statements, GCI, income tax returns, or address of a listing you intend to rent, or other information we request from you that is required by law.
• Information Collected Automatically: We also receive and store certain types of information whenever you interact with the Services. We automatically receive and record information in our server logs from your browser, including your IP address, search queries, cookie information, mobile device identification and the listings and pages you request. We may also record the details of your activity on the Services. This information may be used by us to develop new services or improve the Services and may be shared with third parties in order to do so.
• Information Collected Using Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet. We sometimes use cookies to identify that your web browser has accessed aspects of the Services. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties, including our third-party partners and service providers, but third-party cookies may be used in order to develop new services or improve the Services.
• Information Collected from Third Parties: If you choose to register on our Site or otherwise link your Zarco Properties account with a third party’s service (such as Facebook or another third-party website), we may receive the same type of information we collect from you (described above) directly from those services. We may receive additional information about you, such as demographic data, employment information, social media networking and imprints or fraud detection information, from third party partners and service providers and combine it with other information that we have about you.
• Information Collected from Agents: If you choose to use our Site or Services, we may receive certain information about you through our Agents. Such information may include, without limitation, PII, such as your name, date of birth, age, email address, mailing address, phone number, employment information, social security number, demographic information, rental listing information, financial information, credit card or other payment information, background check information, rental application information, information contained in any lease or purchase agreement you are negotiating or entering into, photo identification, reference letters, bank statements, GCI, income tax returns, or address of a listing you intend to rent, or other information an Agent may request from you that is required by law or is otherwise required to facilitate a real estate transaction. By providing this information to our Agents, you understand that we may store such information and contact you to send you information about a real estate transaction, the Services, Zarco Properties, or for any other reason set forth in this Privacy Policy.

3. How Do We Use Your Information?

In addition to the uses set forth above, we may use information that we collect about you or that you provide to us, including any PII:

• to present the Services and its contents to you;
• to present brokerage services through our Affiliates to you;
• to present other adjacent services through our Affiliates to you;
• to develop Services that help Agents provide real estate transaction services to you;
• to provide you with information or services that you request from us;
• to fulfill any other purpose for which you provide it;
• to contact you regarding the Services or your account;
• to provide you with promotional information regarding the Services;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to the Services or any services we offer or provide through the Services;
• to allow you to participate in interactive features of the Services;
• to conduct research and development for the improvement of the Services, the development of new services and offerings and in connection with our business;
• in any other way we may describe when you provide the information; or for any other purpose with your consent.

We do not sell your PII to any third parties, nor do we use any of your SPI to create profiles or inferences in furtherance of decisions that produce legal or similarly significant effects concerning a customer.

4. How, And With Whom, Is My Information Shared?

• Affiliates: We may receive and share your PII or other information about you with our Affiliates to develop or provide the Services. Information we share with and receive from Affiliates includes, but is not limited to, your name, email address, address, phone number, geolocation data, employment information, social security number, demographic information, electronic network activity information, rental listing information, financial information, credit card or other payment information, background check information, rental application information, information contained in any lease or purchase agreement you are negotiating or entering into and related transaction information, photo identification, reference letters, bank statements, GCI, income tax returns, or address of a listing you intend to rent, other information we request from you that is required by law, or any other information you provide to us or our Affiliates.
• Information Shared with Our Agents: We may share PII with our Agents in connection with their provision of services to you related to the sale, purchase, lease or financing of properties and the advertising and marketing of such properties and related services.
• Third-Party Partners and Service Providers: We may receive additional information about you, such as demographic data, employment information, or fraud detection information, from third party partners and service providers and combine it with other information that we have about you. We work with third-party partners and service providers to perform Services on our behalf, and we may share your PII with such third-party partners and service providers to help us provide the Services.
• Email Communications, Phone Calls, SMS Communications with Us and Other Users: As part of the Services, you may occasionally receive email, phone calls or SMS (text), and other communications from us, such as communications relating to a transaction, promotions, marketing, and recruiting. By creating an account on our Site, you acknowledge and agree that by providing us with your contact information and/or posting information on or through the Services, or requesting that we do so on your behalf, we and our Agents, the landlords, tenants, buyers or sellers relevant to your request for Services, and others may send you e-mail, call you or text you or otherwise contact you or engage in other communications pursuant to your request.

You may opt-out of receiving communications from us by following the instructions included with such emails or emailing us at [email protected]. This opt-out only applies to messages from Zarco Properties and not third parties, Agents, or Affiliates.

If you want to opt-out of communications from third parties (including, without limitation Agents) or Affiliates, please follow their opt-out instructions as prescribed in their respective notices.

• Information Disclosed Pursuant to Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your PII as set forth in this policy.
• Information Disclosed for Our Protection and the Protection of Others: We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the Terms of Service or this Privacy Policy, including investigation of potential violations thereof or hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
• Information We Share in Connection with the Services Performed for You: The information you provide us, including, without limitation, your profile information, search criteria, username, phone number, email, address, and co-habitant information, may be used by us to facilitate and provide the services for you and transactions within the Services. This may include, without limitation, sharing your PII within Zarco Properties and with Affiliates, potential landlords, owners, co-brokers, our Agents and our third party partners and service providers, as applicable, to your request for Services; and if you are landlord or owner, we may also share your PII (such as name, listing address, etc.) to potential tenants, buyers, co-brokers, our Agents and our third party partners and service providers, as applicable, in connection with the Services.

5. What About Tracking Technologies and Do Not Track Signals?

Tracking Disclosures: We may use tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We collect this information for both IT debugging purposes, and to provide us with valuable information used when considering possible web and mobile enhancements. We will comply with web browser “do not track” signals that you may set in your web browser regarding the collection of PII about your online activities over time and across third-party websites or online services, as recognized by many states Attorney General offices.

6. Any Limits I Should Know About?

Additional Limits on Use of Your Google User Data: If you provide certain information to us, that information may be subject to Google’s Privacy Policy and/or Terms of Service. Notwithstanding anything else in this Privacy Policy, if you provide us access to the following types of your Google data (generically referred to in Google’s Privacy Policy as “data” and referred to herein as “Google Data”), our use of that Google Data will be subject to these additional restrictions:

• Google will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
• Google will not use this Gmail data for serving advertisements.
• Google will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then, only when the data have been aggregated and anonymized.

Your Google Data is subject to the terms in the Google Privacy Policy.

Some content or applications, including advertisements, on the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal information or they may collect information, including PII, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We use conversion tracking from third-party advertising platforms, including Google and Facebook. These advertising programs use cookies to help determine aggregate, anonymous actions people took on our website after clicking an ad. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Zarco Properties use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

7. Is PII About Me Secure?

You need to do what you can to prevent unauthorized access to your account and PII by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account. We endeavor to protect account information to ensure that it is kept private; however, we cannot guarantee the security of any account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We otherwise store all of our information, including your IP address information, using industry-standard security techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you we store, PII or otherwise. We are not responsible for any security incidents that result from your use of third-party services including those offered by Agents associated with Zarco Properties (who are independent contractors of Zarco Properties). In no event shall Zarco Properties incur any legal, financial, or other liability for security incidents caused by your use of third-party services or otherwise attributable to our Agents, Affiliates, or third-party service providers.

8. What Information Can I Access?

We may allow you to access certain information about you for the purpose of viewing, and in certain situations, updating that information. This list will change as the Services change. When you update information, however, we often maintain a copy of the unrevised information in our records. You may request deletion of your account by sending an e-mail to our webmaster at [email protected]. Please note that some information may remain in our records after deletion of your account.

9. What Happens When There Are Changes To This Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected unless we obtain your consent for another purpose. If we make material changes to this Privacy Policy, we will publicly post an updated version of this Privacy Policy for your review on the Site.

10. What If I Have Questions Or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to [email protected].

11. What if I am a minor (under the age of 16)?

We do not knowingly collect, share, or sell personal information of anyone under the age of 16 years old.

12. What if I am a Connecticut, Colorado, or Virginia resident?

If you are a resident of Connecticut, Colorado, or Virginia, you have certain legal rights related to your Personal Information, as described in greater detail below:

• The right to request information about personal information collected about you.
• The right to access personal information in a portable format.
• The right to opt out of the sharing of personal information to a third party.
• The right to request deletion of personal information.
• The right to correct your inaccurate personal information.

You can submit your verified consumer request to know information, opt out of sharing, or for deletion by emailing us at [email protected]. To verify residency, we may request up to three pieces of Personal Information for comparison against our records.

We may deny or fulfill certain requests, either in part, or in full, based on our legal rights and obligations. You have the right to submit an appeal if you are not satisfied with the outcome of your request, by emailing us at [email protected].

Authorized Agents

You may choose a person you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Zarco Properties requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Zarco Properties. Failure to do so may result in Zarco Properties denying your request.

An Authorized Agent may e-mail proof of signed permission along with a copy of their identification and have the consumer directly confirm with us that they provided permission to submit the request on their behalf, by sending an e-mail to [email protected].

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