​Net Trade Ventures, Inc. (“we,” “us,” or “our”) is pleased to provide you with access to our Services. This Privacy Policy describes our practices with respect to the collection, transfer, manipulation, disclosure and other uses of Your Information and certain other information collected by us through our Services. For purposes of this Privacy Policy, “Your Information” means information about you which may be of a confidential nature and may include personally identifiable information, including your first and last name and email address. Capitalized terms used but not defined in this Privacy Policy have the meanings ascribed to them by our Terms of Service.

This Privacy Policy applies to information collected by us through our Services, but does not apply to information collected by any person or entity other than us, even if related to our Services, and/or by our Third-Party Service Providers.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES. BY USING OUR SERVICES OR BY CLICKING TO ACCEPT OR AGREE TO OUR TERMS OF SERVICE WHEN THIS OPTION IS MADE AVAILABLE TO YOU, YOU ACCEPT AND AGREE TO BE BOUND AND ABIDE BY OUR TERMS OF SERVICE, INCLUDING THIS PRIVACY POLICY. IF YOU DO NOT WANT YOUR INFORMATION USED OR DISCLOSED IN THE MANNER DESCRIBED IN THIS PRIVACY POLICY, OR IF YOU DO NOT AGREE WITH ANY TERM OR CONDITION IN OUR TERMS OF SERVICE, INCLUDING THIS PRIVACY POLICY, THEN YOU MUST NOT ACCESS OR USE OUR SERVICES (IN WHOLE OR IN PART) OR SUBMIT YOUR INFORMATION TO US.

This Privacy Policy may change from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. Amendments will take effect immediately on our posting of the updated Privacy Policy. Your continued access or use of our Services after receiving the notice of changes means you accept the updated Privacy Policy, so please check this policy periodically for updates.

1. Children Under the Age of 18

Our Services are intended to be accessed and used only by adults and are not directed to minors. If you are below the age of 18, you may access and participate in our Services only under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy and our Terms of Service.

We do not knowingly collect personally identifiable information by anyone under the age of 16 and you should not provide us with any information regarding any individual under the age of 16.  If we learn that we have inadvertently gathered information from anyone under the age of 16, we will take reasonable measures to promptly remove that information from our records.

2. What Information We Collect and How We Collect It

We receive and collect several types of information about you, such as the information described below.

Information you provide to us: From time to time, you may provide us with certain information, including Your Information, such as your name and email address. Instances where you may provide this information include when you sign up for an account on our Services, fill out forms or fields on or through our Services, or sign up for any promotions or to receive newsletters or other materials from or about us.

Information we receive from third parties:  We may obtain information about you from sources other than you, such as from our payment processing services provider when you make payments for a subscription to our Services, or for other transactions facilitated on or through our Services. Any content or information submitted by you to third parties will be used and disclosed by such third parties in accordance with their respective privacy policies. You should review the privacy policies and practices of such third parties prior to disclosing information to them.

We may also collect information on third party platforms such as HubSpot, Google AdWords, Google Analytics, financial information platforms, or platforms with stock information, etc.  Additionally, some information we collect is publicly available. For example, we may collect information you submit to a public website or platform, blog, a chat room, or a social network like Facebook, Twitter or Google+.

We may collect information from public sources, such as county and state tax and property records, government agencies, multiple listing services (or MLS), and sales comparables and tenant database information suppliers. Most of this information is about properties and not people. However, some information we collect, such as the identity of a property’s owner or real estate license information, may relate to individuals.

We may collect broker offering memorandum information and data with information including, listing broker details, property characteristics, location descriptions, proprietary asset features, lease details and tenant details such as corporate guarantors or franchisees, credit scores, number of units, stock symbols, third-party company descriptions, links to third-party company details, ESRI sourced demographics, traffic counts, and other similar or additional information or details.

Information we collect automatically: As you navigate through and interact with our Services, we and third parties acting on our behalf may use automatic data collection technologies to collect certain information. See Section 3 “Cookies and Other Automatic Tracking Technologies” for more information.

Our Collection Practices with Respect to Certain Specific Information:

Device Information. When you access or use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events, such as crashes, and associate that temporarily with your account (if any) to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

Location Information. If you submit your zip code or other geographic information to us, you may provide us with your location information. Furthermore, if you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device’s GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers) or obtain your location information from third parties. 

Communications with Us. We may collect information about your communications with us, including relating to support questions, your account, and other inquiries.

Third-party content providers may collect information: Some Content or applications, including advertisements, on our Services may be served by third parties, including our Third-Party Service Providers, ad networks and servers, content providers and other application providers. These third parties may collect information about you when you use our Services using Cookies alone or in conjunction with web beacons or other tracking technologies. 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. Please note that the information collected by these third parties may be associated with Your Information and that these third parties may collect information, including Your Information, about your online activities over time and across different websites and other online services.

3. Cookies and Other Automatic Tracking Technologies

Description of the Technologies Utilized on our Services: We may use various technologies to collect and store information when you use our Services, including sending Cookies, embedded scripts, web beacons, pixel tags or other anonymous identifiers to your device, or otherwise tracking your activities on our Services over time. We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (a practice known as behavioral tracking).

• “Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session Cookies will only stay on your device until you stop browsing. Persistent Cookies stay on your browsing device until they expire or are deleted. A “web beacon” is a type of technology that lets us know if you visited a certain page or whether you opened an email. A “pixel tag” is a type of technology placed within a website or e-mail for the purpose of tracking activity, which is often used in combination with Cookies. Other “anonymous identifiers” include random strings of characters used for the same purposes as Cookies, such as with mobile devices where cookie technology may not be available. These technologies help us know that you are logged on to or using our Services, provide you with features based on your preferences, help us understand when and how you are interacting with our Services and compile other information regarding your use of our Services. 
• With respect to Cookies, we use first-party and third-party Cookies to: make our Services function properly; improve our Services; make access to our Services easier; recognize you when you return to our Services; track your interaction with our Services; enhance your experience with our Services; remember information you have already provided; collect information about your activities over time and across third-party websites or other online services in order to deliver Content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Services. The categories of Cookies used or that may be used on our Services include:
  • Strictly Necessary Cookies, which are needed for our Services to operate as you reasonably expect.
  • Functional or Preference Cookies, which are used to remember your name or choices.
  • Performance or Analytic Cookies, which collect passive information about your use of our Services.
  • Advertising or Targeting Cookies, which are used to make advertising messages more relevant and personalized to you based on your inferred interests. 
• We may use Third-Party Service Providers to monitor and analyze the use of our Services. For example, we may use Google Analytics as one of our analytics service providers that tracks and reports platform (including website) traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page. To learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link. 
  The information collected through these technologies, standing alone, cannot be used to determine your identity. Such information may, however, be combined in a way that makes it become personally identifiable information (i.e., information that can identify you). For example, we may tie this information to personal information about you that we collect from other sources or that you provide to us. If this happens, we will treat the combined information as personally identifiable information.

Choices as to Cookies and Other Automatic Tracking Technologies: It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of all or a portion of our Services. The method for disabling Cookies or other automatic collection technologies may vary by device and browser but can usually be found in preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. See Section 6 “Choices About How We Use and Disclose Your Information” for more information.

Do Not Track Requests:  Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Services do not currently process or respond to “DNT” signals.

4. How We Use Your Information

We may use the information we collect for various lawful business purposes. Among others, these purposes may include using this information, including Your Information, to:

• Present our Services and related Content to you. For example, to provide our Services, including its features, services, marketing, and promotional information to you and/or other account owners or Registered Users, and to customize Services features and recommendations for users. We may also use Your Information to manage our relationship and contracts with account owners, including billing, compliance with contractual obligations, and related administration.
• Contact you and provide you with information. For example, if you subscribe to an account on or through our Services, we may contact you to notify you of and/or deliver applicable information or Content to which you are subscribed. Additionally, if you complete the “contact us” form on our website, we might contact you via e-mail or other communications to provide you with information regarding our Services, promotions, offers, personalized information and other information from us or our Third-Party Service Providers or business partners or to respond to comments, inquiries, and other information submitted by you.
• Provide you with customer support. For example, if you request us to contact you in connection with any customer support matters, we may collect certain information from you in order to assist you as requested.
• Analyze, improve, and manage our Services, products, service offerings, marketing, and operations. For example, we might obtain feedback regarding our Services, products, and service offerings to: (i) understand and anticipate your needs and preferences; (ii) better understand your use of our Services, products, or service offerings; (iii) customize and tailor Content, and for advertising; (iv) improve our marketing and promotional efforts; (v) engage in statistical analysis; and (vi) provide feedback or information to our business partners, contractors, vendors, advertisers and other third parties.
• Resolve problems and disputes, and engage in other legal and security matters. For example, we may use the information we collect to comply with, monitor compliance with and enforce this Privacy Policy, our Terms of Service (including any terms and conditions incorporated or referenced in our Terms of Service) and any other applicable agreements and policies, meet other legal and regulatory requirements, and protect the security and integrity of our Services. We might also use Your Information to authenticate accounts and activity, detect, investigate, and to prevent malicious conduct or unsafe experiences or address security threats, or protect public safety. We might also use information that we collect to investigate any complaint you make regarding our Services, Content, products, service offerings or other related matters, to provide evidence in any dispute or anticipated dispute between you and us, or to prevent fraud or other criminal or otherwise inappropriate activities.
  Display advertisements to our advertisers' target audiences. For example, we may use your device information for direct advertising and retargeting ads, such as providing you with information or advertising relating to our products and services based on your precise geolocation, when in line with the preferences you have shared with us. Additionally, even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Note also that our third-party content providers may use information they collect via our Services to provide you with interest-based (aka behavioral) advertising or other targeted content.
• Comply with a request from you in connection with the exercise of your rights. For example, where you have asked us not to contact you for marketing purposes, we or our service providers will keep a record of this on our suppression lists to be able to comply with your request.
• Other Purposes. We may also use Your Information in other ways. To the extent required by applicable law, we will provide notice at the time of collection and obtain your consent. 

5. How We Disclose Your Information

General Disclosure of Your Information:  We may disclose the information we collect, including Your Information:

• to the public and other users of our Services.  Your Information and Content you upload or post to public areas of our Services may be viewable by others on our Services, and the public. Please do not provide personal information you would not want to be public. You may be able to control the visibility of some of Your Information on your account profile page (see “Choices About How We Use and Disclose Your Information” below). We share Your Information with third parties to whom you express your interest in, or for other transactions facilitated on, or through, our Services, for example, if you request information on a particular property or submit an offer on a particular property, then the seller, broker and/or its representative will be given access to Your Information. When you log-in and visit any property on, or through, our Services, we also share Your Information, such as Content you provide consisting of information about individual properties, including, but not limited to, information regarding title and legal status, current and potential valuations, physical conditions, and other pertinent information;
• to our third-party vendors or suppliers (including our payment processing Third-Party Service Provider and our hosting Third-Party Service Provider) so that they may provide support for our internal and business operations, including for the processing of your payments for a subscription to our Services, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials and our Services’ maintenance and security. For example, we use (and thus disclose certain of Your Information to):
• Google Analytics so that they can help us understand how our customers use our website and platform – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  HubStop in order to effectuate our marketing campaigns — you can read more about how HubSpot uses Your Information here: https://legal.hubspot.com/privacy-policy .
  Other Third-Party Service Providers that assist with evaluating our marketing campaigns.
• to our affiliates and their respective employees, agents and representatives involved in delivering our Services, products and other services to you;
• to fulfill the purpose for which you provide it;
• to any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
• to third parties when you engage in certain activities through our Services, such as those financial or other institutions with which you maintain accounts to which you have authorized us to access for purposes of providing our Services to you;
• as required by applicable law or ordered by a court, regulatory or administrative agency;
• as we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, restriction or regulation, or are otherwise interfering with another’s rights or property, including our rights or property;
• if requested by authorities in the event of any act instance of local, regional or national emergency;
• to enforce our Terms of Service, including this Privacy Policy, and any other applicable agreements and policies; with your consent;
• to otherwise enforce or protect our rights; and in connection with a Business Transfer (see “Other Disclosures by Us” below). 

Please note that the list above is not exhaustive and that we may, to the extent permitted by applicable law, disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you. 

 

When we disclose the information we collect to third parties, such information will become permanently subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of such information. Furthermore, these third parties may further disclose, share and use this information. By submitting information (including Your Information) to us, you expressly consent to such disclosure and use of such information. If you do not want this information (including Your Information) shared as described above, then you should not provide us with such information.

Other Disclosures by Us:

Aggregation and De-Personalization. We may use and disclose any de-identified information for any lawful purpose, including for any commercial purpose. De-identified Information means information that does not identify you, including any identifiable information de-identified by either by combining it with information about others, for example, by aggregating your information with information about other persons, or by removing characteristics, such as your name, that make the information personally identifiable to you.

Business Transfers. We may disclose, lease, sell, assign or transfer the information we collect (including Your Information) to third parties in connection with a Business Transfer. A “Business Transfer” means a sale, acquisition, merger, consolidation, reorganization, bankruptcy or other corporate change involving us, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part of or our whole business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity or assets (including our Services) to an affiliate or independent third party at any time, for any lawful purpose, without notice or compensation to you.

Circumvention of Security Measures: We use certain technical, administrative and organizational security measures to keep Your Information safe. However, despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of Your Information, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, to the extent permitted by law, we are not responsible for circumvention of any privacy settings or security measures of our Services. Therefore, you use our Services at your own risk, you should not expect that Your Information will always remain private, and we do not guarantee the performance or adequacy of our security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate Your Information.

6. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding our collection, use and disclosure of the information that we collect. Below are some mechanisms that provide you with control over such collection, use or disclosure:

• Cookies and Other Tracking Technologies. It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of our Services. The method for disabling Cookies or other automatic collection technologies may vary by device and browser, but can usually be found in preferences or security settings.

  You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.

  • First-Party Cookies. You can use the browser with which you are viewing our Services to enable, disable or delete Cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable Cookies, you may not be able to access secure areas of our Services. Also, if you disable certain Cookies, other parts of our Services may not work properly. You can find more information about how to change your browser cookie settings at allaboutcookies.org.
  • Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising Cookies go to aboutads.info/choices.

  We do not control third-parties’ collection or use of Your Information to serve interest-based advertising. However, these third-parties may provide you with ways to choose not to have Your Information collected or used in this way. In addition, most web browsers provide help pages relating to setting Cookie preferences. More information may be found for the following browsers here:

  - Google Chrome
  
  - Safari (Desktop)
  
  - Internet Explorer
  
  - Android Browser
  
  - Mozilla Firefox
  
  - Opera
   
• E-mail Offers. If you do not wish to receive e-mail offers or other information or communications from us, you can opt-out of receiving such e-mail offers or other information or communications from us (other than e-mails or other information or communications related to the status of your job application with us (if any), correction of user data, change of password and other similar communications essential to your transactions on or through our Services) by using the unsubscribe process at the bottom of the e-mail. Please be aware that it can take up to 10 business days to remove you from our marketing e-mail lists. If you opt-out from receiving our marketing e-mails, you may continue to receive certain status e-mails relating to your transactions on or through our Services.  
• Managing, Modifying, or deleting Your Information.  If you have any questions about reviewing, modifying, updating, or deleting Your Information, or if you want to remove Your Information from our Services or publicly displayed Content, you can visit your account profile page, or contact us directly at [email protected].  We may not be able to modify or delete Your Information in all circumstances. 
• Online Behavioral Advertising. As described above, we may use Your Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. Certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by visiting http://www.networkadvertising.org/choices/ and following the NAI’s directions. Note that if you opt-out through the NAI, you will still receive advertising. In addition, if you opt-out through the NAI and later delete your Cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. Additional options for opting out of target advertising include, without limitation:
  • FACEBOOK - https://www.facebook.com/settings/?tab=ads   
  • TWITTER - https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
  • GOOGLE - https://www.google.com/settings/ads/anonymous
  • BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
  • Digital Advertising Alliance - http://optout.aboutads.info/ 

7. Information that You Disclose to Third Parties

Our Services, including any of our newsletters or e-mail messages, may contain links or access to websites or platforms operated by third parties that are beyond our control. Links or access to third parties from our Services is not an endorsement by us of such third parties, or their respective websites, applications, products, platforms or practices. We are not responsible for the privacy policies, terms and conditions, practices or the content of such third parties. All information that you disclose to such third parties will be subject to the privacy policies and practices of such third parties. You should review the privacy policies and practices of such third parties prior to disclosing information to them. If you have any questions about how these third parties use Your Information, you should review their policies and contact them directly.

8. Operation of our Services in the United States

Our Services are operated in the United States. As a result, the information we collect (including Your Information) will be used and disclosed as described in this Privacy Policy in the United States, as well as in other countries if you access our Services outside of the United States. In some cases, the laws of countries other than the United States regarding our use and disclosure of Your Information may be less stringent than the laws of the United States.

9.Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. We will comply with all such laws that apply to us and with respect to our collection, use and/or disclosure of Your Information. For example, see Section 12, “Privacy Notice for Nevada Residents”.

10. Changes to Our Privacy Policy

We may amend this Privacy Policy at any time and from time to time. Amendments will take effect immediately upon us posting the updated Privacy Policy on our Services. Accordingly, you are encouraged to revisit this Privacy Policy from time to time in order to review any changes that we have made. The date on which this Privacy Policy was last updated will be noted immediately above this Privacy Policy.

11. Contacting Us

If you have any questions, suggestions or complaints regarding our use or disclosure of the information we collect from you or wish to contact us to make a request regarding such information (including Your Information), please contact us at [email protected].

In contacting us, you must include the reference to “Privacy Request” in the subject line and in the body of the message and include the email address or mailing address, as applicable, for us to send our response. We reserve the right not to respond to inquiries submitted other than to the address specified above.

12. Privacy Notice for Nevada Residents

This Section 12 supplements the information contained in this Privacy Policy, but applies solely to all consumers who reside in the State of Nevada. Nevada law permits our users who are Nevada consumers to request that their personal data (as defined under applicable Nevada law) not be sold, even if their personal data is not currently being sold. Requests may be sent to [email protected], and are free of charge.