Last modified 18 Nov 2016
We at Cartus (collectively, “Cartus”, “we”, “us”, or “our”) recognize the importance of protecting the privacy of personal data ("Information" or “Personal Information”) collected by us. This Privacy Statement discloses what Information we gather, how we use it, and how to correct or change it. Information obtained and shared with you through this web site is our confidential information unless expressly indicated otherwise. Information may be requested/collected to enable the delivery of our services, to operate our business and to make the experience of using this site faster and more effective.
By using this web site, you consent to the terms of our Privacy Statement and to Cartus’ processing of Information for the purposes stated above, as well as those explained where Cartus collects Personal Information on the web. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT, YOU CANNOT USE THE SITE. Should our Privacy Statement change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on our web site for a reasonable period of time.
Scope of this Privacy Statement
This Privacy Statement applies to the following sites only: www.cartus.com, online.cartus.com, www.cartusnetworks.com, www.cartusvirtualresources.com, www.cartusmoves.com, and www.myaffinityservices.com, owned and operated by Cartus. This Privacy Statement describes how Cartus collects, uses, shares and secures the Personal Information we receive. It also describes your choices regarding use, access and correction of your Personal Information.
The site contains links to third-party web sites. When you click on those links, you will go to a third-party site where you will be subject to that site’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 web sites and we expressly disclaim any liability for their actions, including actions relating to the use and disclosure of Personal Information by those third parties.
Cartus collects Information in order to operate our business of providing relocation, assignment management, real estate and related services. We may transfer Information to companies, which may include your employer or membership group and our affiliated companies listed below, and others that help us to provide our services.
In some cases, Cartus acts solely as a processor of the Information at the direction of our client. In those instances, an individual who seeks access to, or who seeks to correct, amend, or delete inaccurate Information should direct his query to Cartus, and Cartus will review with the client (the data controller) and respond within a reasonable timeframe.
We will retain Information for as long as needed to provide our services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
1. What is Personal Information?
Personal Information is information collected by Cartus that identifies the person to whom such information pertains, including without limitation: name, address, telephone number, and e-mail address. We may also collect sensitive Personal Information, such as bank account number, government issued identifiers such as Social Security number, driver’s license number, and an individual’s geolocation or historical precise geolocation information.
2. Collection and Use of Your Information
2(a). Personal Information
While most of the Information collected by Cartus is supplied by our clients, our suppliers, and our customers as part of the relocation process, we may, at times, ask you to (or you may voluntarily in CartusOnLine) update or confirm a subset of that Information on this web site. To do this, you may be asked to register to use this site. Additionally, your Information may be shared with our affiliates listed below, and third party suppliers (e.g. home inspectors, moving companies) where necessary to support the services we deliver. This Information will be used solely for the purposes of providing services in accordance with our contracts with our clients, which may include making Information available to your employer or membership group. In addition, we may collect Personal Information from our suppliers and from client and potential client contacts. That Information may be used by Cartus to market and/or provide our services to those clients and potential clients.
We will share your Personal Information with our affiliated listed below and with third parties only in the ways that are described in this Privacy Statement. We remain responsible for the handling of your Personal Information by those affiliates and third parties as provided in the EU - U.S. Privacy Shield Framework Principles, including the Supplemental Principles.
Our affiliates who may receive Personal Information for the purposes described above are CARTUS RELOCATION CANADA LIMITED, CARTUS SARL, CARTUS BRASIL SERVIÇOS DE RELOCAÇĂO LTDA, CARTUS SAS, CARTUS LIMITED, CARTUS B.V., CARTUS CORPORATION PTE. LTD., CARTUS RELOCATION HONG KONG LIMITED, CARTUS INDIA PRIVATE LIMITED and CARTUS REAL ESTATE CONSULTANCY (SHANGHAI) CO., LTD.
Each of those affiliates is committed to complying with the EU - U.S. Privacy Shield Framework Principles, including the Supplemental Principles.
We will retain your Information for as long as your account is active and thereafter in accordance with our data retention policies. If you wish to cancel your account or request that we no longer use your Information to provide you services, contact us as specified in Contacting Us/Correction/Updating Personal Information. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Registration for Personalized Services
If you wish to use Cartus’ personalized services, you may be asked to create an account or enroll as a delegate authorized by an existing account holder. The process of creating this account or enrolling as a delegate necessitates that you provide Personal Information about yourself. If you choose to provide us with your Personal Information on the web, we may transfer that Personal Information within Cartus and its affiliates to Cartus’ third-party service providers, including locations across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
Cartus strives to comply with all applicable laws worldwide that are designed to protect your privacy. Although legal requirements may vary from country to country, Cartus intends to adhere to the principles set forth in this Privacy Statement even if, in connection with the above, we transfer your Personal Information from your country to countries that may not require an "adequate" level of protection for your Personal Information. In other words, our goal is to provide protection for your Personal Information no matter where that Personal Information is collected, transferred, or retained.
Requests for Periodic Industry Updates
If you request Periodic Industry Updates, we collect Personal Information, which is submitted directly to our web hosting services vendor’s system to create automatic e-mails to people who choose to subscribe. The information we collect is not used in any other way and is not retained once you end your subscription to Periodic Industry Updates. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at InformationProtection@cartus.com.
Requests to Find or List a Property and to Find a Sales Associate
If you submit a request through this site to find or list a property or to find a real estate agent, you will be asked to provide Personal Information and we refer this information to real estate agents to respond to your request. For example, if you ask that we list your property or if you ask to see more listings in a given area, you will be directed to a real estate agent in that area.
In addition, telephone calls to or from Cartus may be recorded. Phone call participants are advised at the commencement of services that their participation in telephone calls to or from Cartus, whether or not an announcement is made at the time of the call, grants all rights of permission of the participant(s) to Cartus to record calls and utilize such recordings for its business purposes. The participant is advised to notify and obtain recording consent from any family members or others who may communicate with Cartus as part of receiving our services or other parties that participant conferences in or requests Cartus to conference in to any telephone calls with Cartus.
2(b). Non-Personal Information
Even if you do not send us any Personal Information, we collect information about how you use our site (“Non-Personal Information”). This information cannot be used to identify you personally and is explained in more detail below.
What is Non-Personal Information?
Like many sites, we obtain Non-Personal Information automatically and store it in log files, such as: IP (internet protocol) addresses, browser types, the name of a user’s ISP (internet service provider), information about where a user comes from before arriving at our site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor performs this service for us by sending a cookie to gather this information, compiling it, and reporting to us. We may combine this automatically collected log information with other information that you voluntarily provide. We do this to improve the services we offer you, to improve marketing, analytics or site functionality.
Use of Non-Personal Information
We use Non-Personal Information to improve our services, conduct research, and provide anonymous aggregated reporting for internal audits and third-parties.
Technologies such as cookies or similar technologies are used by Cartus and our marketing partners and analytics providers. These technologies are used in analyzing trends, administering the site, tracking users’ use of the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Behavioral Targeting / Re-Targeting
Local Storage (HTML5)
Third parties with whom we partner to provide analytics or tracking may use Local Storage such as HTML 5 to collect and store information.
Various browsers may offer their own management tools for removing HTML 5.
2(c). Use of Information With Respect to Third Parties
We reserve the right to share your Personal Information with our clients, affiliates listed above and third party service providers, as permitted by law, in order to help us deliver our services.
Cartus may also disclose your Personal Information if Cartus is involved in a merger, acquisition, or sale of all or a portion of its assets. In such case, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Service providers are also an important means by which Cartus maintains its web site and mailing lists. Cartus will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on Cartus’ behalf.
Cartus does not intend, without your consent, to transfer Personal Information to third parties who are not bound to act on Cartus’ behalf unless such transfer is legally required. Similarly, it is against Cartus’ policy to sell, without consent, Personal Information collected online.
Social Media Widgets
Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy statement of the company providing it.
3. Location of Servers and Transfer of Information to the United States
The site is hosted by servers in the United States, and, as such, the site is governed by United States law. If you are located outside of the United States, your Personal Information will be transferred to the United States. By submitting your personal Information, you consent to its transfer to the United States and to its storage, processing, and use there in accordance with this Privacy Statement and United States law.
4. Compliance with Privacy Shield and Independent Recourse Mechanism; Federal Trade Commission Jurisdiction
Cartus participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Cartus is committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. Each of our affiliates listed above is committed to complying with the EU - U.S. Privacy Shield Framework Principles, including the Supplemental Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.
Cartus is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Cartus complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Cartus is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Cartus may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Where applicable for employee matters, Cartus commits to cooperation with the panel of the EU Data Protection Authorities (DPAs), the state or national data protection authority where the employee works or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, to investigate unresolved complaints.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted. Once arbitration is invoked, in some cases the individual may lose the option to seek relief for the same claimed violation in another forum. For more information about binding arbitration please visit: http://www.commerce.gov/privacyshield/
5. U.S. - Swiss Safe Harbor
Cartus also complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Cartus has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Swiss Safe Harbor program, and to view Cartus Corporation’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
The security of your Personal Information is important to us. Cartus maintains its systems in accordance with reasonable industry standards to reasonably secure Information against unauthorized access, accidental or intentional manipulation, and loss, both during transmission and once it is received. However, no data transmission over the Internet can be guaranteed to be 100% secure, and you use the site at your own risk. If you have any questions about the security of your Personal Information, you can contact us using the addresses noted in the “Contact Us” section below.
www.cartus.com/en/blog offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at InformationProtection@cartus.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
This site is not directed to children under the age of 13 (“Children”), and we do not knowingly collect any information, including Personal Information, from Children.
8. Changes in this Privacy Statement
If we decide to change our Privacy Statement, we will post those changes to this Privacy Statement here, and any other places we deem appropriate so that you can be aware of what Information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Statement at any time, so please review it frequently. If we make material changes to this Statement, we will notify you here or by other means we deem appropriate, prior to the change becoming effective.
9. Contacting Us/Correction/Updating Personal Information
Upon request, Cartus will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by contacting us at the contact information below.
You may contact us through the methods stated below for a number of purposes, including: (1) if you no longer wish to use the site; (2) to opt-out of communications or unsubscribe from any industry updates as described in “Requests for Periodic Industry Updates”; (3) to receive information or special offers; (4) to provide feedback and comments on this Statement; (5) to request access to your Personal Information, deletion of your incorrect Personal Information or correction of your Personal Information; and (6) to make inquiries as to whether we hold or process on behalf of a third party, any of your Personal Information or complaints regarding our Privacy Statement and/or privacy practices.
|By email to:||InformationProtection@cartus.com|
|By mail:||Privacy Officer, Cartus, 40 Apple Ridge Road, Danbury, CT 06810.|
|By phone:||(203) 205-1540|
We will respond to your request within a reasonable timeframe, but in no event later than 45 days.