MDRA Civil Consulting Privacy Policy
General
This Privacy Policy describes the privacy practices of MDRACivilConsulting.com (“MDRA Civil Consulting,” "partners," “we,” “our,” or “us”) with respect to the website(s) and web applications (the “Sites and Apps”) consisting of the following: MDRACivilConsulting.com and any other Internet Sites and Apps operated by us. We are committed to protecting the privacy or our customers and their clients. Please read the following information to understand what information we collect and how we use that information.
This Privacy Policy describes our collection, use, disclosure, and protection of personal information collected or provided through the Sites and Apps and how we use personal information in connection with our services offered through the Sites and Apps (“Services”). “Personal information” is information that identifies an individual and is associated with a specific person. Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.
We are committed to the protection of the privacy of personal information provided to us by our customers and their clients.
Customer Information
Our customers are almost always real estate agents who desire to use our services and subscribe to one or more of our Sites and Apps. The Sites and Apps are also often involved in the collection of personal information from clients of our customers with their consent. See “Client Information” below. Our use of the term “customer information” does not include personal information collected by customers from their respective clients.
We limit the collection of personal and public information to what is required to accomplish our services. We may collect the following types of personal information about our customers through the Sites and Apps, including but not limited to:
- When a customer registers to use our Services, basic registration information and identifiers are required, such as name, address, telephone number, email address, user name, password, MLS affiliation(s) and other personal information.
- To subscribe for our Services, customers are required to a credit card number, expiration date, and credit card security code.
- We may collect information about customers’ interaction with our Sites and Apps such as computer browser type, pages visited, Internet and network activity, average time spent on our Sites and Apps, IP address, unique identifier of the device, operating system version, and app version.
- We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas to provide customers with other benefits or to improve upon the Services. In such instances, customers are given the opportunity to provide or decline that information.
We obtain the categories of information identified above directly from our customers. We will not collect additional categories of personal information from customers or use the personal information we collect about customers for materially different, unrelated, or incompatible purposes without providing notice to our customers.
Use of Customer Information
We use customer personal information to:
- respond to customer inquiries about our Services;
- fulfill customer requests for our Services;
- provide customers with the information regarding products and services that are offered by us, requested from us, or that relate to our Sites and Apps;
- carry out our obligations arising from any contracts entered into between our customers and us;
- analyze Sites and Apps usage and improve the Services provided through the Sites and Apps;
- alert customers to software compatibility issues and to improve our Sites and Apps design and functionality;
- deliver to customers any notices or alerts and communications relevant to customers regarding their use of the Services;
- perform market research, project planning, product development, troubleshooting problems, analysis of user behavior, marketing, and promotions;
- detect and protect against errors, fraud, or other criminal activity; and
- enforce our Terms of Service and as otherwise set forth in this Privacy Policy.
In order to allow customers to use certain Services, we may be required to verify their identity. We may use customer information to verify a customer’s identity in the event a customer contacts us for assistance with the Sites, Apps, or Services.
We may use customer information to pre-fill form fields on the Sites and Apps for the convenience of our customers.
Disclosure of Customer Information
We will not, without a customer’s permission, sell, publish, or share personal information of such customer to third parties, except that by necessity we use third party service providers for data analysis and cloud computing Services in order to perform the services provided by our Sites and Apps. These service providers are not allowed to use such personal information for their marketing purposes. We will not, without the permission of a customer, sell, publish, or share a customer’s personal information to third parties for their marketing purposes. We do not share credit card information.
Our customers may opt-out of allowing us to use their personal information for our own marketing purposes, including opting-out of our providing a customer with information regarding our products and services that are not requested by the customer.
We reserve the right, however, in our sole discretion, to share or disclose customer personal information with law enforcement, government officials, and other third parties:
- to respond to subpoenas, court orders, or legal process;
- in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites and Apps or Services;
- to respond to claims that any posting or other content violates the rights of third parties;
- in an emergency, to protect the health and safety of our Sites and Apps' users or the general public; or
- as otherwise required by any applicable law.
We may share customer personal information with other third parties with consent or instructions to do so.
Information of Clients of Customers
Our customers are almost always homeowners or businesses who desire to use our services and subscribe to one or more of our Sites and Apps. The Sites and Apps often involve the collection of personal information from clients of our customers. The clients and potential clients of our customers are not our customers. We refer to information received by our customers from their clients as “client information.”
Client Information
We limit the collection of personal and public information of clients of our customers to what is required to accomplish our services. As a service provider and data processor serving at the instruction of our customers, we process the following types of personal information about the clients of our customers through the Sites and Apps, including but not limited to:
- Basic identifying information, such as name, address, telephone number, email address, and other personal information.
- Information relating to relating to real estate owned by a client, including valuation and comparative market analysis.
- We may collect information about clients’ interaction with our Sites and Apps such as computer browser type, pages visited, Internet and network activity, average time spent on our Sites and Apps, IP address, unique identifier of the device, operating system version, and app version.
- We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas from clients to provide customers with other benefits or to improve upon the Services. In such instances, clients are given the opportunity to provide or decline that information.
We obtain the categories of information identified above directly from our customers, from clients of our customers. We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing notice to the affected client.
Use of Client Personal Information
We use client personal information to:
- fulfill requests for our Services;
- carry out our obligations arising from any contracts entered into between customers and us;
- analyze Sites and Apps usage and improve the Services provided through the Sites and Apps; and
- detect and protect against errors, fraud, or other criminal activity.
Disclosure of Client Information
We will not, without permission, sell, publish, or share personal information of clients of customers to third parties, except that by necessity we use third party service providers for data analysis and cloud computing services in order to perform the services provided by our Apps. These service providers are not allowed to use such personal information for their marketing purposes.
We reserve the right, in our sole discretion, to share or disclose client personal information with law enforcement, government officials, and other third parties:
- to respond to subpoenas, court orders, or legal process;
- in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites and Apps or Services;
- to respond to claims that any posting or other content violates the rights of third parties;
- in an emergency, to protect the health and safety of our Sites and Apps' users or the general public; or
- as otherwise required by any applicable law.
Mergers and Acquisitions
If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information that includes, without limitation, personal information of clients and customers and other information concerning the relationship between our real estate agent clients and us. Such third parties will assume responsibility for the information collected by us in connection with our business operations or through our Sites and Apps and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.
Changes to Personal Information
Customers may access and update much of the information they have submitted to us at any time via the Sites and Apps.
Customers may choose to delete their account for the services provided by our Apps at any time. We will delete customer and client information upon verified request pursuant to applicable law. Once we receive and confirm a verifiable request, we will delete (and direct our service providers to delete) personal information from our system, unless an exception applies under applicable law. For instance, we may deny a deletion request if retaining the information is necessary for us or our service provider(s) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or to comply with a legal obligation.
We retain customer and client personal information as long as necessary to provide the Services each real estate agent customer has requested. Additionally, we may retain personal information to comply with law, prevent fraud, resolve disputes, trouble shoot problems, enforce our Terms of Service, and as permitted by applicable law.
Links to and from Other Web Sites
Our Sites and Apps may offer links to other third party websites for convenience and information only. These websites have their own privacy and information collection practices and security measures. Third party sites are not subject to this Privacy Policy.
Use of Non-Personal Information
When using our services and offerings we may also collect non-personal information − data in a form that does not permit direct association with any specific individual. Aggregated data is considered non-personal information for the purposes of this Privacy Policy. If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.
We also collect and use publicly available information from government records regarding real estate.
We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
- We may collect information such as language, zip code, area code, unique device identifier, location, time, and the time zone where our Sites and Apps is accessed or used so that we can better understand customer behavior and improve our offerings, programs, products, services, and advertising.
- We also may collect information regarding customer activities from our other programs and offerings. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our programs, offerings, and services are of most interest.
As our Sites and Apps are navigated, certain information may also be passively collected by us or a third party service provider. This information includes Internet protocol addresses, browser types, domain names, access times, operating systems, mouse clicks, mouse movements, and scrolling activity. We also use cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of uses or visits. This type of information is collected to analyze the use of our offerings, programs, and services to make them more useful to customers and to provide customers with relevant offerings.
Protection of Information
We take the security of personal information seriously. We use technical and administrative security measures such as but not limited to firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of personal information. However, no complete assurance can be made against all cyber attacks and other security breaches. To safeguard against unauthorized access, customers are required to login to certain secure areas of our web Sites and Apps using a user name and a password. Both user name and password are encrypted when sent over the Internet.
Cookies and Tracking
We may aggregate information through cookies, or alphanumeric identifiers that we transfer to a computer's hard drive through the web browser. This allows us to collect and track information about users and users’ activities online at our websites over time and across third-party websites or online services including, but not limited to, a computer's network address and operating system, the Sites and Apps from which a user linked to our Sites and Apps, the time and date of the visit, how our offerings, programs, services are used and what offerings and services are used. We may also link this information with other personal information about users and may use this linked information. This helps us to recognize users, customize, or personalize user’s utilization of our Services and to store such information in between visits to our Sites and Apps. It also allows us to aggregate demographic and statistical data and compilations of information that may or may not include personal information and provide this information to our business partners, third party vendors, and service providers. By doing so, we hope to understand our customer’s needs and desires so that we can make new offerings to them or tailor existing offerings to fit their desires.
Minors
Our Sites, Apps, and Services are not intended for minors or not of a legal age to form a binding contract with us. We do not knowingly collect personal information from these individuals. If a minor (as defined by law) provides us with his/her personal information without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future communications with us.
California Users
To the extent the personal information contains personal data relating to an individual who resides in the California, we comply with the California Consumer Privacy Act of 2018 (CCPA) and we expect our customers to do so. A California resident may request a correction or deletion of the personal information we have in our possession, and we will do so upon receipt of a verified request. We will, in accordance with CPA and upon verified request, permit a California resident access to the personal information we hold about him or her that has been collected over the past 12 months. If you are a California resident, once we receive and confirm your verifiable consumer request we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you; and
- The personal information categories that our service providers obtained.
Canadian Users
To the extent the personal information contains personal data relating to an individual who resides in the Canada, each of our customers is responsible for compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA). We require our customers to acknowledge that they may use personal information of Canadian residents only for the purposes for which it was collected, unless the individual client consents. Whenever we are notified that a client has withdrawn their consent and opted out, we will delete their personal information from our system. We do not collect, use, or disclose personal information without a client’s consent, except where required or allowed by law. We will, in accordance with PIPEDA and upon proof of entitlement and the presentation of proper identification, permit an individual access to the personal information that we have in our possession.
EU and Swiss Users
The General Data Protection Regulation (GDPR), effective May 25, 2018, creates consistent data protection rules across Europe. It applies to all companies that process personal data about individuals in the Europe and Switzerland, regardless of where the company is based.
Each of our customers is responsible for complying with all applicable privacy laws with respect to client personal information, including the GDPR.
As part of our Services, we operate as a data processor through our Sites and Apps on behalf of our customers. Where we act as a data processor on a customer’s behalf, we will rely on our customer's legal basis as data controller for our processing of this data. Where we act as a data processor on the behalf of any European customers, we will ensure that we comply with the specific requirements for data processors. We have updated our related terms of service to align with the GDPR. Where we appoint parties to act as data processor on our behalf, we will ensure that we have appropriate terms in place to comply with our requirements under the GDPR and to safeguard personal data.
Questions or Concerns
If you have questions or concerns regarding our Privacy Policy, please contact us at:
MDRA Civil Consulting
Justin, TX 76247
dave@mdracivil.com
Modifications to this Privacy Policy
We may modify our Privacy Policy from time to time, so please review it periodically. If our practice in using and/or sharing personal information changes in the future, those changes will be reflected in this Privacy Policy. This was last updated on April 3, 2024. V1.1