Last modified: February 21, 2022
If you have any questions about our policies and practices, we encourage you to contact us via the contact information provided at the end of this Policy.
Personal Information We Collect.
We collect information that is necessary to provide and improve our Services, to communicate with you, to conduct our operations effectively, and to support customer relations. Information collected may include:
- Your contact information. This may include information you provide to us when you register for Services, such as: your name, username, and contact details—including your email address, mailing address, telephone number and information about the institution you represent;
- Facial and image recognition data. When you use our cloud solution, we will also collect the information that is upload to our Services such as facial and image recognition data;
- Information concerning your use of Services. This includes information related to your activities on our SAFR website, including pages visited; and
- Information about your hardware. This information may include your unique device ID (persistent/ non-persistent, MAC or IMEI), hardware, software, platform, and Internet Protocol (IP) address.
We do not intentionally or knowingly collect any personal information from children under the age of 13.
How We Use Your Personal Information.
We use information to provide you with our Services, as well as to enable our operations. Such uses might include:
- Verifying your access rights;
- Determining whether your device meets our minimum system requirements;
- Enabling compatibility and interoperability;
- Initiating automatic updates to downloaded Services;
- Providing language and location customization;
- Developing aggregated statistics that help us better understand how our Services are used and how to market them;
- Improving our Services, such as fixing problems and continually improving the performance of features; and
- Communicating with you, such as sending you messages concerning your account and customer service issues; asking you to participate in surveys; and delivering news, updates, promotions, and special offers.
When and How We Share Personal Information with Third Parties.
We will not share personal information with third parties without your consent, except as necessary for the purposes set forth in this Policy. We may disclose personal information that we collect or you provide as described in this Policy:
- To our subsidiaries, affiliates, and successors; or
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, provided that we will take reasonable measures to inform you in advance of such request; and
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ourselves, our customers, or others.
We use third-party analytics providers such as Google Analytics and Mixpanel to help us compile aggregated statistics about the operation and effectiveness of SAFR websites. Analytics providers set or read their own cookies, or other identifiers on your device, and transmit events through which they can collect information about your use of our websites and those of other companies.
Learn more about our analytics providers:
- You can learn more about Google Analytics, including how to opt-out, by visiting Google’s Privacy & Terms for Partners or visit our Cookies Policy.
- You can learn more about Mixpanel and how to opt-out by visiting our Cookies Policy.
If you search for specific content on the SAFR website, the search terms may be embedded in the “search string” that appears in the URL display window of your web browser. Certain advertising services or third-party content providers may associate these search strings with cookies they set or retrieve from our pages.
Retention of Personal Information.
We retain personal data for as long as necessary to provide the products and fulfill the transactions requested by the customers, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.
We revise this Policy as needed to keep it up-to-date with Services. When we do, we will update the date at the top of this Policy. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this page. We encourage you to periodically review this page for the latest information on our privacy practices.
Transfer of Data to Other Countries.
EU-U.S. And Swiss-U.S. Privacy Shield
In absence of an adequacy decision, Real provides appropriate safeguards for the transfers personal data to a third country or an international organization such as, but not limited to, standard contractual clause, and binding corporate rules. In absence of an adequacy decision and appropriate safeguards, Real will only make an international transfer of personal data if the transfer is necessary for the performance of a contract between you, as the data subject, and the controller, or for the implementation of pre-contractual measures taken at your request.
In some cases, Real may remain liable if a third party processes personal data on our behalf in a manner inconsistent with the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
If you have a question or complaint related to our participation in the Privacy Shield, we encourage you to contact us via our contact information below. For any complaints related to the Privacy Shield frameworks that cannot be resolved with Real directly, you may seek resolution of your complaint by contacting the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR-AAA). As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means. Real is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
EU Data Protection Rights.
We collect and process personal data about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You may request access to, and rectification or erasure of, personal data;
- If automated processing of your personal data is based on a contract with you or your consent, you have certain rights to data portability;
- If the processing of personal data is based on your consent, you have a right to withdraw consent at any time (without affecting the lawfulness of processing that occurred before its withdrawal); and
- You have a right to object to, or obtain a restriction of, the processing of personal data under certain circumstances.
You may exercise those rights by contacting us as described below. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
To ask questions or comment about this Policy and our privacy practices, contact us at:
1501 First Avenue South, Suite 600
Seattle, WA 98134