- About NER and How to Contact Us
- Sources of Personal Data
- What Personal Data do we Collect and Why
- Our Use of Personal Data
- Data Retention
- Who Receives Your Data
- Opt-Out of Marketing
- Transfers of Personal Data
- Data Protection Rights
- Data Protection Officer
- Accountability for Onward Transfer
- Our Policy with Respect to Children
- Privacy Shield Policy
- Recourse Mechanism
1. About NER and How to Contact Us
Northeastern Realtors, LLC is the controller of your personal data. We also act as data processor when providing certain services to our clients. If you have any privacy concern or questions about how your personal data is used, please feel free to contact us.
Northeastern Realtors, LLC (collectively “NER”, “we,” or “us”) develops and sells real estate transaction software and provides real estate service to consumers. You can find a list of NER’s products and services at https://nercloudoffice.com.
We operate globally through Amazon cloud service network. The location of our physical office is: 520 Blue Hill Ave, Milton, MA 02186.
We are data controller and data processor
NER is the data controller of information collected through this website or when you otherwise interact with us. There are certain circumstances where our affiliates may also be data controllers or data processors, for instance when you engage us for the provision of services, but we will inform you of these circumstances in advance.
How to contact us
If you want to exercise your data protection rights, have any questions, or need further information about this Privacy notice or the processing of your Personal Data by NER, please contact us by email at email@example.com
- On this Website;
- On our real estate transaction platform https://platform.nercloudoffice.com;
- On our marketing website https://www.nercloudoffice.com;
- On our support website https://support.nercloudoffice; and
- Any other software our staff uses internally within our company.
We are committed to complying with local legal requirements.
- All electronic communications with NER, including visiting our website (‘Website’);
- Personal data we receive from anyone who requests information or otherwise interact with us;
- Job applications with NER;
- Our marketing activities, including events and conferences;
- Our collection and use of information in the normal course of business.
3. Sources of Personal Data
We collect information from different sources depending on the context of your interactions with NER, for instance when you visit our website, when applying for a job position, or when engaging our services.
We collect information and data from you in various ways, including:
Information received directly or indirectly from you:
- Contact and event registration. Information that you provide when you contact us, or for event registration;
- Job applications. When you apply for a job position with NER;
- Business relationships. When you provide or receive services from NER we usually collect information voluntarily from you, or from third parties, with your authorization;
Or from third-party sources:
- Information that we obtain from other third-party sources such as social media sites, company websites, and subscription-based third-party databases such as corporate research databases.
4. What Personal Data We Collect and Why
Depending on the relationship you have with NER and where you are located, we collect and use different types of personal data, according to local laws.
“Personal Data” as used herein means all information that can directly or indirectly identify you or other individuals.
If you choose to submit your contact information to indicate an interest in our services, we receive from you your name, address, telephone number and e-mail address. If you choose to submit your e-mail address to indicate an interest in our electronic newsletter, we receive from you your e-mail address.
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal data can also include information about any transactions, both free and paid, and information about you that is available on the internet, such as from LinkedIn, Twitter and Google.
We may collect personal information about you (such as name, email address, Social Security number or another unique identifier) only if you specifically and knowingly provide it to us. We will use your information to process requests for certain services or information. Providing your information is generally voluntary, but if it is not provided, we might not be able to process your transaction. When information is required, we will let you know before we collect it.
Our websites do not currently support “do not track” settings on your browser or have any similar mechanism that allows you to opt out of or otherwise control the collection of certain information about your online activities. We collect PII and other information only as necessary to administer our programs. The information you provide will be used only for that purpose. We do not sell the information collected at this site or any other information we collect. You do not have to give us personal information to visit our websites.
Technical Usage Information and Analytics
Contact information for Event Registration and to respond to inquiries
We collect your name, email, title, company, postal address, telephone number or other information that you voluntarily choose to provide to us for event registration, or to send you marketing information as requested.
If you do not provide us with all the information requested for event registration, we may not be able to respond to your request or needs.
If you apply for a position at NER, we will collect information such as name, address, telephone number, resume, employment history, education, reference information, salary expectations, work permit/visa requirements, and other information that you choose to provide to us.
When providing names and contact information of third-party references in connection with applying for a position with NER, you represent that you have obtained permission from your references to provide us with their personal information. Any providers we engage during the screening process will be vetted to ensure they have the appropriate privacy and security practices in place.
If you don’t provide us with all the requested information, we may not be able to consider your job application.
Additionally, as permitted by applicable local law and when you authorize us through a separate consent, we will collect special categories of personal data, your social security number, or a consumer report (e.g. background check). Note that we don’t want this information or additional details, like your date of birth and financial information, in your resume.
When we have or are developing a business relationship, we collect contact business information, such as: names, titles, contact information and emails from you (if you are a natural person) or from your employees or representatives, including areas of interest and potential synergies for future projects.
When receiving or providing services, we also collect payment information, conflict checks and credit reference information (including background checks when appropriate and according to local laws).
If you do not provide us with the information required, we may not be able to do business with you.
Information related to the provision of our services
When providing services to clients, in additional to business information we will process different documents that may contain personal data, and special categories of personal data.
The provision of this type of information and consequences are defined on our terms and conditions policies.
We will collect certain information for security purposes in order to verify your authorized access to an account or to reset your password if you cannot access your NER account. Some Services may require added security and you may be asked to provide additional information. The email address and password that you use to sign up for a NER account are your “credentials” that you will use to authenticate with our network. We assign a unique ID number to your credentials to track you and your associated information. NER Services do not allow sharing of accounts between users or individuals.
Information from Other Sources
The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, additional contact information) that we have acquired in accordance with law. For example, if you work at a real estate brokerage firm but we don’t know your title, we may go to the firm’s website or a social media site to confirm your title.
We do not use solely automated decision-making systems.
5. Our Use of Personal Data
The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are a website visitor, one of our clients, or if you apply for a job position with us.
We collect and use Personal Data collected from you according to the following purposes and legal basis:
When it is necessary for entering into or the performance of a contract:
- We process your job application for employment management and recruitment purposes;
- Compliance with contracts and engagements. We collect personal data to perform our business functions providing tax return submission services to clients, and executing contracts with our providers;
- Billing and payments; we collect data of the appropriate representatives of accounts payable or receivable
To comply with applicable laws:
- To comply with laws such as anti-money-laundering rules, fraud prevention, tax, employment and other relevant national laws;
- Courts, and law enforcement requests. Including disclosures to courts, public authorities and law enforcement;
For our legitimate interests in:
- Responding to inquiries and information requests;
- Providing registration for Events. We collect information necessary for the organization of events, seminars, and publications related to our different practices and services;
- Conducting Marketing activities. Our marketing activities include sending newsletters, updates, and other information and materials related to our services and events that we think will be of your business interest;
- Engaging in Business development. Building business relationships and synergies for future projects with our clients and potential clients, including business strategy decisions;
- Client Administration and management. Consolidating information relating to our clients, potential clients and service providers for the provision of services and for business development purposes;
- Information security. Implementing security measures to protect availability, integrity and confidentiality of information processed by NER, and to prevent and respond to cybersecurity threats and data breaches.
- Defending our interest and legal rights. For instance, to enforce our website terms, policies and contracts with clients and providers; for the establishment, exercise or defense of legal claims;
- Business transfer. Sharing certain personal data in the context of a merger, sale, acquisition, reorganization, dissolution or other change of ownership of control;
We also use your personal data based on your consent, in these cases you can withdraw that consent at any time:
- When appropriate and permitted by applicable local laws we process special categories of personal data based on your explicit consent (for instance when you provide diet preferences or disability-related needs when you register to our events).
- Some marketing activities and events are based on your consent (for instance, when we don’t have a business relationship with you).
6. Data Retention
We retain personal data only for the length of time required to fulfill the purpose for which the data was collected or to comply with legal obligations.
According to our retention policy, we retain Personal Data as necessary for the duration of the purposes outlined in this Privacy Notice and to comply with our legal obligations. The retention period depends on the context in which we process personal data, for instance:
- Career information. We keep your personal data up to 5 years for potential future opportunities unless you request that we delete your information sooner. If you are successful and offered an employment with NER, this information will be retained and transferred to your personnel file and used to manage your employment or other relationship with NER (e.g. to administer benefits, training, performance reviews, regulatory compliance).
- Remaining information. The rest of retention periods are determined by the purposes defined above for which the information is collected and used, for instance when it is necessary to continue providing a service or to comply with our professional obligations, taking into account applicable data protection laws, and legal requirements, including tax and anti-money laundering regulations, that may vary depending on the jurisdiction.
We will delete or block your Personal Data after these retention periods, unless you authorize us to keep it, or when it is necessary to enforce our agreements or resolve disputes.
These storage terms apply unless agreed otherwise in a contract with NER or in locally applicable legislation.
7. Who Receives Your Data
At times, we disclose your personal data to our vendors to help accomplish our business objectives and provide you services. There are other circumstances where we are required by law to disclose personal data to public bodies or judicial authorities.
Information collected may be shared with:
We may share the information we collect about you with our NER affiliates.
The information may be disclosed (i) to provide joint content and our services (e.g. real estate transaction services); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our NER services, website, and communications.
Service Providers and Other Third Parties
We may disclose your information to service providers under contract who help with our business operations including, sub-contractors supporting the delivery of professional, technology, or communication services. Any providers or third parties we engage will be vetted to ensure they have the appropriate privacy and security practices in place.
Other Entities with your Consent
We will disclose your information to other third parties to whom you explicitly ask us to send your Personal Data. On this Site, you may have opportunities to express interest in or register for other services such as registering for events and webinars organized by third parties. If you do, we will provide your Personal Data to those third parties, to fulfill your request.
Social media sites
We may disclose your Personal Data as required by law, such as to comply with lawful requests by enforcement and public authorities or courts, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will use reasonable endeavors to notify you before doing so, unless we are legally restricted from so doing.
Change of Control
NER may in the future reorganize or transfer all or part of its businesses, which may result in the transfer of your Personal Data to new NER entities or third parties through which the whole or a part of the NER businesses will be carried out. If NER becomes insolvent, enters receivership or any similar or equivalent event occurs, parts of the business may be sold or transferred to a third party. This change of control may result in the transfer of your Personal Data to a third party that will carry out the business.
8. Opt-Out of Marketing Communications
You can opt-out of your marketing communications anytime.
You can opt-out of receiving our newsletter or other marketing communications by following the opt-out instructions in our commercial e-mails or by contacting firstname.lastname@example.org
9. Transfers of Personal Data
If you are located outside the United States and you interact with our Website or provide NER Personal Data, then your information may be transferred to the United States. Only in certain circumstances, your personal data will be transferred to other jurisdictions. However, we provide appropriate safeguards to ensure the same level of protection of your personal data.
If you are located outside the United States and you interact with our Website or provide us Personal Data, then your information may be transferred to NER or to our third-party service providers located in the United States. In certain circumstances, for instance, when it is necessary for the provision of services, we may transfer your personal data to service providers based in other jurisdictions. In these situations, we ensure compliance with local data protection requirements.
10. Data Protection Rights
If you interact with our Website, reside in these territories or in other locations where similar rules apply NER is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence.
Your rights under the GDPR consist of:
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erasure;
- The right to restrict processing;
- The right to data portability;
- The right to object; and
- The rights in relation to automated decision making and profiling.
NER is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence. Accordingly, some of the rights listed below will only apply in certain circumstances. You can contact us at any time to discuss any of these rights or your privacy concerns at email@example.com
- Right to access, and rectification: we provide you with access to your own personal data where required by applicable law. In addition, we will rectify your Personal Data when we are notified that it is inaccurate.
- Right to object, restriction of processing, erasure and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities, the right of erasure and restriction of processing will be balanced to ensure that these are not incompatible with local laws and regulations or other overriding rights. When we have collected your personal data with your consent, then you can withdraw it at any time.
- Right to data portability: based on your specific situation, we provide you with the right to obtain and reuse your data across different services, including the transfer of your data to you or to another third-party.
- Right to lodge a complaint with your supervisory authority: if you are not satisfied with our response or how we process your personal data you can complain to the data protection authority of your habitual residence.
How to exercise these data protection rights
All these requests should be submitted as follows:
- Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails or by contacting us at firstname.lastname@example.org
- To exercise the rest of your rights: you should send a communication in writing to email@example.com. NER will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
- You also have the right to lodge a complaint with a supervisory authority: A list of the European authorities is available here, the contact information of the Federal Data Protection and Information Commissioner of Switzerland is available here, and the Information Commissioner’s Office in the UK is available here.
11. Data Protection Officer
A defined role of Data Protection Officer (DPO) is required under the GDPR if an organization is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider.
Based on these criteria, the Company DOES NOT require a Data Protection Officer to be appointed.
We take commercially reasonable precautions to try to keep all information obtained from you secure against unauthorized access and use, and we periodically review our security measures.
13. Accountability for Onward Transfer
NER will apply the notice and choice principles in providing EUPI collected directly from a EU Person and thereafter provided to a third party. NER is potentially liable in cases of onward transfers of EUPI to third parties. Accordingly, NER will obtain assurances that its agents and subcontractors use safeguards consistent with this Policy.
14. Our Policy with respect to Children
Our services are not directed to children
We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, please contact us at firstname.lastname@example.org
This Policy was last updated on January 16, 2021.