This Privacy Policy ("Policy") sets out the Center for REALTOR® Development’s (hereinafter referred to as “us” or “we”) privacy obligations and principles that apply to you (hereinafter referred to as "you" or "user") as a user of this website.

The Center for REALTOR® Development believes that your personal information deserves protection. We take the responsibility of handling that information very seriously. All personal information that you provide to us through our website, online registration forms, e-mail, your enrollment and participation in our courses, or otherwise, will be dealt with as provided in this Policy. By using our website, you consent to the Center for REALTOR® Development’s processing of your personal information as set forth in this Policy, the Privacy Notice for California Residents (if applicable), and any amendments to either.

For further understanding of the rules governing our website, you should also review our Terms and Conditions. For California residents, please read our Privacy Notice for California Residents.

This Policy will apply to all personal information collected, used, or disclosed by the Center for REALTOR® Development, except information that is aggregated in such a manner that it cannot be connected to an individual. We may use this aggregated information to generate statistics and aggregate reports for internal use and for sharing with affiliates, content providers, and advertisers. These statistics and aggregate reports will not contain any personally identifiable information. Your individual identity is always kept anonymous.

Collection and Storage of Information
In the course of our business, we may collect your personal information, including, but not limited to, your name, address, and e-mail address, from: (a) your registration for our services or purchase of any education courses or materials, (b) your usage of our website, (c) any communication, application or other form we receive from you or your authorized representative, whether in the ordinary course or in connection with any special offers, contests or other promotions offered by us, (d) your transactions with, or from the services performed by, us, our affiliates, our underlying service provider, Crowd Wisdom, or others, including our parent, the National Association of REALTORS®, and/or (e) “cookies” that are used to store and track your preferences and your access privileges on our website. A cookie is data sent to your Internet browser from a web server and stored on your computer hard drive. Cookies make your web experience easier by saving your personal member information and retrieving it each time you visit our website and by storing your usage patterns and preferences and personalizing your experience by alerting you to features and information we think may be of interest to you. Cookies are used by most Internet websites and are required to use our website to increase the functionality of our website and to enhance your experience. Specifically, cookies set by our website are: (i) random session identification and token numbers that are generated each time you visit our website, and (ii) various other values that allow us to know what courses are available to you, your course history, your progress, etc.

We maintain any personal information collected hereunder in our customer database.

We collect personal information for the following purposes:

• To build your Center for REALTOR® Development member account;
• To process your course registrations;
• To process your CE credits, designations, certifications and for other similar purposes;
• To personalize the delivery of website content to you;
• To build and maintain your online report card;
• To provide the service or course requested;
• To enable billing and shipping;
• To provide you with information about related products and services based on the preferences you have indicated;
• To improve our website;
• For our development of new products and services; and
• For systems administration and troubleshooting purposes.

How do we protect your personal information? When you provide us with personal information or make a purchase, it's done through a secure server, Secure Socket Layers (“SSL”). SSL encrypts all information you provide before sending it to our own server. Only when it reaches our server is your information decrypted.

We will endeavor to advise any third party with whom we share your personal information of the confidentiality of the information and the purposes for which it is to be used.

Do you disclose personal customer information to third parties? In general, we use the information collected to provide services and courses to you and to communicate with you. However, we may share your personal information:

• With our employees, contractors, consultants and other parties who require that information to assist us with managing our relationship with you and processing your CE credits, designation, certification or for similar purposes, including, without limitation, third parties that provide services to us or on our behalf, including the company that develops and hosts the courses in which you may register;
• As permitted or required by applicable law or regulatory requirements or to protect the rights, property, or personal safety of the Center for REALTOR® Development, its users, or the public against harm;
• To enforce or investigate a potential violation of our Terms and Conditions;
• To detect, prevent or otherwise respond to fraud, security, or technical concerns;
• In the event that the Center for REALTOR® Development or the National Association of REALTORS® is involved in a merger, acquisition, or any form of sale of some or all of its business, your information may be shared with its successors or assigns;
• Where the personal information is publicly available; and
• With your consent or at your direction.

We may include on our website links to the websites of other entities, including without limitation, our underlying service provider, Crowd Wisdom. These third-party websites may collect personal information about visitors and users, and this Policy does not govern collection and use of any such personal information. By accessing any link to websites of other entities via our website, you acknowledge and agree that your identification information with the Center for REALTOR® Development may be shared with such third party. Please review the privacy policy of each third party, including without limitation, the privacy policy of Crowd Wisdom, for relevant terms regarding collection and use of any personal information by such third party

Unless required by law, we will not use or disclosure personal information for any purpose other than those described above without obtaining your consent, where such consent may not reasonably be implied.

E-commerce Securities & Guarantees We use technology and third party e-commerce transaction processing companies that ensure your payment information is kept confidential and secure. Unless you enroll in a course that is billed on a subscription basis, credit card details will not be stored after your purchase is processed and billing information will need to be provided each time a course is chosen.

You may review and approve the information that you provided to us upon registration in our customer database. Upon request, we will remove that information from our customer database or change/correct personal information that you state is erroneous.

Privacy Contact Questions regarding this Policy should be directed to Privacy Office at [email protected] or 1.800.874.6500.

Center for REALTOR® Development (“us” or “we”)

Privacy Notice for California Residents

Effective Date: 9/25/2020

Last Reviewed on: 9/25/2020

This Privacy Notice for California Residents (“Notice”) supplements the information contained in the Center for REALTOR® Development’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

● Publicly available information from government records.

● Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

● Directly from you. For example, from forms you complete or your login to our Website.

● Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.

· To provide, support, personalize, and develop our Website, products, and services.

· To create, maintain, customize, and secure your account with us.

· To process your requests, purchases, transactions, and payments and prevent transactional fraud.

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party, including without limitation, our underlying service provider, Crowd Wisdom, for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category J: Non-public education information.

We disclose your personal information for a business purpose to the following categories of third parties:

● Service providers.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information. We do not, and will not, without prior notice to you, sell your personal information to any third party.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), 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 (also called a data portability request).

● If we disclosed your personal information for a business purpose, a list of disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

● Calling us at 800-874-6500

● Emailing us at[email protected]

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, without limitation:

○ First and Last Name

○ Login Information (User Name)

○ NRDS ID

● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance;specifically, we will provide this information via email to the email address specified in your request for information or your member account.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell your personal information. However, if you access a third party’s website via our Website, youridentification information may be transmitted to the third party. By accessing any such link, you consent to the transmission of your identification information to the third party, you agree to review the third party’s privacy policy and terms of use, and you release us from all liability in connection with such sharing and the third party’s use of that personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

● Deny you goods or services.

● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

● Provide you a different level or quality of goods or services.

● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can resultin different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone:800-874-6500

Email:[email protected]

Postal Address:

Center for REALTOR® Development

430 N. Michigan Ave.

Chicago, IL 60611