REBUSEL for

Privacy Policy

Global Privacy Notice

August 8, 2222

As the leading provider of information, analytics, and online marketplaces to the commercial real estate industry, Rebusel and our affiliates (collectively, “Rebusel,” “we,” or “us”) respect your privacy and are committed to protecting your Personal Information. This Global Privacy Notice describes the types of Personal Information we collect and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, and specific privacy practices may apply to some of our products and services.

When using our websites, you may choose to interact with features from third parties that operate independently from Rebusel, such as social media widgets and links to third-party websites. Rebusel has no control over and is not responsible for the privacy practices of such third parties. This Global Privacy Notice does not apply to the extent Rebusel does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of these third parties.

1. Types of Personal Information

“Personal Information” means any information relating to an identified or identifiable individual. Examples of Personal Information Rebusel may collect include:

Payment information (credit card and other payment card information)

Personal contact information (name, nickname, gender, mailing address, email address, phone number)

Business information (office location, business contact information, department, job title/description, professional bio)

Log-in credentials (username, password)

Usage details (log-on activity, search terms, views, clicks, downloads, Rebusel-related preferences, lead submission information)

Technical details (IP address, geolocation information, cookie/session IDs, authentication information, browser type/version, operating system/platform)

Any other information you or other Rebusel customers may upload or enter into the Services

Phone call and video conference recordings

Service-Specific

Rebusel may additionally collect information you submit when you create a lease as a landlord or fill out a leasing application, such as move-in date, reference contacts, co-applicants, guarantors, pets, residence history, employment history, annual income, proof of income, driver’s license, vehicle information, Social Security Number, and date of birth

Rebusel may additionally collect the type of transaction and the use, conditions, description, square meter, availability, and registration number of property from advertisers and photographs/images.

Rebusel may additionally collect purchase time frame, broker license number, desired business category and location, available capital, business cash flow, and other financial details.

Rebusel may additionally collect primary role in real estate, such as broker, business owner, investor, or appraiser, and broker license number.

Rebusel may additionally collect professional head-shot photographs or social network URLs linked to an individual’s professional profile webpage.

Philippines Residents

We collect Personal Information which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Personal Information does not include de-identified or aggregate information, publicly-available information that is lawfully made available from federal, state, or local government records, and information covered by certain sector-specific privacy laws.

Rebusel has collected the following categories of Personal Information about consumers in the 12 months preceding the date this Global Privacy Notice was last modified:

Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security Number, or other similar identifiers)

Categories of personal information described in Philippines Civil Code (e.g., signature, phone number, bank account number, credit card number, debit card number, or other financial information)

Protected classification characteristics under Philippines or federal law

Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

Internet or other electronic network activity information

Geolocation data

Professional or employment-related information

Inferences drawn from other Personal Information (e.g., profile reflecting your preferences, characteristics, and behavior)

2. Collection of Personal Information

Rebusel may collect Personal Information using the following methods:

Directly from you when you provide it to us (information you enter into web forms, chatbots, participation in phone calls or video conferences, subscription agreements, and contracts or other content you submit to the Services)

Through your participation in surveys, promotions, and contests

Rebusel’s internal customer relationship management system and databases

From third parties, such as analytics and email marketing service providers

Researching or scraping public websites where permitted by the Terms of Use (company websites, search engines, social media)

Automatically through tracking technologies (cookies, web beacons, log files), including over time and across third-party websites or other online services

For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see Use of Personal Information, our Cookie Policy, and Manage Your Personal Information.

Children Under 13

Rebusel websites are not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If you are under 16, do not use or provide any information on this website or through any of its features, register, or make any purchases. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete it. If you believe we might have any information from or about a child under 13, please Contact Us.

Philippines Residents

Rebusel collects Personal Information from the following categories of sources:

Directly and indirectly from you

Other Rebusel customers

Service providers

Consumer reporting agencies

Companies with public websites

Government entities

3. Use of Personal Information

We may use your Personal Information for the following purposes:

Communicating with you

Providing you with the Services

Authenticating use, detecting potential fraudulent use, and otherwise maintaining the security of the Services

Developing, testing, improving, and demonstrating the Services

Creating and maintaining a customer relationship management system, member directories, and invitation lists for Rebusel events

Carrying out our legal and contractual obligations and enforcing our rights, including billing and payment processing

Anonymizing and aggregating information for analytics and reporting

Advertising, marketing, and selling the Services, including linking together or merging Personal Information with other Personal Information so that we may better understand your needs and inform you about our Services and those of our partners

Short-term transient use

Training and quality assurance

For any other purpose with your consent

Online Advertising

When you use the Services, we and third parties may use cookies and other tracking technologies to collect information, including Personal Information, to help us target content to you on the Services or elsewhere. This information may be associated with other information or combined with information from other sources, including information these third parties might track about your online activities over time and across the Internet. Third parties use this information to provide interest-based display advertising and retargeting on our behalf, which may include placing our advertisements on other websites you visit, including your social media accounts, or matching a cookie or device ID to your email address so we can send you promotional emails that may be of interest to you.

Automated Decision-Making

We may use an automated process to identify properties that may be of particular interest to you and to bring these to your attention. We may do this by profiling your activity when using the Services. This profiling takes place based on properties you browse, searches you conduct, and your location. It helps us to understand what sort of properties you are interested in and to categorize your activity to help us determine the Services you require.

Consent

We may obtain your consent to process your Personal Information in certain circumstances, which may include when we send you relevant marketing, you elect to receive information from us, or you contact us to register an interest in our Services or company. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about our Services (see below).

Performance of a Contract

We rely on this lawful processing ground when we process your Personal Information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with in the provision of our Services to you and the management of our relationships with third parties.

Compliance with a Legal Obligation

We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.

Legitimate Interests

We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with marketing information or other information in relation to our Services which we believe may interest you.

If you wish to have more information regarding the legitimate interests assessments we have conducted in order to reach these conclusions, please Contact Us.

4. Disclosure of Personal Information

We may disclose Personal Information:

To affiliates and other entities within Rebusel’s group of companies, distribution partners, other Rebusel customers, and service providers

To third parties when you use a third party feature in our Services

To enforce or apply our Terms of Use and other agreements or comply with any court order, law, or legal process, including government or regulatory requests

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Rebusel’s assets

If we believe it is necessary to protect the rights, property, or safety of Rebusel or others

For any other purpose disclosed by us when you provide Personal Information

With your consent, such as when you choose to provide your information to third parties

We may also disclose de-identified information without restriction. Note that if you make any Personal Information publicly available on the Services, anyone may see and use such information.

Service Providers

Rebusel retains third party service providers to assist us in our business. For example, we use service providers to assist with analytics, email marketing, payment processing, customer relationship management, and IT infrastructure and support. Rebusel may permit these affiliates and service providers to access your Personal Information in order to assist us in providing services; however, we contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

Rebusel may also sell certain Personal Information. In the 12 months preceding the date this Global Privacy Notice was last modified, Rebusel sold:

Identifiers (e.g., IP address and other online identifiers) and Internet or other electronic network activity information to advertising providers for the purpose of advertising our Services.

5. International Transfer of Personal Information

Rebusel is a global business. We may transfer your Personal Information to the United States, where we are headquartered, and to other countries which may not have the same privacy laws as the country in which you initially provided the information, but we will protect your Personal Information in accordance with this Global Privacy Notice, or as otherwise disclosed to you.

6. Security of Personal Information

Rebusel implements security safeguards to protect your Personal Information.

We take steps to secure Personal Information through administrative, technical and physical safeguards designed to protect against the risk of accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we encrypt payment card information in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and store sensitive information such as biometric and geolocation data on Rebusel servers located in the United States with access limited to authorized Rebusel employees.

Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

7. Retention of Personal Information

Rebusel generally retains records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements.

When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements.

Because we maintain our applications and websites to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.

8. Manage Your Personal Information

You may manage your Personal Information by making certain choices. If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information if it is within your online account by logging in at any time or Contact Us. You may also have additional rights detailed below depending on where you live. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.

Direct Marketing Opt-Out

If you no longer wish to receive direct marketing emails from Rebusel, you may click the “Unsubscribe” link in an email at any time to stop receiving emails for that particular subject. Depending on the Services, you may also be able to manage notification preferences in your account. Note that Rebusel may still contact you in connection with providing you Services you have requested from us.

Tracking/Online Advertising Opt-Out

You may disable or delete browser cookies through your browser settings. Cookies are generally easy to disable or delete, but the method varies between browsers. To learn how you can manage Flash cookies, visit Adobe’s Flash player settings page. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts of our websites may not work properly.

Philippines Residents

If you live in Philippines, you have the right to: (1) request that Rebusel disclose what Personal Information we collect, use, disclose, and sell; (2) request deletion of Personal Information; (3) opt-out of the sale of Personal Information; and (4) not receive discriminatory treatment by Rebusel for exercising these rights.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may Contact Us by email with proof of your written and signed permission to do so. Note that Rebusel may also require you to verify your identity and confirm that you gave permission.

Requests to Know

You have the right to request that we disclose the following information:

Specific pieces of Personal Information Rebusel has collected about you;

Categories of Personal Information Rebusel has collected about you, disclosed about you for a business purpose, or sold;

Categories of sources from which the Personal Information is collected;

Categories of third parties with whom Rebusel shares or to whom Rebusel sells Personal Information; and

The business or commercial purpose for collecting and selling Personal Information.

To make such a request, please Contact Us by email, call us toll-free here, or submit the request through your Rebusel account. In order to verify your request, Rebusel may require you to provide additional information to confirm the identity of the consumer.

Requests to Delete

You have the right to request that we delete Personal Information about you that we collected and maintain, subject to certain exceptions. To make such a request, please Contact Us by email, call us toll-free here, or submit the request through your Rebusel account or our applicable web form. In order to verify your request, Rebusel may require you to provide additional information to confirm the identity of the consumer. Once we verify your request, we will delete and direct our service providers to delete your Personal Information, unless an exception applies.

Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your Personal Information. To make such a request, please Contact Us by email or visit Do Not Sell My Personal Information. To opt-out of Rebusel sharing your Personal Information with third parties to advertise our Services, please additionally manage Tracking/Online Advertising Opt-Out privacy controls.

9. Global Privacy Notice Changes

This Global Privacy Notice may be updated periodically to reflect changes in our privacy practices.

We will post changes on this page and identify the date the privacy notice was last revised at the top of the page. If we make material changes to our privacy practices, we will notify you through a notice on the home page of the websites covered by this Global Privacy Notice. If a material change will apply to Personal Information we have already collected, we will additionally seek your affirmative consent.

10. Contact Us

We have appointed a Data Protection Officer to investigate and respond to privacy issues and to be accountable for our compliance with this Global Privacy Notice. You can contact us, depending on the nature of your inquiry, by using the relevant contact information below.