Privacy Policy

This privacy statement discloses the privacy practices for The Real Deal.

UPDATED: December 2021

Data We Obtain

Personal Data From Participating Company Affiliates

We receive Personal Data about:

  • users of various The Real Deal (TRD) brands and properties:
    • who visit and interact with our Company affiliate sites and applications;
    • who participate in TRD surveys; and/or
    • from publicly and commercially available sources; social media networks.

As further discussed below, we collect Personal Data to offer advertising services that we have a legitimate interest to believe are of interest to our customers and/or that you have requested, to manage the relationship we have with our customers, and to perform other activities based on your consent where required by law.

The types of Personal Data the Company may obtain from Company affiliates, surveys, and publicly and commercially available sources include:

  • Name
  • Postal and/or billing address
  • Email address
  • Telephone and/or mobile numbers
  • Geo-location (such as city, state and zip code associated with your IP address)
  • Username
  • Preferences and shopping interests
  • Demographical data (such as ethnicity (to the extent permitted), gender, age range, educational level, household income range, number of children in household)
  • Occupational data (such as profession, position, title, industry)
  • Survey responses, reviews and comments
  • Data provided to us by social networks when you visit Company affiliate social media platforms, social networking sites or otherwise register on a Company affiliate site or application through your social network account (such as name, likes, location, friends list and other information described when you connect with the social networking platform). The specific information we obtain depends on your privacy settings on the applicable social media network.

Data Obtained by Automated Means

We also obtain certain data by automated means, though the use of cookies (including HTTP and HTML5 local storage), web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your usage of various Company affiliate sites and mobile applications, and other offerings and services. A “cookie” is a file that websites send to a user’s computer or other Internet-connected device to identify the user’s browser or to store information or settings in the browser. A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

The data the Company obtains and receives from users of its affiliates’ sites and applications through these automated collection methods may include:

  • IP address
  • Mobile device advertising ID
  • Browser characteristics
  • Device characteristics
  • Operating system
  • Language preferences
  • Referring URLs
  • Information on actions taken on Company affiliate sites
  • Dates and times users access or use Company affiliate sites
  • Cookies set on Company affiliate sites for syncing purposes as described below.

We may link this data, such as browser or device information, with other data obtained by automated means, including what search queries you may have run and what advertisements you may have seen on Company affiliate sites and the advertisements placed by TRD on whitelisted non-Company sites.

You can learn more and control Flash Cookies by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies some or all of the features of the Company affiliate services may not be available to you. User device settings also may limit mobile application platforms (such as Apple and Google) from sharing certain data obtained by automated means with us through our Company affiliate mobile applications.

ID Syncing

ID syncing, also known as cookie syncing or cookie matching, is a common industry practice that enables businesses to use data to coordinate an advertising campaign across multiple publishing platforms and advertising service providers. As an example, an individual uses a web browser to visit a publisher’s website and then leaves the website. The publisher wants to advertise relevant services to that visitor after he/she leaves the website. To do so, the publisher stores a cookie on the visitor’s browser with an ID (such as “123”) and associates the ID with information about what the visitor viewed on the publisher’s website, and buys advertising through an online advertising exchange or marketplace. In order to buy appropriate advertising to display to that visitor, the publisher would need to match the “123” ID with the ID that the exchange has assigned to the same visitor (for example, exchange ID “XYZ”). Using ID syncing, the publisher “123” ID is associated with the same browser or device as the exchange ID “XYZ”. In addition, the publisher may be able to show more relevant advertisements to the visitor based on the initial information the publisher collected from that visitor when the visitor was on the publisher’s site. For example, the syncing allows the publisher to match the data collected from the visitor while on the publisher’s site with other sources of data also associated with the visitor. This syncing can be done across multiple sites.

The Purposes & Legal Bases for Which We Use the Data We Obtain

With your consent, when required under applicable law, we use the data collected from and about you, and rely on legitimate interest to use the data, to:

  • Supplement Personal Data collected by the Company and our affiliates with additional data from publicly and commercially available sources, and make inferences regarding your preferences and further supplement your profile with such inferred preferences to provide relevant content and advertising;
  • Display targeted advertising on Company affiliate sites and whitelisted non-Company sites;
  • Customize your visits to and use of our Company affiliate sites and applications, and deliver content (including advertising) tailored to your interests and the manner in which you use our Company affiliate sites and applications (please also see the Interest-Based Advertising Section below for more details);
  • Aggregate Personal Data and non-Personal Data to generate statistics of non-personally-identifiable data to include such statistics in reports to share with third parties;
  • Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes (please also see the Interest-Based Advertising Section below for more details);
  • Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our programs and offerings; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
  • Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities; and
  • Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.

With your consent, when required under applicable law, we use the data to:

  • Customize your visits to and use of our Company affiliate sites and applications, and deliver content (including advertising) tailored to your interests and the manner in which you use our Company affiliate sites and applications (please also see the Interest-Based Advertising Section below for more details);
  • Administer surveys, market research and contests.

We also may use your Personal Data in other ways for which we will provide specific notice, and if necessary, seek your consent, at the time of collection. In addition, when the data collected from or about you does not identify you as a specific person, we may use it in any lawful manner.

Interest-Based Advertising

On our Company affiliate sites, applications and/or emails, we and our service providers obtain data about your activities to provide you with advertising about products and services tailored to your individual interests.

Throughout the TRD advertising exchange, we can gather information about online activities over time and across Company affiliate sites and applications by obtaining data, as described above, and may link such data to a user’s browser or device and associate that data with other browsers or devices linked to the user. Collection of such data currently takes place on the Company affiliate sites, applications and emails that participate in our advertising exchange. Our exchange uses all such data to show users advertisements on our Company affiliate sites and applications and on whitelisted non-Company sites that aim to be tailored to your individual interests. We also track the effectiveness of marketing campaigns conducted through the TRD advertising exchange, which also include whitelisted non-Company sites.

The Company adheres to the Digital Advertising Alliances Self-Regulatory Principles and provides users choice with respect to the Company advertising exchange interest-based advertising. The Company is also a member of the European Interactive Digital Advertising Alliance (“EDAA”) and adheres to the EDAA’s Self-Regulatory Framework. To learn how to opt out of the TRD interest-based advertising see the section on Your Choices below.

The Company also participates in the IAB Europe Transparency & Consent Framework (the “Framework”) and complies with its Specifications and Policies. The goal of the Framework is to inform users about the storing and/or accessing of information on their devices and the personal data about them that is being processed, the purposes for such processing and the companies that are seeking to process their personal data for such purposes, and to provide users with choice about such processing. For more information on the Framework, please visit the following site: https://iabeurope.eu/transparency-consent-framework/.

Transfers of Data

The data obtained by the Company may be hosted in and managed from a country outside the country in which users initially provided the information. We transfer the Personal Data we collect about you to the United States, and may also transfer Personal Data to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the Personal Data. When your Personal Data is in such countries, it may be accessed by the courts, law enforcement and national security authorities in accordance with applicable law.

We will protect your information as described in this Notice and will implement appropriate safeguards to ensure that your Personal Data remains protected.

Data We Share

With your consent, when required under applicable law, we may share your data with:

  • Our participating affiliates and other Company affiliates, any of whom may use Personal Data consistent with this Privacy Notice or for each of their own purposes, including marketing purposes. 
  • Service providers (or data processors) in the US and other jurisdictions that perform services on our behalf. Services NCAE receives include database hosting, analytics, advertising placement sales, advertisement delivery.
  • Our advertising clients to provide reports on advertising campaign parameters, performance and other metrics. We may also share your data with our advertising clients for their own direct email marketing campaigns to the extent you have consented as may be required under applicable law, and for their own targeted advertising programs. Typically, however, our advertising clients and third party business partners will collect data about you directly from their advertising unit through their own cookie placed on the advertising unit.

Our affiliates, service providers and advertising clients are obligated to process the Personal Data in a manner consistent with the standard contractual clauses, and TRD remains responsible under the Principles for its affiliates and service providers. We have agreements in place with our service providers and advertising clients that ensure the adequacy of data protection practices.

In addition, when the information collected from or about you is aggregated and otherwise does not identify you as a specific person, we may share it with third parties at our discretion. For example, we may include and share your data in a report that consists of aggregated demographics of an audience against which an advertising campaign was served.

We may further disclose Personal Data about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, and (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer data in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Your Choices

We offer you certain choices in connection with the Personal Data we obtain.

Opting Out of Receiving TRD’s Targeted Advertising and Disclosing Personal Data to Certain Third Parties

If you wish to opt out of receiving personalized advertisements from TRD or if you no longer wish to have your personal data shared by TRD for advertising purposes, you may click here. When such choice is exercised on a browser, TRD will also stop using and sharing or selling data from that browser for interest-based advertising on other browsers and/or devices associated with that browser by TRD, and in turn, will stop using data from those associated browsers and/or devices for interest-based advertising on the initial browser. You may also visit www.aboutads.info/choices, or www.youronlinechoices.eu for EU/EEA users to stop receiving TRD targeted advertising. Please note that opting out of receiving personalized or interest-based advertisements from the Company will only opt you out of receiving personalized or interest-based advertisements from TRD, and you may continue to receive personalized or interest-based advertisements from others, including the Company affiliates, and our third party business partners, and each of their advertising networks, and/or other advertisements that are not tailored to your interests. For more information about interest-based advertisements, and to opt out of other advertising for companies participating in self-regulatory programs, please visit: www.aboutads.info/choices and www.networkadvertising.org/choices.

Accessing, Reviewing, Updating and Modifying Personal Data

Subject to applicable law, you may be provided access to, and/or be able to review, update, and correct inaccuracies in the Personal Data obtained about you in the Company’s control by emailing or writing to us at the contact information set out below. We may request certain Personal Data for the purposes of verifying the identity of the individual seeking access to his/her Personal Data records.

If you are in the European Union/European Economic Area or the United Kingdom, you may request to access, rectify or erase (under certain circumstances) your Personal Data. If you ask us to delete your Personal Data, we may not be able to do so due to technical, legal, regulatory or contractual constraints. You have the right to object to the processing of your Personal Data, restrict the processing of your Personal Data and exercise your right to data portability (under certain circumstances). Where you have given us your consent for specified uses of your Personal Data, you have the right to withdraw such consent at any time and we will apply your preferences for the future. We will respond to your questions or complaints relating to the processing of your Personal Data. If you are not satisfied with our responses, you have the right to lodge a complaint with a supervisory authority, although we would like the opportunity to resolve any concerns you may have, so do get in touch with us.

 

How We Protect and Retain Personal Data

We maintain administrative, technical and physical safeguards designed to protect the Personal Data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data.

We retain Personal Data for the period needed to fulfill the purposes for which Personal Data was collected, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to reflect changes in our Personal Data practices. For significant changes, we will notify you by posting a notice where the Notice is accessible and indicating at the top of the Notice when it was most recently updated.

How To Contact Us

For any questions about this Privacy Notice or the manner in which we or our service providers treat your Personal Data, or if you would like to exercise your choices as described above, please contact us as follows:

[email protected]

Users also may write to:
Privacy Policy
The Real Deal
450 West 31st St, 4th Floor
New York, NY 10001

Notice to California Residents

California Shine the Light Law

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at [email protected].

For all such requests, please indicate “CA Shine the Light” in the subject field of your request and include the name of “TRD” with respect to which you are requesting the information.

California Consumer Privacy Protection Act

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and uses our services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information by TRD:

Categories of Personal Information We Collect About You

The categories of personal information we may collected about you or your use of our Services are:

  • Identifiers, such as your name, email address, postal address, phone number (if provided by our affiliates or from commercially available sources);
  • Unique personal identifiers, such as wireless device ID, cookies, IP address;
  • Commercial information, such as preferences and shopping interests on aggregated basis;
  • Internet or other network or device activity, such as browsing history, browser type and language, operating system or app usage;
  • Geo-location information, such as city, state and zip code associated with your IP address;
  • Education information, such as educational level;
  • Inference information about you, such as preferences, characteristics, and behaviors;
  • Legally protected classifications, such as gender, race, marital status;
  • Profile data about you and any inferences drawn from the profile data, such as characteristics, behaviors, attitudes;
  • Information that identifies or can be reasonably associated with you.

More details on the categories of personal information we may collect are set forth in the Data We Obtain section of our Privacy Notice.

Categories of Sources From Which We Collected Personal Information

The sources from which we may have collected personal information about are:

  • Directly from you;
  • From automated means;
  • Company affiliates;
  • From other third party sources, such as advertising providers; analytics providers; marketers; public and commercial databases; consumer data resellers;

as otherwise set forth in the Data We Obtain section of our Privacy Notice.

Business or Commercial Purposes for Which We Collected or Sold the Personal Information

The business or commercial purposes, as defined under the CCPA, for which we collected or sold the personal information, are:

  • performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services;
  • auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • debugging to identify and repair errors that impair existing intended functionality;
  • undertaking internal research for technological development and demonstration;
  • undertaking activities to verify or maintain the quality of a service, and to improve, upgrade, or enhance a service; and
  • to advance the commercial or economic interests of the Company, such as by inducing another to subscribe to or provide information or services, or enabling or effecting, directly or indirectly, a commercial transaction.

More details concerning the business or commercial purposes are set forth in the The Purposes & Legal Bases for Which We Use the Data We Obtain section of our Privacy Notice. We may disclose the categories of personal information identified in Data We Obtain section of our Privacy Notice about our California consumers for our operational purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.

Categories of Third Parties With Whom We Shared the Personal Information

The categories of third parties, as defined by the CCPA, with whom we shared the personal information, are set forth in the Data We Share section of our Privacy Notice, and include:

  • Our Subsidiaries and Affiliates;
  • Third Party Partners, such as advertising clients, for marketing purposes;
  • Third Party Online Advertising Providers.

Categories of Personal Information Sold

The categories of personal information we may sell, as defined under CCPA, include:

  • All of the categories listed above with respect to our subsidiaries and affiliates and third party partners;
  • Unique personal identifiers and geo-location information with respect to third party online advertising providers.

More details on the categories of personal information we may sell are set forth in the Data We Obtain and Data We Share sections of our Privacy Notice. We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.

Categories of Personal Information Disclosed for a Business Purpose

The categories of personal information disclosed for a business purpose, as defined under the CCPA, include all of the categories of information listed above.

More details on the categories of personal information we may disclose for a business purpose are set forth in the Data We Obtain and Data We Share sections of our Privacy Notice.

California Consumer Privacy Rights and Choices

California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure. You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:

  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected or sold the personal information;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

The right to deletion. You may have the right to request that we delete the personal information we have collected from you. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

How to exercise your access and deletion rights. California residents may exercise their California privacy rights by sending an email to [email protected], indicating “CA Privacy Rights” in the subject field of your email. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your unique identifier, or name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will provide such list in a written email to the email address you provide.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
  • Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify, or aggregate, as appropriate, any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

The right to opt-out of the sale of your personal information. California residents may opt out of the “sale” of their personal information. California law broadly defines sale such that it may include your information that may be “sold” to third party advertising clients as described in the Data We Share section of our Privacy Notice. You have the right to opt out of the sale of your personal information. You may send an email to [email protected], indicating “CA Privacy Rights: Opt-Out of Sale” in the subject field of your email.

Authorized Agents. You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.


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