About the Home Sale Network

The Realogy Group of Companies, to which Cartus Ltd ("Cartus" or "we") belongs, respects your privacy. Accordingly, Cartus has reviewed its policies and practices to ensure that they meet legislation introduced within the European Economic Area (EEA), which includes the European Union (EU), in line with the EU Data Protection Directive (95/46/EC) and the EU Telecommunications Data Protection Directive (97/66EC) ("the Directives") and will continue to ensure that its policies and practices comply in all respects with any future laws and regulations in relation to your privacy.

The purpose of this document is to inform you of the policies that have been put in place to protect your interests in this respect.

1. Fair and lawful information-handling
We will process all the data we collect and hold on you fairly and in accordance with applicable law. As further explained in this policy statement, we will ensure the quality and security of your data (even if the data are transferred to other companies in Europe or elsewhere); and we will fully respect your rights, interests and fundamental freedoms with regard to your data.

2. Legitimate purposes
We will only collect, record, process and store data which are needed to fulfil our contractual obligations towards our customers, our partners, and the customers of our partners; to serve other legitimate business interests such as credit assessment or marketing; or to comply with legal requirements. We may disclose to any other company or companies within the Realogy Group of Companies, and to third parties authorised by us, such information as may be necessary to provide you with products and services you have requested or for the purpose of verification of details relating to your data held by us for legitimate purposes.

3. Data quality
We will employ effective procedures and safeguards to ensure that the data we hold on you are adequate, relevant and not excessive in relation to the purposes for which they were obtained, as well as accurate and up-to-date. Where we become aware of any inaccuracies in the data we hold, we will correct and, where appropriate, delete incorrect data. Retention periods are in place to ensure that data are only stored whilst they are required for the purposes in question or to meet legal and regulatory requirements. Where data are no longer required, we will ensure that they are disposed off in a secure manner.

4. Information to you
When we collect data from you, we will identify ourselves and inform you of the purpose(s) for which we collect the data. If we are collecting data from you on behalf of one of our sister companies or partners, we will identify that sister company or partner (the "controller" in terms of the European data protection regime) and explain that we are acting as the agent (or "processor") for that other company. If our partner is a non-European company which has appointed a representative in Europe in accordance with the Directives, we will also inform you of the identity of that representative (which may be Cartus). If we have obtained data on you other than directly from you, we will inform you of this as soon as practicable after we have entered the data in our files or computers (unless you were already aware of the fact). We may also record or monitor telephone calls to and from any of the Realogy Group of Companies (including Cartus), without notification, for staff training and quality control purposes.

5. Special restrictions on the use of sensitive data
We will not normally seek data on your racial or ethnic origins, political opinions, religious or other beliefs, trade-union membership, physical or mental health, sex life or criminal convictions. When we do collect such data, it will be limited to data which are:

required to be kept by law

needed for legal proceedings or to establish, exercise or defend legal rights (including protection against fraud)

clearly and strictly necessary to fulfil a contract between you and us (or between you and a company we represent)

needed to protect your vital interests or the vital interests of another person (for instance, if medical data are urgently required after an accident and you cannot give your consent).

6. Your rights
You have the right to require us or our partners to cease the communication of advertising or marketing material to you, and we will ensure that your request is complied with. This includes the right to withdraw your consent to third-party direct-marketing use of your data, at any time. You have the right to see all the data we hold on you. Should you wish to have access to all or a particular part of your data, please contact the Data Protection Co-ordinator at Cartus Ltd, Frankland Road, Blagrove, Swindon, Wiltshire SN5 8RS, United Kingdom. Such access will be granted in accordance with the requirements of national legislation and subject to any discretionary allowance for Cartus to make a charge payable by you to cover Cartus' administration costs incurred in providing you with such data. Such payment is to be made on application for access to your data and is to be no more than the maximum stipulated by national legislation (if applicable) The information will be forwarded to you within an appropriate period of time in accordance with national legislation, but in any event no more than 40 days from the date of such request for access. Where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records. We will confirm the actions taken in writing to you within an appropriate period of time in accordance with national legislation, but in any event no more than 40 days after receiving your request to amend our records.

7. Security of information
We will only provide access to data on you to those of our employees who need such access in order to carry out any necessary processing. We have taken appropriate steps to ensure the security of data, whether it is stored in computer systems, paper files or other storage media. We expect the same high standards of security and confidentiality of any agents or sub-contractors we employ to process data for us.

8. Transfer of information outside the EEA
Data on you may, on occasion, be transferred to Realogy Group facilities, or to any other company or companies within the Realogy Group of Companies, data processing agencies ("processors") or third parties, outside the EU or the EEA for analysis, technical processing or other legitimate purposes. The countries where such other facilities or companies are situated may have no data protection legislation, or laws which are less rigorous than the legislation introduced by the Member States of the EU and the EEA. In such cases, we will ensure that your rights with regards to any such processing and your data will still be adequately protected. Within the Realogy Group of Companies we have agreed world-wide acceptance of the European standards with regard to the processing of personal data from all our European companies, including Cartus. If we transfer your data to agencies or third parties outside the EEA, we require similar, binding contractual undertakings, and we monitor compliance. Our partners have agreed to adopt equivalent measures.

9. Direct marketing
We, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, may market to you directly through any media to keep you informed of further offers from us, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, which may be of interest to you (unless you write to us asking us to exclude you from such offers or alternatively telephone, fax or e-mail us to that effect or you have done so previously and such exclusion is still operative) and for our own administration, market analyses and operational reviews. (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.) We, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, may make contact with you by post, e-mail, telephone (including automated dialling equipment), facsimile transmissions, and/or pre-recorded messages for the purposes set out herein (unless you notify us either in writing or by telephone, fax or e-mail that you object to being contacted in a particular stated way and/or by a certain stated company or companies within the Realogy Group of Companies or by third parties authorised by us). (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.) We, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, will always act according to your wishes and preferences. Whenever we, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, directly market to you by telephone or fax, we, or any other company or companies within the Realogy Group of Companies or third parties authorised by us, will comply beforehand with the requirements of national legislation under and by which you have recorded your desire not to be contacted by telephone and/or fax, as the case may be, for the purposes of direct marketing by any organisation. If you have notified such desire according to the laws of your country of domicile, then we will not call or fax you unless you subsequently notify us directly (either in writing, or by telephone, fax or e-mail) that this no longer applies or at least does not apply to any other company or companies within the Realogy Group of Companies or to third parties authorised by us. (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.)

11. Internet
At Cartus, we are committed to protecting your privacy in the following ways:

When you use this Web site, we may monitor customer traffic patterns and site usage to help us develop its design and layout.

When you use this Web site, we may also use the data we collect to occasionally notify you about important functionality changes to it, and to notify you of new products or services, and special offers we think you'll find valuable and of interest.

When you use this Web site, we may provide aggregate statistics about customers of Cartus entering into transactions on-line, sales, traffic patterns and related Web-site information to reputable third parties, but these statistics will include no personally identifying data.

Cartus is the sole controller in the EEA/EU Member States of all data held in relation to use of this Web site for information and transactional purposes on-line and all processing of data relating to your requirements and requests is therefore (in accordance with EC Directives 95/46/EC and 97/66/EC) subject to the data protection laws and regulations of your country of domicile. If no such laws and regulations exist in your country of domicile, then all processing of data relating to your requirements and requests is subject to United Kingdom data protection laws and regulations only.

We will maintain records relating to your use of this Web site for information and transactional purposes on-line (including information about you provided by yourself or by third parties). We shall be entitled to process those data for the purpose of providing your requirements and requests and to keep you informed of further offers from us which may be of interest (unless you write to us asking us to exclude you from such offers or alternatively telephone, fax or e-mail us to that effect). (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.) We shall be entitled to disclose to any other company or companies within the Realogy Group of Companies, or to third parties authorised by us, such information as may be necessary to provide your requirements and requests or for the purpose of verification of details relating to any requests for information or transactions on-line you may make with Cartus.

We will not send you e-mails that you do not want, but we cannot guarantee that third parties to whom your details are sent will not do so.

You are entitled to receive a copy of any data held by us on you in accordance with the requirements of national legislation and subject to any discretionary allowance for Cartus to make a charge payable by you to cover Cartus' administration costs incurred in providing you with such data. Such payment is to be made on application for access to your data and is to be no more than the maximum stipulated by national legislation (if applicable). The information will be forwarded to you within an appropriate period of time in accordance with national legislation, but in any event no more than 40 days from the date of such request for access.

Where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records. We will confirm the actions taken in writing to you within an appropriate period of time in accordance with national legislation, but in any event no more than 40 days after receiving your request to amend our records.

We will always seek your consent before disclosing data relating to you for the making of offers by third parties by informing you of an intention to process your data for such purposes, and offering you a possibility to opt out of such use of your data, in a form or document returned to us or by notifying us by telephone, fax or e-mail. (If you use more than one e-mail address to communicate with us, complete this form for each e-mail account you use.)

This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States . Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If at any time you feel that Cartus has not adhered to these principles, please either notify us in writing or by telephone, fax or e-mail and we will use all commercially reasonable efforts to determine and correct the problem promptly. Cartus welcomes your questions and comments about privacy.