Privacy Policy

Effective September 2016; updated December 2019;

Weichert Workforce Mobility Inc.(“Weichert” hereinafter, we or us) respects the confidentiality and privacy of our clients, our colleagues, customers and others with whom we do business. We know privacy is important to you. It is extremely important to us. This document explains our Privacy Policy. We want you to know how we keep your personal information private and secure. We also want you to know how we use personal information to serve you better.

What Does the Privacy Policy Include 
This policy provides valuable information related to the following topics:

• Who is Covered by the Privacy Policy
• How Weichert is Protecting the Privacy of Personal Information
• The types of Personal Information Weichert Collects
• How Weichert Collects Personal Information
• How Weichert Updates Personal Information And Your Right Of Access
• How Weichert Uses Personal Information
• On-line Security
• Use of Cookies
• Links to Third Party Websites
• Use, Choice and Acceptance
• Contact Information

Who is Covered by the Privacy Policy 
This Privacy Policy applies to residents of the United States and those countries in which Weichert and its suppliers are providing employer-approved relocation services. Please note that a separate Privacy Policy applies to HR data relating to Weichert’s own EU-based employees, details of which are available from Weichert’s Data Protection Officer, Chris Shull, and on our website.

Protecting the Privacy of Personal Information

We are very serious about protecting the privacy of customer information. We maintain safeguards that comply with mandated standards for storing and securing confidential information. The safeguards utilized are an aggregation of physical, electronic, and procedural controls. These safeguards protect information against unauthorized access, alteration and destruction. For example, we have security procedures in place that limit access to information to only those people who need access to perform the employer-authorized scope of work.

We enter into agreements with suppliers to provide services to us or to make products and services available directly to you. These agreements allow them to receive information about you, but only as long as these suppliers are able to maintain applicable compliance. Additionally, these agreements state that they must safeguard this information and use it only to the extent needed to provide those services specifically authorized by your employer and for no other purposes.

Personal Information Weichert Collects
In the course of providing services to you or your employer, we obtain a variety of personal information. The most sensitive information may include:

• Social Security Numbers (national tax identification numbers)
• Annual Salary
• Wage and Tax Updates
• Mortgage Loan Information
• Other Encumbrances (i.e., Home Equity Loans, Liens, etc.)
• Monthly Mortgage Payments
• Real Estate Taxes

We do not seek to collect personal information from children under the age of 18. We believe that children under the age of 18 should obtain permission from their parents before providing any personal information to us via this website. Again, Weichert and its authorized suppliers will ONLY utilize that amount of personal information that is required to provide you with those services that have been approved by your employer. As part of its operating practices, Weichert formally obtains your consent about disclosing your personal information during an initial orientation call when we explain the services that have been approved by your employer, and the minimum amount of such information that we require in order to deliver your employer-approved relocation services to you. As stated above, in maintaining the controlled use of this information as described in this Policy, Weichert complies with applicable data protection laws.

How Weichert Collects Personal Information
Your employer will provide us with personal information about you and your dependents who are eligible to receive employer-approved relocation and/or assignment management benefits. This information is provided via a controlled access electronic authorization form. Personal information contained in this form includes: names, addresses, telephone numbers, email addresses and benefit eligibility instructions. We supplement this information by communicating directly with you and/or your dependents in an effort to customize services to meet your needs. We may also receive personal information from suppliers who assist us in providing services to you and your dependents. We offer you choices with respect to the use and disclosure of your personal information, while drawing to your attention the limitations this may place on Weichert and suppliers in terms of provision of services to you.

When you visit our website, we automatically collect additional personal and non-personal information. This information relates primarily to your computer system (i.e., internet address, search engine, browser software, etc.). We also monitor your usage of our site. This information is used to make improvements to site content, to improve services offered to you through this site, and ensure the security of the system.

How Weichert Updates Personal Information And Your Right of Access
We use reasonable efforts to verify the accuracy and timeliness of personal information used in our business. We periodically update this information based upon input provided by you, your employer and suppliers. You are entitled to verify the accuracy of the personal information we hold about you (by contacting Weichert’s Data Protection Officer, Chris Shull)  and to have the personal information corrected, amended or deleted where it is inaccurate or processed in violation of our obligations under the EU-US Privacy Shield. At any time, you can log into your private home page to access your personal information. From your home page, you can activate various links to view, add or change personal information and data. Information that you add or change will be automatically saved to our database when you prompt the system.

How Weichert Uses Personal Information 
We share your personal information with our employees, our affiliates and our network of suppliers in order to deliver the relocation services that we have been engaged to provide. Information that we share with our employees is distributed strictly on a need-to-know basis. We will provide personal information to our affiliates if you, or your employer, have selected them as the supplier-of-choice. Personal information will be shared with external suppliers who are assisting us in providing services to you. These suppliers include, for example, temporary accommodation providers and local destination services specialists, each providing essential parts of our overall relocation service to you. We require these suppliers to protect the confidentiality of your personal information and to limit their use of such information to delivery of the requested services. We also exchange personal information with your employer to enable them to monitor our performance and to update their employee records.

On occasion, we may be required to share your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Weichert and its affiliates will never sell or lease your personal information to any third party. Weichert is not a consumer reporting agency. Therefore, we will not furnish any of your personal credit information to any third party or any consumer reporting agency. In addition, we will not use your personal information to make decisions about granting, or extending, credit to you unless you provide written authorization that Weichert and its affiliates can use or disclose the information for this purpose.

Weichert also follows guidelines as to the proper storage, retention, and permitted destruction of personal information.

Your Remedies

1. If at any time during the course of your receiving service from Weichert that you have any questions concerning this Privacy Policy, or any concerns that you may have about how Weichert is performing in regard to this Privacy Policy, please contact our Data Protection Officer, Chris Shull.
2. Additionally, if your personal information is provided to us from the EU or Switzerland, you should be aware that as a result of the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks, which Weichert has committed to:

• You may bring a written complaint directly to Weichert and Weichert must respond to you within 45 days thereafter.
• You are entitled, at no cost to you, to have any concerns or complaints that have not been resolved to your satisfaction by Weichert to be reviewed by an independent professional third party administrator, the American Arbitration Association/International Centre for Dispute Resolution.
• If you are located in the EEA or Switzerland and we have not been able to satisfactorily resolve your question or complaint regarding our privacy practices, you may raise your concern to the attention of your data protection authorities (“DPAs”). The DPAs will establish a panel to investigate and resolve complaints brought under the Privacy Shield and Weichert will cooperate with this panel. Furthermore, Weichert will comply with the advice given by data protection authorities and take necessary steps to remediate any non-compliance with the Privacy Shield Principles.
• Weichert will also cooperate directly with EU or Swiss data protection authorities with regard to human resources data transferred from the EU or Switzerland which relates to Weichert’s own employees.
• You may also be entitled to invoke binding arbitration.
• Weichert will meet its liabilities, arising under the Privacy Shield, in relation to any transfers of your personal information to its suppliers or sub-contractors
• Your personal information is protected under the Privacy Shield as set out in more detail in the Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov.

3. If you are a resident of California, the California Consumer Privacy Act (CCPA) grants you several rights concerning your personal information, including the right to exercise an:
   1. Abbreviated Right to Know;
   2. Expanded Right to Know;
   3. Right to Know about Sale or Sharing for a Business Purpose [Note: we never sell your personal information];
   4. Right to Opt-Out of Sale for Adults 16 and over [Note: we never sell your personal information];
   5. Right to Opt-in to Sale for kids under the age of 16 [Note: we never collect personal information from children under the age of 16];
   6. Right to access data;
   7. Right to delete data;
   8. Right to be free from discrimination.

To exercise these rights, please either:

• login to your account to access your information,
• call us at 877-711-6622 — our menu will prompt you through your choice(s), or
• download, complete and submit the request form at

http://www.weichertworkforcemobility.com/CCPA-request.

to privacy@weichert.com.

4. You are entitled, at no cost to you, to have any concerns or complaints that have not been resolved to your satisfaction by Weichert to be reviewed by an independent professional third party administrator, the American Arbitration Association/International Centre for Dispute Resolution: http://go.adr.org/privacyshield.
5. Weichert is subject to the investigatory and enforcement powers of the Federal Trade Commission.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Weichert has appointed the Voerman Group as its GDPR representative in the EU. You can contact the Voerman Group regarding matters pertaining to the GDPR at:

Voerman Group, attn René Postma (Voerman Group Quality Manager)
Wolga 12, 2491 BJ, The Hague, The Netherlands
+31 (0) 70 301 1337
rpostma@voerman.com

On-line Security 
We strive to maintain and improve security to protect the confidentiality of your personal information. We will use commercially reasonable efforts to protect personal information in a manner consistent with applicable laws and regulations. We use a variety of security measures to protect your personal information, including data encryption, ID and password protection, user type security, and menu security. All of these measures help secure your personal information from loss, interception or theft. We also maintain a robust firewall as a safeguard to control access to, and use of, your personal information. Please note that Weichert does not encrypt open email communications. As a result, if you choose to provide us with personal information by email, we cannot guarantee that such transmission will be optimally secure. Therefore, we recommend that you transmit personal information through our website where you will be afforded individual, controlled access, or communicate personal information by telephone directly to your Relocation Counselor.

Use of Cookies 
Cookies are small pieces of data that websites send to your computer, which are stored in files on your hard drive. A cookie stores information on your hard drive to make communication with a website more effective. We use session cookies within our site. These cookies consist primarily of text that facilitate user identification, data retrieval, data sorts and graphic images. These cookies expire automatically after every session.

You can set your browser to notify you when a cookie is received so that you can decide whether to accept or reject it. Notwithstanding, you should be aware that access to our website may be obstructed or impaired if a cookie is refused.

When you download materials from our site, you authorize us to send you the material you are requesting as well as other related educational material from time-to-time. We take pride in sharing important news, trends and thought leadership publications that benefit the workforce mobility community. Please be assured we’ll never sell your contact information to another company for marketing purposes, and we’ll make it easy to withdraw your consent at any time. As a key component of our company’s compliance with GDPR, we will always give you the opportunity to “opt out” from receiving new materials from us whenever you download a product.

For more information, please see our Cookie Policy.

Links to Third Party Websites 
This website may, from time to time, supply links to other websites controlled by third parties. PLEASE NOTE that Weichert does not exercise control over such third party websites and that Weichert is not responsible, or liable, for the privacy policies, practices or security measures used (or not used) on these third party websites. Similarly, Weichert does not endorse, sponsor or approve the content on third party websites. These third party websites may have privacy policies that differ from this Weichert Privacy Policy, so you should review the privacy policy posted on any such third party website.

Use, Choice and Acceptance
Your decision to provide us with your personal information and to use our website is voluntary. Before providing you with services, we will issue you with a Notice and Consent Form and you may elect to prohibit us from using your personal information and thereby prohibit us from using or sharing any such personal information with our approved suppliers and subcontractors who assist us in providing services authorized by your employer. If you do choose to opt-out, we may be prevented from providing you (your family and/or domestic partner) with employer-approved Weichert services and we shall inform your employer of your election.

By using this website, it is understood that you have agreed to the terms of this Privacy Policy. You should not use this site if you do not agree with these terms.

We may update this Privacy Policy periodically. Changes to this Privacy Policy will be posted on-line. Your ongoing use of this site serves as your implied agreement with the revised terms.

Contact Information
Please contact your Client Service Director or Relocation Counselor if you have additional questions about this Privacy Policy. Additionally, for your convenience, you may also directly contact Weichert’s Data Protection Officer, Chris Shull.

WWM Privacy OPT OUT NOTICE REQUEST FORM