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Privacy Policy
Updated and Effective Date:
November 29, 2024
Updated and Effective Date: November 2024
This Online Privacy Policy (this "Policy") sets forth how SitusAMC Holdings Corporation and its subsidiaries ("SitusAMC", "we", “us”, or “our”) gathers and uses information when you: access or use our SitusAMC or subsidiary websites, mobile applications, and other online products and services, including but not limited to: https://www.situsamc.com; https://cjcweb.com; and https://Securentrisk.com; visit our physical locations; contact our customer service team; engage with us on social media; or otherwise interact with us (collectively, our "Services").
This Policy does not apply to any third-party website to which the Services may link.
Please read this Policy carefully and consult our Terms and Conditions for more information about the general terms and conditions regarding your use of the Services.
In some circumstances, we may provide you with additional or supplemental privacy notices to the extent they apply to you because of the products and services you obtain from us or different laws that may apply to you. If you are a California resident, please refer to Section 13 (Your California Privacy Rights) below. If you are a European Resident, please refer to Sections 11 and 12 below.
To learn about the SitusAMC Complaint Policy, please click here.
1. THE TYPES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU
We collect the following categories of personal information from you in different ways, including from you directly, from you automatically through your use of the Services, and from third parties. The personal information we collect is used and shared as described below.
Personal Identifiers:
We collect certain personal information including your name, company name, postal address, e-mail address, telephone number, fax number, content stored on your device, such as photos and videos, and investor status when you access certain features of the Services or request certain information regarding SitusAMC directly from the company via the Services.
We may collect this information from various sources, including from you directly, from your device, through your use of the Services, recruiting agencies, financial institutions, service providers and other individuals.
Characteristics of Protected Classifications:
If you choose to provide it, we may collect personal and protected classification characteristics and similar information, including ethnicity and citizenship. You can choose not to provide this information, but then you might not be able to gain access to such information and services.
Commercial Information:
We may collect commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties, including data brokers.
Internet or other electronic network activity information:
We may also collect information about you through technology. For example, when you visit the Services, we may collect your IP address (an IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet Service Provider), or your company) or other information you choose to explicitly share or submit to us. At times, we use IP addresses to collect information regarding the geolocation and frequency with which visitors browse various parts of our Services and combine this information with other information about you.
The Services also use Cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about the processing of information we obtain by automated means and how to change your Cookie settings, please visit our Cookie Policy. To the extent required by applicable law, we will obtain your consent before using Cookies or similar tools.
Our Services also use other technical methods to track visitor usage, including web beacons ("web beacons" are small pieces of data that are embedded in images on the pages of a website). We use these technical methods to analyze the traffic patterns on our Services, such as the frequency with which our users visit various parts of our Services. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we may send visitors to our Services to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails. Information we collect using these technologies is never combined with the information you provide (e.g., name, email, etc.).
We collect this information through your use of the Services and from our service providers.
Professional or Employment Information:
When you register for Services, we may collect professional and employment information such as information about your employers, awards, and associations.
We may collect this information from various sources, including from you directly, through your use of the Services, educational institutions, financial institutions, service providers and other individuals.
Audio, electronic, visual, thermal, olfactory, or similar information:
When you visit some of our physical locations, our CCTV cameras may capture your image. If you call SitusAMC, your calls may be recorded.
We may collect this information from various sources from you directly.
Educational Information:
When you register for our Services, we may collect educational information such as information about schools you attended, degrees awarded, and academic status.
We may collect this information from various sources, including from you directly, through your use of the Services, financial institutions, service providers, and other individuals.
2. HOW WE USE PERSONAL INFORMATION WE COLLECT ABOUT YOU
For each category of personal information above, we use your personal information as permitted by applicable laws to carry out the following purposes:
Provide you with Services:
We use your personal information to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us.
Improve the Services:
We use your personal information about you to improve our Services. We might use your personal information to deliver the Services and/or customize your experience with us. For example, we may use your personal information to improve the Services and our other internal business purposes.
Security and Fraud Prevention and Detection:
We use your personal information for security purposes. We may use personal information to enforce our rights, for fraud prevention and detection, or to protect our company, affiliates, our customers, or our Services, or a third-party website or platform.
Compliance with Laws and to Protect Ourselves:
We use your personal information to support auditing, legal and compliance purposes, including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Marketing:
We use your personal information to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about. We use your personal information to make suggestions and recommendations to you and other users of our Services about products or services that may interest you or them. We use your personal information to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. We use your personal information to provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you, where you have consented to being contacted for such purpose.
Communications:
We use your personal information to communicate with you about your account or our relationship. We may contact you about your use of our Services. We may contact you about your account, feedback, or changes to our service. We might also contact you about this Privacy Policy or the Services’ Terms of Use.
Debug and Identify Errors:
We use your personal information to debug and identify and repair errors that impair existing intended functionality on our Services.
Statistical Analysis and Research:
We may use your personal information for statistical analysis and research purposes, including analyzing performance.
Aggregate and de-identified information:
We may de-identify personal information and create anonymous and aggregated data sets and reports to assess, improve, market, and develop our business, products, and services, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. This information is not generally subject to the restrictions or rights in this Policy, provided it does not identify – and could not be used to identify – a particular individual.
We either maintain aggregated or de-identified information without attempting to re-identify it or treat such information as personal information subject to applicable privacy laws.
Other purposes:
We may also use your personal information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law. We may combine information we obtain about you (such as offline through our services or from third parties) for the purposes described above.
3. WAYS WE SHARE PERSONAL INFORMATION WE COLLECT ABOUT YOU
We do not disclose personal information we collect about you, except as described in this Privacy Policy. For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes. As more fully described below, we may share your personal information to fulfil the purpose for which you provide it, for a purpose disclosed by us when you provide the information, or with your consent.
SitusAMC Companies and Affiliates:
We may share your personal information within the SitusAMC family of companies and with our affiliates.
Contractors, Service Providers:
We share personal information with contractors and service providers who perform services on our behalf based on our instructions. We do not authorize these contractors or service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples include companies we hire to help deliver products or services, like a shipping company that delivers a package, and companies who help us either gather your information or communicate with you.
Comply with the Law:
We also may disclose personal information (a) if required by law, including, for example, to comply with a court order, subpoena, or other legal process, including a response to a government or regulatory request (b) to enforce our Terms of Use; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Services, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
Information You Elect to Share:
We may share your information with third parties when you engage in certain activities on our Services that are sponsored by third parties, such as electing to receive information or communications from a third party. When you participate in such activities, you will either be required or requested to agree that the sponsor or business associate may use your personal information (including, in some cases, your e-mail address) in accordance with the sponsor or business associate’s privacy practices. If you provide a product review or otherwise share content on our Services, we may share this information publicly/with other users of our Services. If you choose to use integrations we offer on our Services, including for reporting purposes, locking rates, and returning diligence results, we may share certain information with the integration partners.
Business Transfers:
In some cases, we may choose to buy, sell, or merge parts of our business or our assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. We reserve the right to transfer personal information we have about you, as necessary, in the event that we sell or transfer all or part of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation). You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this Privacy Policy.
Aggregate and de-identified information:
We may share aggregate or de-identified information, which cannot reasonably be used to identify you.
4. THE SECURITY MEASURES WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION
The security and confidentiality of your personal information is important to us. We maintain reasonable technical, administrative, organizational and physical security measures to protect personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or misuse. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite these efforts, no security measures are perfect or impenetrable.
Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
5. HOW LONG WE RETAIN PERSONAL INFORMATION
To the extent permitted by applicable law, we retain your personal information for the duration of our relationship (but no longer than reasonably necessary to fulfil the purposes for which we collected such information), plus a reasonable period in order to be able to run regular deletion routines or to consider the applicable statute of limitation period or to comply with mandatory applicable law. If you have created an account with us, we will delete your account information once your account becomes inactive (i.e., when there has been no user log-in to the account in over 1 year).
We may retain your personal information for a longer period due to legal or regulatory requirements, including in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
6. YOUR RIGHTS AND CHOICES
We will provide you an opportunity to update your contact information and/or modify your communication choices by sending you an e-mail or other communication that invites your response, or by providing a means to update that information via our Services. You also may opt out of receiving text messages or e-mail marketing communications by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
To the extent provided by the law of your jurisdiction, you may at any time request, in writing, access to the personal information we maintain about you, request how we collect, use and process your personal information, or request that we correct, update, amend, or delete/erase your information, or restrict the processing of such information by contacting us as indicated below, or object to the processing of your personal information in certain circumstances. Subject to applicable law, you also have the right to receive, in a structured, commonly used, and machine-readable format, the personal information that you have provided to us about you, with your consent or based on a contract to which you are party. You have the right to have this information transmitted to another company, where it is technically feasible.
You may make these requests by calling our toll-free number 1-855-824-9297 or by contacting us at Privacy@situsamc.com. You may also designate an authorized agent to make a request on your behalf by contacting us as described below. In order to protect your data from unauthorized access or alteration by third parties, all requests regarding your personal information will be subject to verification of the identity of the requesting individual. We endeavor to respond to a verifiable request within forty‑five (45) days of its receipt. If we require more time (up to forty‑five (45) days), we will inform you in writing.
Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.
To ask us to remove your information from our mailing lists, exercise your rights or submit a request, please contact us as indicated in the " Contact Us" section of this Privacy Policy.
Authorized Agent: An authorized agent can be a natural person or a business entity. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain personal information, depending on the nature of the information you require, which we will endeavor to match with information we may maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will also be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity. Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
7. CHILDREN
Our products and services are not directed to minors under the age of 18 and we do not knowingly collect or sell the Personal Information of minors. Your use of our Services constitutes a representation that you are 18 years of age or older.
If we become aware that we have inadvertently collected personal information from a child under the age of 18, we will delete such information from our records. If a parent, guardian, or anyone else becomes aware that we have collected personal information from an individual under the age of 18, please contact us.
8. DATA TRANSFERS
SitusAMC is headquartered in the United States of America. We may share personal information we obtain about you with our affiliates and suppliers in the United States in accordance with this Policy.
If SitusAMC is going to transfer personal data to a third party that is acting as an agent or processor on its behalf, it will enter into a written agreement with such third party requiring that the third-party provide at least the same level of privacy and data security protection as is required by the data protection laws applicable to the transferring SitusAMC legal entity. SitusAMC shall remain liable under the Data Privacy Framework (DPF) Principles if such third-party processes such personal data in a manner inconsistent with the DPF Principles. Further, under other certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of your personal information that we transfer to them.
9. INTERNATIONAL DATA TRANSFERS
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).
We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy notice.
SitusAMC recognizes its obligation to comply with the requirements of European Union’s General Data Protection Regulation (“GDPR”) and the United Kingdom’s GDPR (“UK GDPR”), and, accordingly, any transfer of personal data outside the European Economic Area (“EEA”) or the United Kingdom will only be performed in accordance with these requirements, through data transfer agreements or any other mechanism recognized as adequate by the Data Protection Authorities (“DPAs”), including by executing Standard Contractual Clauses and participating in the EU-U.S. Data Privacy Framework Program, as set forth by the U.S. Department of Commerce (“EU-U.S. DPF”), and the UK Extension to the EU-U.S. DPF, and only to the extent necessary to the performance of its contractual obligations as an employer or service provider. Where such transfers are accomplished by use of Standard Contractual Clauses, you may request a copy of these Standard Contractual Clauses by contacting us at Privacy@situsamc.com, or by writing to us at: SitusAMC, Tower 49, 12 East 49th Street, 34th Floor, New York, NY 10017, USA, Attn: General Counsel.
The Data Privacy Framework: SitusAMC complies with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. SitusAMC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
The full list of SitusAMC U.S. entities adhering to the DPF Principles can be found below , and is also available in our self-certification: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000PK7wAAG&status=Active.
- Meridian Asset Services, LLC
- Situs Asset Management LLC
- Situs Group Holdings Corporation
- Situs Consulting Solutions LLC
- Situs Holdings, LLC
- SitusAMC Real Estate Valuation Services, LLC
- SitusAMC Transaction Advisory, LLC
- SitusAMC Risk Advisors, LLC
- SitusAMC Valuation Advisory and Risk Solutions LLC
- Situs Group LLC
- Street Resource Group, Inc.
- The Collingwood Group, LLC
- Situs Real LLC
- Situs Technologies, LLC
- SitusAMC Holdings Corporation
- SitusAMC Insight, LLC
- SitusAMC Platforms, LLC
- SPT Commercial Mortgage LLC
- SitusAMC Title Production Solutions, LLC
- SitusAMC Warehouse & Custodial Solutions LLC
- SitusAMC Warehouse Lending, LLC
- STS Structured Products LLC
- TechEssential, LLC
- LogicEase Solutions, Inc.
- Hanover Street Capital, LLC
- DynAMC Solutions, LLC
- Certainty Title, LLC
- Assimilate Solutions, LLC
- American Mortgage Consultants, Inc.
- AMC Holdings, Inc
- AMC Group Acquisition Corp.
- AMC Diligence, LLC
- Alan King and Company, Inc.
If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
10. OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES
We may provide links on our Services to third parties. In addition, third parties may also provide links to our Services. These companies have their own privacy notices or policies, which you are encouraged to review. We do not control such third-party websites and are not responsible for the privacy practices of any non-SitusAMC websites, apps or services (whether or not such site is linked on or to our Services). These links are provided to you for convenience purposes only, and you access them at your own risk.
11. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the EEA or the United Kingdom, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When we process your personal data, we will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
Data Subject Requests
If you are based in the EU or UK, under certain circumstances, you have certain rights with respect to the processing of your personal data.
Access to personal data and portability
You may have the right to request access to any personal data we hold about you as well as related information, including the purposes for processing, the recipients or categories of recipients with whom data has been shared, where possible, the period for which it will be stored, its source and the existence of any automated decision making.
Data portability is the ability to obtain some of your personal data in a format you can move from one service provider to another. You may be entitled to request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Data Deletion
Personal data is retained for as long as is necessary for the purpose for which such data is processed. You may have the right to request that your personal information is deleted.
Rectification of Inaccurate or Incomplete Information
You have the right to change, alter, modify, or delete your information, and the right to ask us to correct inaccurate or incomplete personal data.
Consent, Withdrawing Consent and Restriction of Collecting Personal Data
You may withdraw your consent at any time by specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal or where SitusAMC is relying on another lawful basis to process your personal data.
Individuals in the EEA and UK may submit queries related to the processing of their personal information by SitusAMC by contacting us directly at Privacy@situsamc.com, or by writing to us at: SitusAMC, Tower 49, 12 East 49th Street, 34th Floor, New York, NY 10017, USA, Attn: General Counsel.
12. RESOLUTION OF DISPUTES AND COMPLAINT MECHANISM
SitusAMC commits to resolve complaints about our collection or use of your personal information in accordance with data protection laws applicable to us for the applicable collection or use.
With respect to SitusAMC’s handling of Human Resource (“HR”) data, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, SitusAMC commits to cooperate and comply respectively with the advice of the panel established by the EU DPAs and the UK Information Commissioner’s Office (“ICO”) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.
With respect to SitusAMC’s handling of personal non-HR data, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, SitusAMC commits to cooperate and comply respectively with the advice of the panel established by the EU DPAs and the UK ICO with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship
EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact us directly at Privacy@situsamc.com, or by writing to us at: SitusAMC, Tower 49, 12 East 49th Street, 34th Floor, New York, NY 10017, USA, Attn: General Counsel.
While you may make a direct complaint at any time to the applicable DPA about our collection or use of your personal information, we would appreciate the chance to deal with any of your queries, concerns or complaints in the first instance.
If we have not been able to successfully resolve your query or complaint, you may raise your query or complaint directly with the applicable supervisory authority. Contact details for DPAs can be found using the links below:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
If your inquiry still has not been satisfactorily resolved, you may have other recourse mechanisms to address your concerns, such as invoking binding arbitration for complaints regarding EU-U.S. DPF compliance and the UK Extension to the EU-U.S. DPF not resolved by any of the other DPF mechanisms (See Annex I for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2).
SitusAMC is subject to the investigatory and enforcement powers of the Federal Trade Commission, the Department of Commerce.
13. YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”) (collectively, the “CCPA”), affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you. If any provision below conflicts with a legal requirement, then we will comply with the applicable law.
The rights for California residents set forth in this section do not extend to (i) personal information that is already protected under the Gramm-Leach-Bliley Act (“GLBA”) as set forth in our GLBA privacy notice (ii) personal information processed solely in the business-to-business context, or (iii) other data that is exempt from certain requirements of the CCPA.
California Consumer Privacy Act
You may have rights under the CCPA, as described in this section of our Privacy Policy.
We may receive, use, and disclose Personal Information for business purposes consistent with applicable laws. Where we disclose Personal Information to third parties, we do so for the business purposes described below and we require that such third parties maintain the confidentiality of this Personal Information and appropriate systems and processes to ensure its security and protection.
We may collect and share the following categories of personal information: personal identifiers; characteristics of protected classifications; commercial information; professional or employment information; and educational information.
Category and Examples of Personal Information | How we use it | Categories of Recipients |
|---|---|---|
Category: Identifiers
Examples: Real name, alias, home and work address, personal and work phone numbers and usage records, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers, names of beneficiaries, dependent and emergency contact information, bank account details and wage garnishment records, travel-related records
| We will use this information to open and maintain your employee records, communicate with you for internal business purposes or emergencies, process pay roll, benefits and travel and business expenses reimbursement, maintain an internal employee directory, grant you access to internal systems and for other matters related to your engagement with us. This information is also used in our loan management system as well as for purposes related to apps, websites and third-party integrations on or using our products. | Loan Management System Provider, Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, Apps, Websites, and Third -Party Integrations on or using our Products. |
Category: Professional or employment-related information.
Examples: Job-related information and qualifications, such as position applied for, work experience, education, awards, qualifications, certificates, licenses, financial relationships, opinions and comments of any previous employers, compensation and salary information, credit check records, eligibility for and participation in benefit schemes and award programs, minor work permit information (including school information), and any other information you choose to provide in your resumes and/or applications as well as work anniversary information and skills and experience over the employment period, performance and development records, including training undertaken, disciplinary and conduct records, attendance and leave records. | We will use this information to determine your suitability for certain roles, assess your personal and professional development, your suitability for promotions, benefits and other awards, job moves and staff restructuring, to determine any actual or potential conflict of interest, and to fulfill our obligations to regulators (including demonstrating the suitability of employees for their role). Additional Sources of Personal Information: Third-party references, credit agencies, or entities verifying work authorization. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, and Government Entities. |
Category: Characteristics of protected classifications under California or U.S. federal law.
Examples: National identification information, such as your country of birth or the country where you are a registered national or citizen, and any visa or other right to work. | We will use this information to determine your eligibility to work and fulfill our obligations to relevant government authorities. Additional Sources of Personal Information: Third-party entities verifying work authorization. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, and Government Entities. |
Category: (1) Characteristics of protected classifications under California or U.S. federal law; (2) Professional or employment-related information.
Examples: Age and benefits information, including your date of birth, marital status, national insurance numbers, information about your pension and other welfare or benefits, and information regarding your use of statutorily-protected or company-protected leaves, such as bereavement leave, domestic violence survivor leave, crime victim leave, and military service leave. | We will use this to maintain employment records and assess your eligibility for and/or pay you any statutory or other benefits to which you may be entitled. Additional Sources of Personal Information: Third-party entities providing information to verify the information you provided, where necessary. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, and Government Entities. |
Category: (1) Professional or employment-related information and (2) Sensitive personal information.
Examples: Professional memberships, including information about your membership in professional bodies and consultation bodies. | We will use this to assess your personal and professional development and perform our legal obligations in relation to your membership. Additional Sources of Personal Information: Third-party entities that verify such membership. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, and Operating Systems and Platforms. |
Category: (1) Professional or employment-related information; (2) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99); and (3) Sensitive personal information.
Examples: Results of background checks and screening, such as education verification and criminal records and driver’s license checks.
| We will use this to determine your suitability for certain job roles (to the extent permitted or required by law) and determine your eligibility for certain benefits. Additional Sources of Personal Information: Third-party entities that conduct and report on background checks and screening. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, and Government Entities. |
Category: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. Examples: Information we obtain from monitoring, such as records of your use of our computer systems or the Internet, and recordings from surveillance cameras on our business premises. | We will use this to monitor your compliance with our internal policies and procedures, to investigate security breaches and misuse of computer equipment and systems, to protect the safety of employees and third parties, and to protect our property from theft, vandalism, and damage. Additional Sources of Personal Information: Information we may collect from your device or from surveillance cameras. | Cloud Storage Provider, Internet Service Provider, Data Analytics Providers, Operating Systems and Platforms, and Government Entities.
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Category: (1) Sensitive personal information; (2) Geolocation information; (3) Biometric information; and (4) Characteristics of protected classifications under California or U.S. federal law. Examples: Sensitive Personal Information, insofar as necessary and legally permitted, such as: (1) Social Security, driver’s license, state identification, or passport number, (2) account login, financial account, debit card or credit card number, in combination with any required security or access code, password, or credentials allowing access to an account, (3) precise geolocation, (4) racial or ethnic origin, religious or philosophical beliefs, or union membership, (5) the contents of your mail, email or text messages, unless We are the intended recipient of the communication, (6) biometric information for the purpose of uniquely identifying you, (7) information regarding your health, such as information relating to health and safety in the workplace, accidents and near misses, and vaccination records and vaccination status information, (8) information regarding your sexual orientation (collectively, “Sensitive Information”).
| Health and disability records: We will use this Sensitive Information to address our legal obligations to you in relation to health and safety in the workplace, for any required reporting purposes (e.g., our workers’ compensation carrier), and to address our legal obligations to you, make any accommodations required to assist you in the performance of your role and determine whether you are fit to undertake tasks required by your job role.
Equal opportunities monitoring information: We will use Sensitive Information, such as your ethnicity, religion, gender and sexual orientation, which you would provide only on a voluntary basis, to conduct equal opportunity and diversity monitoring where permitted or required by law.
Biometric information: We will use Sensitive Information, such as facial recognition, fingerprint or hand punch/hand-geometry data collected by a biometric time clock to monitor and record your hours of work unless otherwise prohibited by law.
As required: We will also use Sensitive Information to ensure compliance with legal and regulatory requirements, and for any other purposes required by law or government authorities.
Additional Sources of Personal Information: Third-party references, credit agencies, or entities verifying work authorization. Information that may be collected from monitoring your device. | Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, Workers’ Compensation Provider, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, and Government Entities.
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Category: Any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code. Examples: Any other information that you store on our equipment and computer systems, such as electronic communications or documents that you create or upload to our systems.
| We will use this information to monitor compliance with our internal rules and policies, investigate security breaches and misuse of computer equipment and systems, and in connection with our back-up and disaster recovery plans. Additional Sources of Personal Information: Information we may collect from monitoring your device.
| Payroll Provider, Benefits Portal Provider, Recruitment Platform Provider, Government Entities, HR Management System Provider, Cloud Storage Provider, Internet Service Providers, Operating Systems and Platforms, Apps, Websites, and Third -Party Integrations on or using our Products. |
Category/Examples: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
| We will use this information in our loan management system to provide services.
| Loan Management System Provider, Cloud Storage Provider, Internet Service Providers, and Operating Systems and Platforms.
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Additional Purposes for Using Personal Information
To comply with applicable legal and regulatory requests and obligations (including investigations).
To establish or defend legal claims and allegations.
For security or the prevention, detection, or investigation of fraud, suspected or actual illegal activity, violations of company policy or rules, or other misconduct.
To seek advice from lawyers, auditors, and other professional advisers.
Sensitive Personal Information
Your Sensitive Information will not be used for any additional purposes that are incompatible with the purposes listed above unless we provide you with notice of those additional purposes.
No Sale of Personal Information
We do not sell your personal information or your sensitive personal information, nor do we share it with third parties for cross-context behavioural advertising.
Your Rights to Request Disclosure of Information We Collect and Share About You
We comply with applicable laws and regulations that permit certain requests related to your personal data, including, but not limited to, the CCPA. We are committed to ensuring that you know what information we have collected and shared about you over the 12-month period preceding the request. You can submit a request to us for the following information:
- The categories of Personal Information that we have collected about you.
- The categories of sources where we collected the Personal Information.
- The business or commercial purposes for why we collected and/or sold the Personal Information.
- The third parties with whom we shared the information.
- The specific pieces of information we collected.
- The categories of Personal Information, if any, we have sold about you, categories of third parties to whom we sold that Personal Information, and the category or categories of Personal Information sold to each category of third party.
- The categories of Personal Information that we’ve shared with third parties for business or commercial purposes.
- To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing.
- To request deletion of personal information we have collected from you.
You have the right to obtain personal information about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity without hindrance.
You may also have the right to submit a request to us to do the following:
Upon receiving and verifying such request as described below, we will delete the Personal Information that we have collected about you, except for situations when that information is necessary for SitusAMC to: provide you with a good or service that you have requested; perform a contract we have entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with expectations based on the your relationship with us.
Our Process for Responding to Consumer Rights Requests for Access or Deletion
We will verify your consumer rights request by asking you to provide information related to your recent interactions with us, as described below.
Requests for Household Information
Please note that certain types of Personal Information may be associated with a household, meaning a group of people living together in a single home. Each member of the household must make requests for access or deletion of household Personal Information. We will then verify each member of the household using verification criteria. If we are unable to verify the identity of each household member to the degree of required certainty, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf.
Requests for specific pieces of personal information
To respond to these requests, we will ask you for at least three pieces of personal information and will endeavor to match those to information we maintain about you. Additionally, we require that you provide a declaration attesting to your identity, signed under penalty of perjury.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. In addition, we will treat the request as one seeking disclosure of the categories of personal information we have collected about you and endeavor to verify your identity using the less-stringent standards applicable to such requests.
Requests for categories of personal information
To respond to these requests, we will ask you for at least two pieces of personal information and endeavor to match those to information we may maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
Requests for deletion of personal information
To respond to these requests, we will ask you for at least two pieces of personal information and endeavor to match those to information we may maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.
Non-Discrimination
You have a right not to be discriminated against for the exercise of the privacy rights conferred by the applicable data protection legislation.
Do Not Track Signals
Our Services currently do not respond to "Do Not Track" (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how in this Privacy Policy.
15. AMENDMENTS TO THIS ONLINE PRIVACY POLICY
This Privacy Policy may be updated periodically to reflect changes in our personal information processing practices. We will indicate at the top of the Policy when it was most recently updated.
16. LIST OF SITUSAMC SUBSIDIARIES ADHERING TO THIS PRIVACY POLICY AND WITH WHICH YOUR PERSONAL INFORMATION MAY BE SHARED
- Alan King and Company, Inc.
- AMC Diligence, LLC
- AMC Group Acquisition Corp.
- AMC Holdings, Inc.
- American Mortgage Consultants, Inc.
- Assimilate Solutions, LLC
- Assimilate Solutions India Private Limited
- Certainty Title, LLC
- DynAMC Solutions, LLC
- DynAMC Solutions, Inc
- Hanover Street Capital, LLC
- Hatfield Philips Agency Services Ltd
- LogicEase Solutions, Inc.
- MBMS Holding, LLC
- Meridian Asset Services, LLC
- SitusAMC Valuation Advisory and Risk Solutions LLC
- SitusAMC Risk Advisors, LLC
- SitusAMC Transaction Advisory, LLC
- ReadyPrice LLC
- SitusAMC Real Estate Valuation Services, LLC
- RERC Europe Ltd
- rSquared CRE, LLC
- Situs Asset Management LLC
- Situs Asset Management Ltd
- Situs Asset Management (Ireland) DAC
- Situs Consulting Solutions LLC
- Situs Deutschland GmbH
- Situs Europe Holdco Ltd
- Situs Group Holdings Corporation
- Situs Group LLC
- Situs Holdings, LLC
- Situs Intermediate Holdco Ltd
- Situs International Ltd
- Situs Real LLC
- Situs Realty Services Ltd
- Situs Technologies, LLC
- SitusAMC Holdings Corporation
- SitusAMC Insight, LLC
- SitusAMC Platforms, LLC
- SPT Commercial Mortgage LLC
- Street Resource Group, Inc.
- SitusAMC India Private Limited
- SitusAMC Title Production Solutions, LLC
- SitusAMC Warehouse & Custodial Solutions LLC
- SitusAMC Warehouse Lending, LLC
- STS Structured Products LLC
- TechEssential, LLC
- The Collingwood Group, LLC
17. CONTACT US
To ask us to remove your information from our mailing lists, exercise your rights or submit a request, or have any questions or comments about this Privacy Policy, please email us at Privacy@situsamc.com or call toll-free at: 1-855-824-9297.