Privacy Policy

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Privacy Policy
Terms of SFRhub Privacy Statement
SFRhub Marketplace, LLC, dba SVN | SFRhub Marketplace, its affiliates, partners, subsidiaries and related
websites and entities (collectively, "SFRHUB", "SFRhub", "we," our, "us" or the "Company") all greatly
value your privacy and want to ensure that you fully understand how SFRhub uses and compiles your
information. In this Privacy Statement, we will describe how SFRhub handles your personal information
when you use the Company's websites (including www.SFRhub.com or any other website where this
Privacy Statement is posted), programs, mobile apps and all other related services (collectively,
"Applications"). By using the Applications, you expressly understand and consent to our collection,
storage, management, treatment, use and disclosure of your personal information as described in this
Statement.
SFRhub's Dedication to Maintaining Your Privacy
SFRhub takes your concerns about privacy very seriously and we are committed to ensuring that all your
individual and corporate privacy needs are met. At SFRhub, we endeavor to provide the very best
commercial real estate services available today and in doing so, we ensure that all of our sellers, buyers,
and other Applications visitors or users feel confident that all of their information, including all of their
company's information, is at all times very well managed and protected. Accordingly, all SFRhub
Applications are compliant with the Online Privacy Alliance Privacy Policy guidelines as they existed on
the updated date of this Statement shown below. We understand that you may have questions about
what we do with the information we collect, how we collect your information, and what specifically we
need from each user to create an account profile and how we collect and use information. This Privacy
User Statement will provide clear and concise answers to all of your questions, while also detailing each
step we take to maintain the confidentiality of your information. If, after reviewing this Statement, you
have any further questions or concerns regarding your privacy, please feel free to contact us at:
SVN | SFRhub Marketplace
Attn: Privacy Department
16211 N Scottsdale Rd. A6A-228
Scottsdale, Arizona 85254
Email: Legal@SFRhub.com
How SFRhub Collects Your Information
Personal Information. While SFRhub does need detailed information from its buyers and sellers, we do
not collect such personal information (including: names, addresses, telephone numbers, email addresses,
or financial account information) from you when you are simply browsing our Applications or related
features, unless you have specifically and knowingly provided us with personal information, (i.e., sending
SFRhub an e-mail or message via the SFRhub.com message feature, by registering your information to
receive e-mail updates or submitting information to create an account and become a user, submitting an
offer for a specific property, completing online forms, executing a non-disclosure and/or confidentiality
agreement, or in any other way creating a contractual agreement with us).
SFRhub automatically analyzes and stores all communications content sent or received via the
SFRhub.com message feature, including email content from incoming and outgoing email. This analysis
occurs as it is sent, received and when it is stored. In certain use cases, SFRhub runs automated
algorithms on such communications to create generic templates (e.g., using common terms to identify the
elements of a request for information about a Property). These templates do not include the recipient’s
personal data. SFRhub may review the templates to improve our Applications and personalization of
your experience. Unless expressly stated otherwise, you may not opt out of these features.
SFRhub uses information, without limitation: to conduct research and development for the improvement
of our Applications and related features in order to provide a better, more intuitive experience, drive
engagement on our Applications and help connect Buyers, Sellers and other visitors; to follow up on
properties or services that we provide to you and to match and serve targeted advertising and
promotions; to detect spam, malware and other malicious links or content; and for abuse protection – all
as further discussed in this Privacy Statement.
Automatic Data Collection. SFRhub will automatically collect information about the computers, tablets,
smartphones or other current or future mobile or stationary devices that you use to login to your account,
access the SFRhub Applications, or otherwise review and analyze the features and information provided
on the Applications. For example, we may collect and store information such as your browser type, IP
address, language, operating system, location of your wireless device (e.g., latitude and longitude), the
state or country from which you accessed the Applications, unique device identifier (e.g., a UDID or IDFA
on Apple devices like the iPhone, iPad and MacBook), the pages you view, the Applications you use, the
date and time of your visit, the websites you visited immediately before and after visiting our websites,
error logs, and other information and data that would help us create better versions of our current
Applications, which will inevitably help you do more with SFRhub. In gathering or reviewing the
information you give to us, we may decide to use third party analytics providers, software or other related
technologies, including cookies and similar web-based tools, to assist in collecting this information. Once
we are able to acquire and analyze the information that we receive from all of our users, we may
subsequently decide to formulate various statistical models about how you use the SFRhub Applications
and features, which will help us enhance the next version of our various Applications, and help us provide
you with tailored content and advertising that you want to see, while filtering out anything that you may
not be interested in. In sum, the information SFRhub collects automatically helps us know you better,
which allows us to provide a user experience that continues to improve on multiple levels.
Disabling Location Information Tracker. If you are uncomfortable providing us your location statistics,
you can disable our ability to track that information by following these instructions. If you are using an
Apple device, click on "General," then "Reset," then "Reset Location and Privacy." This will turn off
location functionality for all of your service programs, so that the next time you download or use an "app,"
you will be asked again to provide your consent for us and others to access your location information.
If you are using an Android device, visit the device settings, click "Location," and then click the boxes for
the particular applications for which you would like to disable location Applications.
Please note that the instructions provided above may be inaccurate should Apple or Android service
providers revise or change the manner in which a user's location and related information can be tracked
after the publication of this Privacy Statement. Therefore, should the above directions prove ineffective,
please consult your device's user manual, or contact your service provider or device's manufacturer.
Cookies. The Applications often uses the latest cookie technology, in addition to other related online
tools, such as web beacons and web pixels, to generate the information necessary to best serve our
clients. "Cookies" are small files that a website stores on a user's computer or device. The Applications
use cookies to keep together the information you enter on multiple pages. The vast majority of the
cookies SFRhub uses are defined as "session" cookies, which means that they are automatically deleted
from your hard drive after you close your browser at the end of your online session. These session
cookies are used to optimize performance of the Applications and to limit the amount of redundant data
that is downloaded during a single session, which helps us understand your relative interest in the variety
of content SFRhub provides. We also use "persistent" cookies, which remain on your computer or device
unless deleted by you (or by your browser settings). We use persistent cookies for statistical analysis of
performance to ensure the ongoing quality of our Applications. In either case, we do not use these
cookies, or any other type for that matter, to obtain or keep any personal or inherently private information
about you or your corporate entity apart from what you have already voluntarily provided us. Additionally,
most current web browsers automatically accept cookies, but you may set your browser to block cookies
if you would prefer to not provide the information noted above (see the "internet options" or related links in
your specific web-browser to disable). However, if you decide to block cookies, this may interfere with
your ability to perform certain actions on the Applications, use certain features available thereon, or
access content and information that would otherwise be fully available to you.
Communications with You. We may use the contact information we collect from you during registration,
as well as the information in the SFRhub database (including your first and last name, telephone number,
postal address, email address and investment preferences) to sort and direct commercial real estate
inquiries and related research to you. For example, we may use this information to follow-up on properties
or services that we provide to you and to inform you of other opportunities, products and services that we
think will be of interest to you.
Use of Your Information
We will use your information in a way that is consistent with your defined interests, and for purposes that
enhance your user experience at SFRhub, including, but not limited to, the below examples:
(a) Build and maintain a user profile for your account;
(b) Enhance the user experience;
(c) Perform research and analytics;
(d) Customize and personalize the content and advertising that you see on the Applications;
(e) Respond to and fulfill your requests for Applications;
(f) Determine your eligibility and profile for certain Real Properties available for Purchase, or for
determining the best Application for your current needs;
(g) Send you information about topics or commercial properties that may be of interest to you, based
on your previous searches, submitted offers, purchases and other indicators; and
(h) Send you a variety of communications and information related to your user account, and alert you
to the latest developments and features of the Applications currently offered at SFRhub that may
assist in your use of the SFRhub platform.
How SFRhub Discloses Your Information
While SFRhub does take your privacy extremely seriously, we may disclose your information in the
following ways:
(a) Make information collected through the Applications available to subsidiaries and affiliated
companies that are under common ownership or control within the SFRhub.com family.
(b) If you request information on a particular Asset, download documents from an Asset's
Portfolio/Property Page (i.e., its Due Diligence Information) or submit an offer on a particular Asset,
then the seller will be given access to your information.
(c) Under limited circumstances, SFRhub may share information about our visitors, users, sellers or
former users with the following types of companies that perform Applications on our behalf or with
whom we have joint marketing agreements:
1. Direct mailers, fulfillment service providers, payment processors, data processors,
customer/support applications or services, and other non-financial corporations or entities.
2. Financial service providers such as companies engaged in banking, mortgage lending,
consumer finance, securities, and insurance.
(d) Under limited circumstances, and only to companies we believe are of interest to you, we may
share or sell, as allowed by pertinent U.S. and international law, information about you with other
companies who may have products and services of interest to you. If you would like to opt-out of our
sharing of your information with these other companies, please contact SFRhub Customer Service.
(e) We may share your information with any person or entity, as needed, when we believe in good
faith that such disclosure is necessary to: (1) comply with the law or in response to a subpoena, court
order, government request, or other legal process; (2) produce relevant documents or information in
connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or
other legal or administrative proceedings; (3) protect the interests, rights, safety, or property of
SFRhub or any subsidiaries and affiliates thereof, or others; (4) enforce the Terms & Conditions,
Sales Process Terms of Use, and other related Applications; (5) provide users of the Applications
with the specific information and services that they request; (6) provide you with special offers or
promotions from us; (7) allow a new company that acquires a complete, majority or minority interest in
SFRhub, or some percentage of any SFRhub assets, to continue to serve you; or (8) ensure that all
SFRhub operations and systems are performing at an optimal level and are providing the very best
service to all users.
(f) Should you provide your willing consent, SFRhub is permitted to share your information with any
person or entity, as we determine is necessary.
(g) Finally, SFRhub may also use and share any of your non-personal information relating to your use
of the Applications, including any de-identified and aggregated data with third parties, without
limitation.
How to Opt Out of Email Correspondence
SFRhub will send you e-mail communications from time to time, which may include a periodic newsletter,
updates to our Applications, related services or policies, important news in the commercial real estate
industry that we feel should be shared with our users, information on any new promotions or events, and
other correspondence relating to promotional and/or innovative information. If you would rather not
receive these communications, you may "opt out" by clicking the "Unsubscribe" tab included at the base
of each e-mail that you are sent by SFRhub, or by contacting SFRhub Customer Service
at legal@SFRhub.com. Our team will gladly comply with all requests for removal, which SFRhub will
execute as soon as possible, within the limits stated in applicable law.
However, certain e-mail communications and confirmations regarding transactional events, such as
confirmation of user account registration, confirmation of Offer submitted, and related e-mail
correspondence, are not included in the e-mails that you can opt out of. You will be able to recognize
these required e-mails, as each of them will lack an "Unsubscribe" tab at the base of the message body.
Should you have any questions or concerns regarding our "opt out" process, please feel free to contact us
at your convenience at legal@SFRhub.com.
Account Protection and Security
We have implemented commercially viable electronic, technical, administrative, and physical security
measures and procedures to protect you against the loss, misuse and change of any of your personal
information. However, despite our highest and best efforts, no security measures are impenetrable. We
ask that you let us know immediately if you suspect that a misuse of your information has taken place;
and we appreciate your continued efforts to safeguard the privacy of your information and that of all
SFRhub users.
Children's Information
SFRhub does not knowingly market to, or collect, any personal information from children under the age of
18. If a parent or guardian believe that we have, in our database, the personal information of any child
under the age of 18, we ask that you please contact us immediately at legal@SFRhub.com. We will use
our best efforts to promptly remove all such information from our database, and endeavor to prevent its
further distribution on the Applications.
Access to Your Personal Information
If any of your personal information changes or becomes inaccurate for any reason, please visit your
Account home page to revise and update your records. If you no longer wish to use the Applications and
other services provided by SFRhub, or if you have any other concerns or questions regarding your
information, please contact us at legal@SFRhub.com.
Third-Party Links and Applications
Many of the Applications provided or offered by SFRhub may include links to third-party websites,
including a variety of social networking and related online community websites. If you decide to act on the
links provided and use the features and services offered by many of these websites, your information may
be collected and/or shared as a result; and this may occur without your express knowledge or consent.
SFRhub will not be responsible for any of the content offered, or privacy practices used, by any other
website or service provider to which SFRhub, or any subsidiary or affiliate thereof, is linked via any
Application, service, e-mail or other component. Moreover, the personal information that you may choose
to share with any third-party website or service provider will not be covered by the SFRhub Privacy
Statement. We encourage you to read and fully understand the privacy policies of any other websites that
you may offer your personal information to.
Amendments to Privacy Statement
From time to time, SFRhub may determine that it is necessary to amend this Privacy Statement and will
do so by posting any such revised terms here, which will become effective at the time of their posting.
Your continued use of the Applications following any changes shall mean that you accept all such
revisions. If and when we make any significant changes to this Privacy Statement, you will be notified the
next time you log into your account.
International Transfers of Information
Many of the uses and disclosures mentioned in this Privacy Statement may involve the transfer of your
personal information to various countries around the world that may have different levels of privacy
protection than your country. By submitting your personal information, you consent to any such transfers,
and to abide by any resultant regulations or rules.
Contacting Us
Should you have any questions, concerns or comments about this Privacy Statement, please contact us
by sending an e-mail to legal@SFRhub.com. In your message, we ask that you please provide your
name, mailing address, telephone number and e-mail address, so that we can better serve you. In the
alternative, you may also contact us via telephone at (602) 441-5354 or write to us at "SVN | SFRhub
Marketplace, Attn: Privacy Department, 16211 N. Scottsdale Rd. A6A-228, Scottsdale, Arizona 85254."
Please note that we may record the conversations that some of you have with SFRhub Client Relations
representatives, agents or employees, so that we can monitor the level of service you are receiving and
make any changes that we believe would provide you with a better user experience. Unfortunately, callers
may not "opt out" of the recordation procedures, as they are not only used to enhance our service
protocols, but also to ensure that all SFRhub representatives are following corporate guidelines and
providing you with the most accurate and beneficial information available at that time.
This Privacy Statement was last updated on November 30, 2018 (version 1.0.3)
© SVN | SFRhub Marketplace LLC, All Rights Reserved
SFRhub.com California Data Privacy Policy
This Privacy Policy is intended to inform users of SFRhub.com (referred to as "we," "us," or
"our") about how we collect, use, and protect personal information in compliance with California
state laws.
By using our website, you consent to the practices outlined in this Privacy Policy.
1. Information We Collect:
We may collect both personal and non-personal information from users, including but not limited
to:
• Personal Information: This may include your name, email address, phone number,
postal address, and other information you voluntarily provide to us.
• Non-Personal Information: We may collect data that does not identify you individually,
such as your browser type, IP address, and usage data.
2. How We Use Your Information:
We use the information we collect for various purposes, including:
• To provide and maintain our services.
• To send you updates, newsletters, and promotional material.
• To improve our website and user experience.
• To comply with legal obligations.
3. Sharing Your Information:
We do not sell your personal information to third parties. However, we may share your
information with trusted service providers who assist us in operating our website or conducting
our business, but only to the extent necessary for them to perform their services.
4. Your California Privacy Rights:
As a resident of California, you have certain rights regarding your personal information under
the California Consumer Privacy Act (CCPA). These rights include:
• The right to request access to the personal information we have collected about you.
• The right to request the deletion of your personal information.
• The right to opt-out of the sale of your personal information, if applicable.
• The right not to receive discriminatory treatment for exercising your privacy rights.
To exercise your rights under the CCPA, please contact us using the information provided in
Section 6.
5. Security:
We take reasonable steps to protect your information from unauthorized access and maintain its
accuracy. However, no method of online transmission or electronic storage is entirely secure, and
we cannot guarantee absolute security.
6. Contact Us:
If you have any questions or concerns regarding this Privacy Policy, or if you wish to exercise
your CCPA rights, please contact us at:
info@sfrhub.com
7. Changes to This Privacy Policy:
We may update this Privacy Policy from time to time. Any changes will be posted on this page
with a revised effective date. It is your responsibility to review this Privacy Policy periodically
for updates.
By using our website, you agree to the terms and conditions of this Privacy Policy. If you do not
agree with the practices outlined herein, please do not use our website.
SFRhub.com Europe Data Privacy Policy
1. Introduction
SFRhub.com is committed to protecting the privacy and personal data of individuals within the
European Union (EU) and European Economic Area (EEA). This Data Privacy Policy outlines
how we collect, process, store, and protect personal data in compliance with the General Data
Protection Regulation (GDPR).
2. Definitions
• Personal Data: Any information relating to an identified or identifiable natural person.
• Data Subject: The individual to whom the personal data relates.
• Processing: Any operation performed on personal data, such as collection, storage, use,
and sharing.
• Controller: SFRhub.com the entity responsible for determining the purposes and means
of processing personal data.
• Processor: Any third party that processes personal data on behalf of the Controller.
3. Data Collection
We collect personal data for specific, legitimate purposes, and we only collect data that is
necessary for those purposes. The data subjects will be informed about the purposes of data
processing at the time of collection.
4. Legal Basis for Processing
We process personal data on the following legal bases, as appropriate:
• Consent: Data subjects have given clear, informed consent for processing their data.
• Contractual Necessity: Processing is necessary for the performance of a contract.
• Legal Obligation: Processing is necessary to comply with a legal obligation.
• Legitimate Interests: Processing is based on our legitimate interests, provided they are not
overridden by the interests, rights, and freedoms of the data subject.
5. Data Security
We take appropriate technical and organizational measures to protect personal data against
unauthorized access, disclosure, alteration, and destruction.
6. Data Subject Rights
Data subjects have the following rights under GDPR:
• Right to access
• Right to rectification
• Right to erasure (right to be forgotten)
• Right to restrict processing
• Right to data portability
• Right to object
• Rights related to automated decision making and profiling
7. Data Transfers
We may transfer personal data to countries outside the EU/EEA, but we will only do so if there
are adequate safeguards in place to protect the data.
8. Data Retention
We will retain personal data only for as long as necessary to fulfill the purposes for which it was
collected, and in accordance with legal requirements.
9. Data Breach Notification
In the event of a data breach that is likely to result in a risk to the rights and freedoms of data
subjects, we will notify the relevant supervisory authority and data subjects as required by law.
10. Contact Information
If you have any questions or concerns regarding the processing of your personal data, or if you
wish to exercise your data subject rights, please contact:
info@sfrhub.com
11. Changes to this Policy
We may update this Data Privacy Policy from time to time. Any changes will be posted on our
website, and the date of the last update will be modified accordingly.