W+R Studios Privacy Policy

General

This Privacy Policy describes the privacy practices of Woolley Robertson Group, Inc. a California Corporation d/b/a W+R Studios (“W+R Studios,” “we,” “our,” or “us”) with respect to the websites and web applications (the “Sites and Apps”) consisting of the following: Cloud CMA®, Cloud Streams®, Cloud MLX®, and Cloud Attract®, which comprise our Cloud Agent Suite® of products, and any other Internet Sites and Apps operated by us.  We are committed to protecting the privacy or our customers and their clients.  Please read the following information to understand what information we collect and how we use that information.

This Privacy Policy describes our collection, use, disclosure, and protection of personal information collected or provided through the Sites and Apps and how we use personal information in connection with our services offered through the Sites and Apps (“Services”).  “Personal information” is information that identifies an individual and is associated with a specific person.  Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.

We are committed to the protection of the privacy of personal information provided to us by our customers and their clients.

Customer Information

Our customers are almost always real estate agents who desire to use our services and subscribe to one or more of our Sites and Apps.  The Sites and Apps are also often involved the collection of personal information from clients of our customers with their consent.  See “Client Information” below.  Our use of the term “customer information” does not include personal information collected by customers from their respective clients.

We may collect the following types of personal information about our customers through the Sites and Apps, including but not limited to:

Use of Customer Information

We use customer personal information to:

In order to allow customers to use certain Services, we may be required to verify their identity.  We may use customer information to verify a customer’s identity in the event a customer contacts us for assistance with the Sites, Apps, or Services.

We may use customer information to pre-fill form fields on the Sites and Apps for the convenience of our customers.

Disclosure of Customer Information

We will not, without the permission of a customer, sell, publish, or share a customer’s personal information to third parties for their marketing purposes.  We do not share credit card information.

Our customers may opt-out of allowing us to use their personal information for our own marketing purposes, including opting-out of our providing a customer with information regarding our products and services that are not requested by the customer or other offers from us.

We reserve the right, however, in our sole discretion, to share or disclose customer personal information with law enforcement, government officials, and other third parties:

We may share customer personal information with other third parties with consent or instructions to do so.

Information of Clients of Customers

Our customers are almost always real estate agents who desire to use our services and subscribe to one or more of our Sites and Apps.  The Sites and Apps often involve the collection of personal information from clients of our customers.  The clients and potential clients of our customers are not our customers.  We refer to information received by our customers from their clients as “client information.”

Client Information

As a data processor serving at the instruction of our customers, we process the following types of personal information about the clients of our customers through the Sites and Apps, including but not limited to:

Use of Client Personal Information

We use client personal information to:

Disclosure of Client Information

We do not sell, publish, or share clients’ personal information to third parties for their marketing purposes.

We reserve the right, in our sole discretion, to share or disclose client personal information with law enforcement, government officials, and other third parties:

Mergers and Acquisitions

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information that includes, without limitation, personal information of clients and customers and other information concerning the relationship between our real estate agent clients and us.  Such third parties will assume responsibility for the information collected by us in connection with our business operations or through our Sites and Apps and such third parties will assume the rights and obligations regarding such information as described in this Privacy Policy.

Changes to Personal Information

Customers may access and update much of the information they have submitted to us at any time via the Sites and Apps.

Customers may choose to delete their account for the Service at any time.  We will use commercially reasonable efforts to remove customer and client information with respect to such customer, although some information may be retained on a backup server or media, which is necessary to help ensure continued availability of our Service.

We retain customer and client personal information as long as necessary to provide the Services each real estate agent customer has requested.  Additionally, we may retain personal information to comply with law, prevent fraud, resolve disputes, trouble shoot problems, enforce our Terms of Service, and as permitted by applicable law.

Links to and from Other Web Sites

Our Sites and Apps may offer links to other third party websites for convenience and information only.  These websites have their own privacy and information collection practices and security measures.

Use of Non-Personal Information

When using our services and offerings we may also collect non-personal information − data in a form that does not permit direct association with any specific individual.  Aggregated data is considered non-personal information for the purposes of this Privacy Policy.  If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined. 

We may collect, use, transfer, and disclose non-personal information for any purpose.  The following are some examples of non-personal information that we collect and how we may use it:

As our Sites and Apps are navigated, certain information may also be passively collected by us or a third party service provider.  This information includes Internet protocol addresses, browser types, domain names, access times, operating systems, mouse clicks, mouse movements, and scrolling activity.  We also use cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of uses or visits.  This type of information is collected to analyze the use of our offerings, programs, and services to make them more useful to customers and to provide customers with relevant offerings.

Protection of Information

We take the security of personal information seriously.  We use technical and administrative security measures such as but not limited to firewalls, encryption techniques, and authentication procedures, among others, to maintain the security of personal information.  However, no complete assurance can be made against all cyber attacks and other security breaches.  To safeguard against unauthorized access, customers are required to login to certain secure areas of our web Sites and Apps using a user name and a password.  Both user name and password are encrypted when sent over the Internet.

Cookies and Tracking

We may aggregate information through cookies, or alphanumeric identifiers that we transfer to a computer's hard drive through the web browser.  This allows us to collect and track information about users and users’ activities online at our websites over time and across third-party websites or online services including, but not limited to, a computer's network address and operating system, the Sites and Apps from which a user linked to our Sites and Apps, the time and date of the visit, how our offerings, programs, services are used and what offerings and services are used.  We may also link this information with other personal information about users and may use this linked information.  This helps us to recognize users, customize, or personalize user’s utilization of our Services and to store such information in between visits to our Sites and Apps.  It also allows us to aggregate demographic and statistical data and compilations of information that may or may not include personal information and provide this information to our business partners, third party vendors, and service providers.  By doing so, we hope to understand our customer’s needs and desires so that we can make new offerings to them or tailor existing offerings to fit their desires. 

Minors

Our Sites, Apps, and Services are not intended for minors or not of a legal age to form a binding contract with us.  We do not knowingly collect personal information from these individuals.  If a minor (as defined by law) provides us with his/her personal information without parental or guardian consent, we encourage the parent or guardian to contact us to have this information removed and to unsubscribe the minor from future communications with us.

Canadian Users

To the extent the personal information contains personal data relating to an individual who resides in the Canada, each of our customers is responsible for compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).  We require our customers to acknowledge that they may use personal information of Canadian residents only for the purposes for which it was collected, unless the individual client consents. Whenever we are notified that a client has withdrawn their consent and opted out, we will delete their personal information from our system. We do not collect, use, or disclose personal information without a client’s consent, except where required or allowed by law. We will, in accordance with PIPEDA and upon proof of entitlement and the presentation of proper identification, permit an individual access to the personal information that we have in our possession.

EU and Swiss Users

The General Data Protection Regulation (GDPR), effective May 25, 2018, creates consistent data protection rules across Europe.  It applies to all companies that process personal data about individuals in the Europe and Switzerland, regardless of where the company is based.

Each of our customers is responsible for complying with all applicable privacy laws with respect to client personal information, including the GDPR.

As part of our Services, we operate as a data processor through our Sites and Apps on behalf of our customers. Where we act as a data processor on a customer’s behalf, we will rely on our customer's legal basis as data controller for our processing of this data.  Where we act as a data processor on the behalf of any European customers, we will ensure that we comply with the specific requirements for data processors.  We have updated our related terms of service to align with the GDPR.  Where we appoint parties to act as data processor on our behalf, we will ensure that we have appropriate terms in place to comply with our requirements under the GDPR and to safeguard personal data. 

Questions or Concerns

If you have questions or concerns regarding our Privacy Policy, please contact us at:

W+R Studios
123 Main Street, Ste. 201
Huntington Beach, CA 92648

Modifications to this Privacy Policy

We may modify our Privacy Policy from time to time, so please review it periodically.  If our practice in using and/or sharing personal information changes in the future, those changes will be reflected in this Privacy Policy.  This was last updated on May 31, 2018.