Privacy Policy

ATPL and any affiliate sites, determined by a link to this Privacy Policy located in the footer of the site and their appearance on this list. This Privacy Policy (“Policy”) describes how we collect and use your information and explains your rights and options. This Policy applies to these services (which we call the “Services” in this Policy):

⦁ websites, any newsletter and other disseminated content

⦁ anywhere else we gather information about you and refer to this Policy.

We encourage you to read this Policy carefully.  If you have questions, please contact us at [email protected].

1. About This Policy  

When this Policy applies

This Policy applies when you use the Services, effective as of the Last Updated date above.  By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy and the Terms.

Because the Services change often, this Policy may change over time.  Anytime we modify the Policy, we will post a revised version on the Services and update the Last Updated date above.  If you have given us your contact information, we will notify you before any material changes take effect, so you have time to review them. The Services may contain links to and from third-party websites and services. This Policy doesn’t apply to outside of our Services.  See Third Party Services to learn more.

Location-specific sections

The Services operates from the United States, but this Policy applies worldwide.  Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live.  For example, you may have rights under: (1) “GDPR”: implementations of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679; or (2) “CCPA”: the California Consumer Privacy Act, as ameded.

As a result, certain sections of this Policy apply to you only if you reside in a particular location:

⦁ Residents of jurisdictions where GDPR applies – such as U.K., EU and Swiss residents – should consult the Rights under GDPR and International Data Transfers sections.

⦁ Canadian residents should consult the Canadian users section.

⦁ California residents should consult the Rights under California law section.  If you reside in a U.S. jurisdiction that has enacted a data privacy law similar to CCPA or GDPR, we extend the same rights CCPA grants to California residents to you, except where we specify otherwise.If those sections apply to you, they override any contrary descriptions elsewhere in the Policy as they relate to you.  Please contact us at [email protected] if you have questions about your rights under other data privacy laws.

Information you provide

You may use the Services without providing any information about yourself.  However, to use some aspects of the Services, we will need information about you, such as if you:

⦁ Contact or communicate with us

⦁ Subscribe or opt-in to our newsletters, alerts, or other communications

⦁ Information you provide may include your name or email address (“personal identifiers”).

We generally don’t collect (or want!) your sensitive information, and we strive to limit the amount of sensitive personal information we collect.

In the event you provide sensitive personal information to us, we use it only for our operational business purposes, and we do not disclose it to others for any other purpose.

(2) How We Use Your Information

We use each of the categories of personal information described above for the following business and commercial purposes.  The activities below can involve outside companies, agents or contractors (“service providers”) to whom we disclose your information for these purposes (discussed further below in Section 4).

(a)To provide our content, services and products to you

⦁ Deliver content you request

⦁ Provide you with support in starting a real estate career with Keller Williams.

(b)To manage your subscriptions

⦁ Manage your content subscriptions

(c) To ensure legal compliance

⦁ Verify copyright or IP claims

⦁ Comply with legal requirements

⦁ Assist law enforcement

(d) Purposes

We rely on the following purposes to collect and use your information as described in this Policy:

⦁ Business purposes: Most often, we process your information for operational reasons, in a reasonably necessary and proportionate manner (i.e., for business purposes under CCPA). 

⦁ Comply with applicable laws and regulations: We also process your information where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. 

(e) For legal reasonsFinally, we may disclose personal information:

⦁ In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.  We reserve the right to raise or waive any legal objection or right available to us.

⦁ When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements.

⦁ In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

3. How Long We Retain Your Information

We retain your information only as long as we need it for the purposes described under How we use information, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.

How long we need information for those purposes varies by category, and even within categories.  These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.

4. Your Rights

(a) In General

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

⦁ Content opt-outs:  you may “opt-out” of any newsletters or promotional communications from us by following the unsubscribe instructions in the communication you receive. 

⦁ Exercising rights

(b) Rights under GDPR

This subsection applies to you only if you reside in a jurisdiction where GDPR applies.

1. Lawful basesIf we are aware that you reside in a GDPR jurisdiction, we only collect, use or share information about you when we have a valid reason. This is called a “lawful basis.” Our lawful bases generally map to the Purposes above, but specifically include:

⦁ The consent you provide to us at the point of collection of your information

⦁ The performance of the contract we have with you

⦁ The compliance of a legal obligation to which we are subject, or

ii. GDPR rights

Depending on your jurisdiction’s enactment of GDPR, you may have these rights:

⦁ Request access (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.

⦁ Request correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

⦁ Request erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised objected to processing (see below), where we may have processed your personal data unlawfully, or where we are required to erase your personal data to comply with local law.  We may not always be able to comply with your request of erasure for specific legal reasons.  If so, we will notify you at the time of your request.

⦁ Object to processing where we are relying on a legitimate interest (or those of a third party) and you object to particular processing due to a perceived impact on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

⦁ Request restriction of processing during the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

⦁ Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

⦁ Withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. For clarity, withdrawal is not retroactive.

We do not charge for access to your personal data or to exercise any of the other rights.  However, we may refuse to comply with your request or charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

(c) Canadian users

This subsection applies to you only if you reside in Canada.  To exercise these rights, please contact us via email at [email protected]

Canadian residents have the right to request access to your Personal Information and request the correction of your Personal Information, subject to limited exceptions set out in applicable laws.

You may also withdraw your consent to the collection, use and disclosure of Personal Information at any time, subject to legal or contractual restrictions. Withdrawal of your consent may affect our ability to continue to provide you with the Services that you have or would like to receive because the continued use and disclosure of your Personal Information is a necessary part of making the product or service available to you.

(d) Rights under California law

This subsection applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights, including any analogous rights.  Except as noted in this subsection, we extend these California rights to residents of those other U.S. states regardless of whether applicable law in those states includes all of these rights.

1. Rights under CCPA

The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA).

The categories of personal information we collect depend on how you use the Services.  They’re generally described in Information We Collect.  See Purposes for a general description of the reasons we collect information. For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:

⦁ Advertising and Marketing

Under CCPA, California consumers have the following rights:

A. Rights to Know, Access, Correct and Delete.

You have the right to request that we disclose, correct and delete personal information about you that we have collected.  Your right to know includes the personal information we have sold or shared or disclosed for a business purpose or a commercial purpose.

Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:

⦁ comply with legal obligations;

⦁ allow you, other consumers, or us to exercise free-speech rights or other legal rights;

⦁ complete an obligation that you have requested (for instance, if a product you purchased carries a warranty or could reasonably be subject to recall under applicable law); or

⦁ if we use the information only for internal purposes reasonably aligned with consumer expectations.

B. Rights to Limit and Opt-Out of Sharing/Sale

You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Services to you.

To opt out of the sharing of your information, please contact us at [email protected].  We do not currently offer a mechanism to exercise the right to limit our disclosure of sensitive personal information, as we limit our use of any sensitive information to the purposes you consented to.

As of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 16 for ‘sale’ or ‘sharing’ purposes.

C. Right of No Retaliation

CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted into a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.

Your right of no retaliation doesn’t need to be exercised.  We never retaliate against anyone exercising their rights under this Policy or CCPA.

D. Request process for CCPA rightsTo submit a CCPA request relating to the foregoing rights, please contact [email protected] with “California Privacy Rights Request” in the subject line.  The process described under Requesting information generally applies to requests to exercise CCPA rights.  However, in addition:

⦁ A California resident's authorized agent may submit CCPA rights request.

⦁ Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described below. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf.

⦁ An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.

We will acknowledge your request within 10 days, and our goal is to fulfill your request within 45 days.  However, we may inform you that we will require up to 45 further days to fulfill your request, along with an explanation of why our response is delayed.

⦁ We provide responses in the manner we receive your request (i.e., with an email response to an email request).

ii. Other California law

Because we only give your information to third parties for direct marketing purposes with your consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.

(g) Requesting information

1. Submitting requests

To exercise any of these rights, contact us at [email protected].  Your request must:

⦁ provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.

⦁ not disclose any social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.

ii. Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain.  If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.

iii. Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests.  We will always respond in accordance with any deadlines or requirements specified by the laws that apply to you.

At times, we may be unable to provide responsive personal information.  For example:

⦁ If disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks.

⦁ we do not disclose account passwords or any other non-personal information that enables access to an account.

We reserve the right to retain an archive of any deleted information, to the extent permitted by law.  We may also retain deidentified or aggregate data derived from information about you.

5. Security

ATPL has implemented technical, administrative and physical security measures to protect your information from unauthorized access, use or disclosure. Still, no data transmission over the Internet is 100% secure, so we cannot guarantee or warrant the security of any information you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

6. Use by Minors

The Services are intended for adult users.  We do not knowingly collect information from anyone under the age of majority in their jurisdiction (such as 16 in the UK or 18 in Mexico), and we do not share or sell information about anyone under 16 without affirmative authorization.  If we learn that we have collected information from a child under age 16, we will delete that information as quickly as possible.

⦁ If you are under 16: sorry, but please leave the Services.  If you’ve already sent us information, please contact us first so we can delete it.

⦁ If you are a parent or guardian of a child under 16 years of age and you believe your child has provided us with information, please contact us.

7. Third Party Services

Some areas of the Services contain links to third-party websites, resources and advertisers. These third parties are not part of the Services. We do not control (and are not responsible for) third party content or privacy practices.  Information you provide to them is not covered by this Policy.  These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and where they store information.  We encourage you to familiarize yourself with their privacy policies and terms of use.

8. Contact us

If you have any questions or feedback about this Policy, email us at [email protected].