Privacy Policy

Western Continental LLC and its affiliates, which include but are not limited to, Western Continental Hospitality, The Guild and Western Continental Development Partners, all of which are based in the United States (collectively, “Western Continental,” “we,” or “ us”), want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect about consumers (“you”) through:

• Our website at https://www.westerncontinental.com and other websites and Western Continental-branded web-based applications we operate from which you are accessing this Privacy Policy (collectively, the “WC Websites”),
• HTML-formatted email messages that we send to you that link to this Privacy Policy, and
• Offline interactions you have with us.

Collectively, we refer to the WC Websites, our emails, and offline interactions as the “Services.”

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information including:

• Name
• Postal and email address
• Telephone number
• IP address (we may also derive your approximate location from your IP address)
• Your real estate buying/selling interests, when you choose to share them with      us
• Your mobile device’s contacts, photos, and location, when you choose to share      them with us
• Photos

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services

—We collect Personal Information through the Services, for example, when you fill out a user profile when using our Services, register an account to access the Services, request a consultation, request reservation quotes, or contact us by telephone.

• From Other Sources

—We receive your Personal Information from other sources, for example:

○publicly available databases;

○joint marketing partners, when they share the information with us.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people, such as your friends or family, to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes including:

• Providing the functionality of the Services and fulfilling your requests.

—To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related user support services.

—To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions or comments, or when you request other information about our Services.

—To send administrative information to you, such as changes to our terms, conditions and policies.

—To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

• Providing you with marketing materials and facilitating social sharing

—To send you marketing related emails with information about our services, new products, and other news about our company.

—To facilitate social sharing functionality that you choose to use.

—We will engage in this activity with your consent or where we have a legitimate interest.

• Analysis of Personal Information for business reporting and providing personalized services.

—To analyze or predict our users’ preferences in order to prepare aggregated trend reports, so we can improve our Services.

—To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

—To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We use this information to manage our contractual relationship with you.

• Aggregating and/or anonymizing Personal Information.

—We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.

—For data analysis, for example, to improve the efficiency of our Services;

—For audits, to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements;

—For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

—For developing new products and services;

—For enhancing, improving, or modifying our current products and services;

—For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

—For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

—For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interests.

Disclosure of Personal Information

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• To our third party service providers, to facilitate services they provide to      us.

—These can include providers of services such as data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, user support service, email delivery, auditing, and other services.

• By using the Services, you may elect to disclose Personal Information.

—On message boards, chat, blogs, and other services to which you are able to post information and content. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations.
• To cooperate with public and government authorities.
• To cooperate with law enforcement.
• For other legal reasons.
• In connection with a sale or business transaction.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

• Through your browser or device
• Using cookies
• Using pixel tags and other similar technologies
• Analytics.    We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on      activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about  Google’s practices by going to www.google.com/policies/privacy/‌partners, and exercise the opt-out      provided by Google by downloading the Google Analytics opt-out browser add-on,      available at  https://tools.google.com/dlpage/gaoptout.
• Physical Location

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

• Receiving marketing-related emails from us: If you no longer want to receive      marketing-related emails from us on a going-forward basis, you may opt out

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Updates to this Privacy Policy

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.