1. SCOPE OF OUR PRIVACY NOTICE
This privacy notice applies to our collection, use, disclosure and other processing of personal
information related to: The use of our Sites or Services that display or link to this Policy;
Former, current and prospective clients, brokers, independent agents, and consumers; Other
individuals who use our Sites or Services, whose personal information we received related to the
Sites and Services
All collection, use, disclosure, and processing of personal information by RMS Elite, LLC and
its affiliates about individuals will vary depending upon use of our Sites and Services. This
policy is intended to provide our general practices and procedures. In some cases, different or
additional notices about our data collection and processing may be provided and apply to certain
This policy does not apply to job applicants or candidates who apply for employment with
RMS Elite LLC or its affiliates or to the employees and independent agents of RMS Elite
LLC and its affiliates.
2. COLLECTING INFORMATION
When you visit our consumer applications or purchase and/or sell real estate with RMS Elite,
LLC and its affiliates, we may collect information about you that you share with us. We typically
collect two kinds of information about you through our applications: (a) information that you
provide that personally identifies you; and (b) information that does not personally identify you,
which we automatically collect when you visit our applications or that you provide to us.
a. Personally Identifiable Information: This identification information may include, but is not
limited to, your name, physical address, email address, telephone, mobile and fax numbers,
details of your real estate, lending, title and insurance needs and references, and other details of
your life (“Personal Information”).
b. Non-Personally Identifiable Information: Our definition of non-personally identifiable
information (“Non-PII”) is any information that does not personally identify you. Non-PII can
include certain personally identifiable information that has been de-identified; that is,
information that has been rendered anonymous by a de-identification process. We obtain Non-
PII about you from information that you affirmatively provide to us, either separately or together
with your personally identifiable information. We also automatically collect certain Non-PII
from you when you access any applications. This information can include, among other things,
IP addresses, the type of browser you are using, the third-party website from which your visit
originated, the operating system you are using, the domain name of your Internet service
provider, the search terms you use on our applications, the specific web pages you visit, the
duration and frequency of your visits, and location information.
c. Cookies, Web Beacons and other Tracking Technologies: As you may be aware, it is a
common practice that when you visit our web sites, we may collect data through the use of
cookies, web beacons or other tracking technologies (i.e. small text files placed on your
computer by consumer applications), web server logs, and other web tools. This technology
allows us to customize your online experience as well as track your use of our system so that we
can improve your experience. The tracking data we collect may include, but is not limited to, the
date, time and location of your visit, the time you spend, the web pages you view, the other
consumer applications you visit, your search queries, and basic information about your
computer, such as your Internet Protocol (“IP”) address, your domain name, your browser type,
and the name of your internet service provider. By continuing to browse our site, you are
When visiting our consumer-facing applications, you may be directed, through hyperlinks, to
by those other companies and consumer applications. Although we encourage third parties to
provide their own privacy policies, we are not responsible for their activities, such as how they
handle the information they collect online.
3. BASIS FOR PROCESSING OF PERSONAL INFORMATION
Certain laws, including the EU General Data Protection Regulation (“GDPR”), requires that we
inform individuals of the legal basis for our use and other processing of personal information.
We process personal information for the follow bases: Performance of contract: as necessary to
enter into or carry out the performance of our contract; Compliance with laws: for compliance
with legal obligations and/or defense against legal claims, including those in the area of labor
and employment law, social security, and data protection, tax, and corporate compliance laws;
and Our legitimate interests: in furtherance of our legitimate business interests including:
Performance of contracts; Customer relationship management and improving our services,
including marketing and analytics; Fraud prevention, including misuse of company IT systems or
money laundering; Physical, IT, and network perimeter security; Internal investigations; and
Mergers, acquisitions, and reorganization, and other business transactions
With your consent: where we have your consent (the GDPR (where it applies)) and other
applicable laws give you the right to withdraw your consent, which you can do this at any time
by contacting us using the details at the end of this privacy notice. In some jurisdictions, your use
of the Services may be taken as implied consent to the collection and processing of personal
information as outlined in this privacy notice.
In addition, we may process your personal information where necessary to protect the vital
interests of any individual.
4. HOW WE USE AND SHARE INFORMATION COLLECTED
Personal Information: We primarily use the identification information you voluntarily share
with us to: Customize your online and/or real estate transaction experiences and to carry out your
online requests; Tell you about our products, services and other offerings; Contact you for a
variety of reasons, such as providing you promotional or marketing information for our products
or those of our affiliated companies; On occasion, we use your identification information to
validate your identity; and as for usage tracking data, we primarily use that information to
operate and improve our consumer applications, and to further our marketing efforts.
We further reserve the right to disclose your information under limited circumstances, such as to
cooperate with law enforcement or judicial authorities as required by law or legal process, to
protect our own legal rights, or to protect the public good.
Non-PII: We use Non-PII in a variety of ways, including to: help analyze site traffic, understand
customer needs and trends; carry out targeted promotional activities; and improve our services
We may use your Non-PII by itself or aggregate it with information we have obtained from
others. We may share your Non-PII with our affiliated companies and third parties to achieve
these objectives and others, but remember that aggregate information is anonymous information
that does not personally identify any individual, device, or household.
Whenever you are online or on our applications, you run the risk that the information you
provide will fall into the wrong hands. Although we implement and maintain commercially
reasonable security procedures and practices to safeguard your privacy, we cannot guarantee the
security of any information you provide to us. We accept no responsibility or liability for the
activities of third parties. By using our consumer applications and applications, you agree to our
5. UPDATING INFORMATION
If you would like to review the information about you that we have collected through our
consumer applications, or to change that information, you can make that request by following the
procedure indicated below in Section 10. We may require that you verify your identity before we
process your request.
6. PROCESSING LOCATION
We process your personal information in the United States. For users located outside of the
United States, please see Sections 16 European Union / European Economic Area for more
7. ANTI-FRAUD DISCLOSURE
Electronic communications such as email, text messages and social media messaging, are neither
secure nor confidential. While RMS Elite, LLC and its affiliates have adopted policies and
procedures to aid in avoiding fraud, even the best security protections can still be bypassed by
unauthorized parties. RMS Elite, LLC and its affiliates will never send you any electronic
communication with instructions to transfer funds or to provide nonpublic personal information,
such as credit card or debit numbers or bank account and/or routing numbers.
YOU SHOULD NEVER TRANSMIT NONPUBLIC PERSONAL INFORMATION, SUCH AS
CREDIT OR DEBIT CARD NUMBERS OR BANK ACCOUNT OR ROUTING NUMBERS,
BY EMAIL OR OTHER UNSECURED ELECTRONIC COMMUNICATION. EMAILS
ATTEMPTING TO INDUCE FRAUDULENT WIRE TRANSFERS ARE COMMON AND
MAY APPEAR TO COME FROM A TRUSTED SOURCE.
If you receive any electronic communication directing you to transfer funds or provide nonpublic
personal information, EVEN IF THAT ELECTRONIC COMMUNICATION APPEARS TO BE
FROM RMS Elite, LLC or its affiliates, do not respond to it and immediately contact your real
estate agent or title closer. Such requests, even if they may otherwise appear to be from RMS
Elite, LLC or its affiliates, are likely part of a scheme to defraud you by stealing funds from you
or using your identity to commit a crime.
To notify RMS Elite, LLC or its affiliates of suspected fraud related to your real estate
transaction, please call (727) 821-1999 and request to speak with the Legal Department.
9. DATA RETENTION
We will retain your personal information for the period necessary to fulfill the purposes outlined
in this privacy notice unless a longer retention period is required or permitted by law. We may
retain personal information for longer where required by our legal and regulatory obligations,
professional indemnity obligations, or where we believe it is necessary to establish, defend or
protect our legal rights and interests or those of others. With respect to the data and files we
handle as a processor, we retain this personal information in accordance with our clients’
10. RIGHTS AND “OPT-OUT”
Marketing. You may opt out from receiving marketing-related communications from us on a
going-forward basis by contacting us or by using the unsubscribe mechanism contained in each
email. We will try to comply with your request(s) as soon as reasonably practicable. Please note
that if you opt out of receiving marketing-related emails from us, we may still send you
important administrative messages, from which you cannot opt out.
Cookies and similar technologies. Please review your browser or device settings for certain
cookies and see above to exercise certain choices regarding cookies.
Access, amendment and deletion. Under applicable privacy laws, you may have the right to
request to review, make amendments, have deleted or otherwise exercise your rights over your
personal information that we hold, subject to certain legal limitations and requirements. We
follow applicable law to take steps to keep your personal information accurate, complete and up-
to-date. In your request that is covered by an applicable privacy law, please make clear what
personal information you would like to have changed, whether you would like to have your
personal information suppressed from our database or otherwise let us know what limitations
you would like to put on our use of your personal information.
As outlined below, if you are a California resident or if you are in the European
Union/European Economic Area, you may have additional rights.
Deactivation. You can deactivate your account at any time by contacting us at the email address
at the bottom of this page. However, you will not be able to access many of the services to
deactivate your account. Please note that even if you request deactivation of your account, it may
take some time to fulfill this request.
Responding to Requests. Please note that we may need to retain certain information for
recordkeeping purposes and/or to complete any transactions that you began prior to requesting a
change or deletion. There may also be residual information that will remain within our databases
and other records, which will not be removed. We may not always be able to fully address your
request, for example if it would impact the duty of confidentiality we owe to others, or if we are
legally entitled to deal with the request in a different way.
Additional information for certain jurisdictions. We are committed to respecting the privacy
rights of individuals under all privacy laws applicable to us. Some privacy laws require that we
provide specific information about individual rights to applicable consumers, which we have set
forth at the end of this privacy notice:
California: if you are a California resident, you have certain rights, under California privacy
laws, regarding your personal information as set forth in Section 15 below.
EU/EEA: if you are in the European Union / European Economic Area, we provide further
details about your rights under the GDPR in Section 16 below.
The Services are not intended or directed to children under the age of 18, and we do not
knowingly collect any personal information, or knowingly track the use of our Services, from
children. If we have actual knowledge that personal information about a child under 18 years old
has been collected, then we will take appropriate steps to try and delete such personal
12. EFFECTIVE DATE AND CHANGES TO THIS POLICY
13. CONTACT INFORMATION
For questions and concerns about this Policy, our company can be reached at:
4700 9th Avenue North
Saint Petersburg, Fl 33713
Email Address: firstname.lastname@example.org
14. CALIFORNIA PRIVACY RIGHTS
In this section, we provide information for California residents, as required under California
privacy laws, including the California Consumer Privacy Act (“CCPA”), which requires that we
provide California residents certain specific information about how we handle their personal
information, whether collected online or offline. This section does not address or apply to our
handling of publicly available information made lawfully available by state or federal
governments or other personal information that is subject to an exemption under the CCPA.
Categories of personal information that we collect. Our collection, use and disclosure of
personal information about a California resident will vary depending upon the circumstances and
nature of our interactions or relationship with such resident. The table below sets out generally
the categories of personal information (as defined by the CCPA) about California residents that
we collect, sell, and disclose to others for a business purpose. We collect these categories of
personal information from the sources described and for the purposes also detailed below.
Category Examples Collected
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number,
driver’s license number, passport number, or other similar
B. Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical
characteristics or description, address, telephone number,
passport number, driver’s license or state identification
card number, insurance policy number, education,
employment, employment history, bank account number,
credit card number, debit card number, or any other
financial information, medical information, or health
insurance information. Some personal information
included in this category may overlap with other
C. Protected classification characteristics under
California or federal law.
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, genetic
information (including familial genetic information).
D. Commercial Records of personal property, products or services
information. purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a
template or other identifier or identifying information,
such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and
sleep, health, or exercise data.
F. Internet or other similar
Browsing history, search history, information on a
consumer’s interaction with a website, application, or
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar
I. Professional or employment-related information.
Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained
by an educational institution or party acting on its behalf,
such as grades, transcripts, class lists, student schedules,
student identification codes, student financial information,
or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
Personal information does not include: Publicly available information from government records;
De-identified or aggregated consumer information; and information excluded from the CCPA’s
scope, like: health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information
Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy
laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or
California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of
We obtain the categories of personal information listed above from the following categories of
sources: Information from you that you actively provide: We collect this information from
sources including from online forms, e-mail, and via telephone; Information from you that you
provide passively from your use of your sites and services: We collect this information from
sources including from a web browser, e-mail, or smartphone; and third Parties (information we
collect about you from third party sources): We collect this from sources including marketing
partners, lead generators, and website and app vendors.
Use of Personal Information. We may use or disclose the personal information we collect for
one or more of the following business purposes: To fulfill or meet the services for which the
information is provided; to provide you with information, products or services that you request
from us; to provide you with email alerts, event registrations and other notices concerning our
products or services, or events or news, that may be of interest to you; to carry out our
obligations and enforce our rights arising from any contracts entered into between you and us,
including for billing and collections; to improve our website and present its contents to you; for
testing, research, analysis and product development; as necessary or appropriate to protect the
rights, property or safety of us, our clients or others; to respond to law enforcement requests and
as required by applicable law, court order, or governmental regulations; as described to you
when collecting your personal information or as otherwise set forth in the CCPA; and to evaluate
or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or
transfer of some or all of our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by us is among the assets
We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you
Sharing Personal Information. We may disclose your personal information to a third party for
a business purpose. When we disclose personal information for a business purpose, we enter a
contract that describes the purpose and requires the recipient to both keep that personal
information confidential and not use it for any purpose except performing the contract.
Rights of California residents. California law grants California residents certain rights and
imposes restrictions on particular business practices as set forth below.
- Do-Not-Sell: California residents have the right to opt-out of our sale of their personal
information Opt-out rights can be exercised by clicking on the “Do Not Sell My Personal
Information” (or similar link) at the bottom of this page or the homepage of our website. We do
not sell personal information about residents who we know are younger than 16 years old
without opt-in consent.
- Initial Notice: We are required to notify California residents, at or before the point of
collection of their personal information, the categories of personal information collected and the
purposes for which such information is used.
- Request to Delete: California residents have the right to request deletion of their personal
information that we have collected about them and to have such personal information deleted,
except where an exemption applies. We will respond to verifiable requests received from
California residents as required by law.
- Request to Know: California residents have the right to request and, subject to certain
exemptions, receive a copy of the specific pieces of personal information that we have collected
about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or
(b) electronically in a portable and, to the extent technically feasible, readily useable format that
allows the individual to transmit this information to another entity without hindrance. California
residents also have the right to request that we provide them certain information about how we
have handled their personal information in the prior 12 months, including:
categories of personal information collected; categories of sources of personal information;
business and/or commercial purposes for collecting and selling their personal information;
categories of third parties/with whom we have disclosed or shared their personal information;
categories of personal information that we have disclosed or shared with a third party for a
business purpose; categories of personal information collected; and categories of third parties to
whom the residents’ personal information has been sold and the specific categories of personal
information sold to each category of third party.
California residents may make a Request to Know up to twice every 12 months. We will respond
to verifiable requests received from California residents as required by law.
- Right to non-discrimination: The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a
business denies or provides a different level or quality of goods or services, or charges (or
suggests that it will charge) different prices, rates, or penalties on residents who exercise
their CCPA rights, unless doing so is reasonably related to the value provided to the
business by the residents’ data.
- Financial incentives: A business may offer financial incentives for the collection, sale or
deletion of California residents’ personal information, where the incentive is not unjust,
unreasonable, coercive or usurious, and is made available in compliance with applicable
transparency, informed consent, and opt-out requirements. California residents have the
right to be notified of any financial incentives offers and their material terms, the right to
opt-out of such incentives at any time, and may not be included in such incentives
without their prior informed opt-in consent. We do not offer any such incentives at this
Submitting Requests. Do-Not-Sell (Opt-out) Requests, Requests to Know, and Requests to
Delete may be submitted to email@example.com.
We will respond to verifiable requests received from California residents as required by law. For
more information about our privacy practices, contact us as set forth in the “Contact Us” section
above. You may only make a verifiable consumer request to know information twice within a
12-month period. We cannot respond to your request or provide you with personal information
if we cannot verify your identity or authority to make the request and confirm that the personal
information relates to you. We will only use personal information provided in a verifiable
consumer request to verify the requestor’s identity or authority to make the request.
Changes to Our Privacy Notice. RMS Elite, LLC and its affiliates reserve the right to amend
this privacy notice at our discretion and at any time. When we make changes to this privacy
notice, we will post the updated notice on the Website and update the notice’s effective date.
Your continued use of our Website or Services following the posting of changes constitutes your
acceptance of such changes.
15. EUROPEAN UNION / EUROPEAN ECONOMIC AREA
Individuals in the European Union (EU) and the European Economic Area (EEA) have the
following rights, under the GDPR, regarding their personal information:
- Right of access: You have the right to obtain from us confirmation as to whether or not
personal information concerning you is being processed, and where that is the case, to
request access to the personal information. The accessed information includes – among
others – the purposes of the processing, the categories of personal information concerned,
and the recipients or categories of recipient to whom the personal information have been
or will be disclosed. You have the right to obtain a copy of the personal information
undergoing processing. For further copies requested by you, we may charge a reasonable
fee based on administrative costs.
- Right to rectify and complete personal information: you can request the rectification
of inaccurate data and the completion of incomplete data. We will inform relevant third
parties to whom we have transferred your data about the rectification and completion if
we are legally obliged to do so.
- Right to erasure (right to be forgotten): You have the right to obtain from us the
erasure of personal information concerning you in limited circumstances where: it is no
longer needed for the purposes for which it was collected; or you have withdrawn your
consent (where the data processing was based on consent); or following a successful right
to object; or it has been processed unlawfully; or the data has to be erased in order to
comply with a legal obligation to which we are subject. We are not required to comply
with your request to erase personal information if the processing of your personal
information is necessary for: compliance with a legal obligation; or the establishment,
exercise or defense of legal claims.
- Right to restriction of processing: You have the right to obtain from us restriction of
processing your personal information. In this case, the respective data will be marked and
only be processed by us for certain purposes. This right can only be exercised where: the
accuracy of your personal information is contested, to allow us to verify its accuracy; or
the processing is unlawful, but you do not want the personal information erased; or it is
no longer needed for the purposes for which it was collected, but you still need it to
establish, exercise or defend legal claims; or you have exercised the right to object, and
verification of overriding grounds is pending. We can continue to use your personal
information following a request for restriction, where: we have your consent; or to
establish, exercise or defend legal claims; or to protect the rights of another natural or
- Right to data portability: You have the right to receive the personal information
concerning you, which you have provided to us, in a structured, commonly used and
machine-readable format and you have the right to transmit those data to another entity
without hindrance from us, but in each case only where the processing is (a) based on
your consent or on the performance of a contract with you, and (b) also carried out by
- Right to object: You have the right to object at any time to any processing of your
personal information which has our legitimate interests as its legal basis. You may
exercise this right without incurring any costs. If you raise an objection, we have an
opportunity to demonstrate that we have compelling legitimate interests which override
your rights and freedoms. The right to object does not exist, in particular, if the processing
of your personal information is necessary to take steps prior to entering into a contract or to
perform a contract already concluded.
- Right to object to our use of your personal information for direct marketing
purposes: You can request that we change the manner in which we contact you for
marketing purposes. You can request that we not transfer your personal information to
unaffiliated third parties for the purposes of direct marketing or any other purposes.
- Right to withdraw consent: if you have given us your consent for the processing of your
personal information, you have the right to withdraw your consent at any time, without
affecting the lawfulness of processing based on consent before its withdrawal.
- Right to obtain a copy of safeguards: you can ask to obtain a copy of, or reference to,
the safeguards under which your personal information is transferred outside the EU/EEA.
We may redact data transfer agreements to protect commercial terms.
- Right to lodge a complaint with your local supervisory authority: You have a right to
lodge a complaint with your local supervisory authority if you have concerns about how
we are processing your personal information. We ask that you please attempt to resolve
any issue with us first, although you have a right to contact your supervisory authority at