Privacy
This Privacy Policy (“Policy”) describes the types of information that AdvanceCRE LLC (“AdvanceCRE,” “Company,” “we,” or “us”) may collect from or about you or that you may provide when you visit an AdvanceCRE website or platform or use our Services (as defined below), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
1 General
A This Privacy Policy applies to data we collect through the following mechanisms, which are collectively referred to as the “Services”:
i AdvanceCRE websites, platforms, or mobile applications.
ii Email, SMS, chat or other online communications between you and AdvanceCRE.
iii Registration for any job alerts on a third-party website, platform, or mobile application where AdvanceCRE is a co-controller with the third-party operator.
iv When you interact with any AdvanceCRE widgets, banners, or links contained in job advertisements that are located on websites owned or operated by third parties that have hired AdvanceCRE to provide services to the third party and your interaction brings you to a website, platform, or mobile application owned or operated by AdvanceCRE.
B Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use or in any other contractual document between you and us.
C Key Terms
i As used in this Policy, “Personal Data” refers to any information or pieces of information identifying you or could reasonably be used to identify you or your personal device either directly (e.g., your name) or, where required by applicable law, indirectly (e.g., through pseudonymised data, such as a unique ID number). Personal Data includes information such as e-mail addresses, mailing or residential addresses, usernames, user-generated content, financial information, and health information. It could also include certain Technical Data (defined below), namely, unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies (“Device IDs”), where required by applicable law.
ii As used in this Policy, “Non-Personal Data” refers to data that is not considered Personal Data under applicable law. We reserve the right to treat data as Personal or Non-Personal based on the law applicable to the data and the data subject.
iii As used in this policy, “Special Categories of Personal Data” refers to sensitive Personal Data that reveals racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, financial data such as credit or debit card information, and data concerning health, sex life, or sexual orientation.
2 Types of User Data Collected
A Personal Data
As permitted by applicable law in the country from which you access our website or platforms and use our Services, we may collect, use, store, and transfer different kinds of Personal Data about you. We have grouped these into the following categories of Personal Data:
i “Identity Data,” such as first name, maiden name, last name, resume or CV, social media profiles, username or similar identifier.
ii “Contact Data,” such as physical address, e-mail address, social media address, telephone number(s), and any other contact information you provide to us.
iii “Technical Data” such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
iv “Profile Data” such as your username and password, preferences, user-generated content, job searches, candidate searches, job applications, feedback, and survey responses.
v “Usage Data” such as information about how you use our websites, platforms, products, and services.
vi “Marketing and Communications Data” such as your preferences in receiving marketing from us and our third-parties and your communication preferences.
B Non-Personal Data
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data since it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of Users accessing a specific website feature.
C Effect of Declining to Provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract or prospective contract between you and AdvanceCRE, and you fail or decline to provide that Personal Data when requested, our performance under such a contract may be limited or impossible (for example, to provide you with our Services). In that case, we may have to refrain from providing any Services that we have agreed to provide (or that you have requested from us), and you accept that as a condition of service.
3 Data that Users Should Not Provide
AdvanceCRE does not require any Special Categories of Personal Data about you in order for you to utilize the Services. If you are submitting your resume to our database or sharing your resume with a prospective employer directly using a job application feature on the AdvanceCRE websites or platforms, or through the Services or Mobile Software, please carefully consider the information that is contained within your resume and ensure that you are not providing any sensitive information or other information that is not necessary for your job application or job search.
4 How Data is Collected
We utilize different methods for collecting Personal Data from and about you, including, for example:
A Direct Interaction with Company
You may provide us with Identity Data, Contact Data, Profile Data, and other information by completing forms or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Data you provide when you:
i Create an account on our websites or platforms;
ii Request that information to be sent to you;
iii Submit your CV or resume to our Resume Database;
iv Provide feedback;
v Apply or otherwise respond to a Listing on our websites or platforms;
vi Sign up for Alerts via e-mail or SMS messaging;
vii Authorize AdvanceCRE to connect your account to the account of a "Connected Site" (e.g., Google, Linkedin, Monster, Facebook, or Twitter) and thereby allow us to access information you have provided to the Connected Site, such as profile information, content information, timeline feeds, contact and follow lists, network statistics, or updates regarding your account on the Connected Site.
B Automated Technologies
As you interact with our websites or platforms, Services, or Mobile Software, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data and Non-Personal Data by using cookies, server logs, and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies and other Tracking Technologies (defined below). For more information regarding our use of Tracking Technologies, please refer to “Cookies and Tracking Technologies” below.
C Third Parties
We may receive Personal Data in the form of Technical Data, Usage Data, or Profile Data about you from various third-parties such as analytics providers, advertising networks, or Connected Sites.
D AdvanceCRE as a Service-Provider or Data-Processor
i In certain instances, parties may hire AdvanceCRE to provide services on their behalf. In such case, we process Personal Data under the direction of that party (the data controller) and have no direct relationship with the individuals (data subjects) whose Personal Data we process.
ii Where AdvanceCRE processes your Personal Data in the capacity of a service provider (data processor), and you seek access to, or wish to correct, amend, or delete your Personal Data, we will provide you with the data controller’s contact information, so you can contact them directly. In rare instances, however, circumstances may necessitate that AdvanceCRE assist you with your question or request.
iii For example, some parties may hire AdvanceCRE to send Alert e-mails to their Candidates who have requested Alert e-mails from such parties. In these cases, AdvanceCRE acts as a service provider (i.e., data processor) to the Publisher, who is the data controller. When AdvanceCRE provides services in the capacity of a service provider, it acts under the instructions and at the direction of such party (i.e., the data controller). In the foregoing example, if you are a Candidate who has requested Alert e-mails from one of such parties, that party will provide us with certain Personal Data about you (such as your name, e-mail address, the type of job you want, and your preferred geographic location) to ensure that the Alert e-mails meet your search criteria. If you have questions or requests about your Personal Data with respect to the Alert e-mails, we will provide you with the data controller’s contact information so that you can contact the data controller directly.
5 How AdvanceCRE Uses Data
A Use of Non-Personal Data
Where permitted by applicable law, we may use your Non-Personal Data for any purpose not prohibited by applicable law or inconsistent with this Privacy Policy or any written representation we have made to you at the point and time of the data collection.
B Use of Personal Data
We will only use your Personal Data to provide services directly to you (in our capacity as a data controller) or to provide services to you on behalf of certain hiring parties (in our capacity as a service provider/data processor), except as otherwise described in this Privacy Policy or with your consent.
In the table below, we have described (i) in what context your Personal Data was collected (i.e., what activity you were involved in when we collected or used your Personal Data); (ii) the types of Personal Data that we retain about you; (iii) how and why we use your Personal Data; and (iv) the reasons we retain and use your Personal Data. We will amend the table as needed. We have also provided you with an explanation of some of the terms we use in this table:
i “User Experience” means our goals in conducting and managing our business, to give you the best user experience when using our websites or platforms, products, and Services.
ii “Performance of Contract” means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
iii “Comply with a legal or regulatory obligation” means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
iv “Consent” means that you consent to our use of your Personal Data for one or more specific purposes. Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. You can do this by contacting us at admin@advancecre.com. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will inform you if this is the case at the time you withdraw your consent.
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CONTEXT |
DATA WE MAY RETAIN |
HOW WE MAY USE DATA |
REASONS FOR PROCESSING |
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Account Creation and Management |
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Newsletter and Marketing Communications |
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Website Administration |
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Use of Websites, Platforms, or Mobile Software |
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Online Browsing
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User-Generated Content |
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To provide you with Services that you have requested (i.e., adding your resume or CV to the Resume Database, publication of Listings, sending Applications, or distributing your content in accordance with any contract between you and AdvanceCRE) |
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Enquiries and Messaging Initiated by You |
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6 With Whom AdvanceCRE Shares Data
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow any third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions and this Privacy Policy.
A Personal Data
We may share Personal Data with the following parties:
i Internal Parties
Any of AdvanceCRE’s subsidiaries, officers, directors, employees, or agents. Access to your Personal Data will be controlled and only granted where necessary to provide our services to you or to allow us to perform any necessary or legitimate functions.
ii External Third Parties
a Service providers that we use to support our business or assist with providing our Services to you, including, but not limited to, third parties that host our websites or platforms, Services, or Mobile Software, that assist us in verifying your identity, that perform website or platform maintenance, risk assessments, and security functions, that perform data and web analytics, or that provide databases, IT services, customer service, communication services, and e-mail services. These service providers may be located in the United States or other countries (see section below entitled “Where Your Data is Transferred”).
b Professional advisers, such as lawyers, bankers, auditors and insurers that provide consultation, banking, legal, insurance, financial, auditing, or accounting services to us so that we can operate our business.
c Taxing authorities, such as the Internal Revenue Service and other authorities acting as processors based in the United States or other applicable countries, that require reporting of processing activities in certain circumstances.
d Providers of fraud-prevention and identity-verification services where we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of AdvanceCRE, our Users, or others. This includes exchanging information with third parties for the purposes of fraud detection and prevention and risk reduction.
e In connection with or during negotiations of any proposed or actual financing, merger, purchase, sale, sale, or transfer of some or all of our assets or stock, joint venture, or any other type of financing, acquisition or business combination of our company, or any portion(s) of our assets, or transfer of all or a portion of our business to another company, including, without limitation, in the event of a divestiture, restructuring, reorganization, dissolution, or other event, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding. In the event of a merger, divestiture, restructuring, reorganization, or other sale or transfer of some or all of our assets or stock, Personal Data that we retain about Users of our Services will be one of the assets that will be transferred. If there is a change of ownership with respect to our business, the new owners may only use your Personal Data in accordance with this Privacy Policy.
f Certain third parties, where you have expressly consented to the disclosure of your Personal Data.
g Law enforcement agencies, courts, supervisory authorities, regulatory bodies, and certain other third parties, to the extent that we are permitted or required to do so by law, in order to comply with our legal and regulatory obligations, in the interests of national security, or to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity.
h To enforce our Terms of Use and other agreements with you, to respond to or defend ourselves against claims asserted against us, to protect the rights, property, or safety of AdvanceCRE, our Services, Users, or others, to investigate, prevent, or take action regarding suspected or actual illegal activities, or for debt collection.
i If you are a Candidate and respond to a Listing on our websites or platforms or if you have opted to add your resume or CV to the Resume Database, we will share your Personal Data with prospective employers or their agents or representatives. You may opt out of the Resume Database at any time by updating this preference on your account.
j Upon your authorization, the Services may also post information directly to your account associated with any Connected Sites.
k From time to time, we may run contests, special offers, or other events or activities ("Events") on our Services together with a third-party partner. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use that you approve. We cannot control third parties' use of your information. If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these Events.
l For any other purpose disclosed by us when you provide the information or with your consent.
B Non-Personal Data
Where permitted by applicable law, we may share your Non-Personal Data for any purpose not prohibited by applicable law or inconsistent with this Privacy Policy or any written representation we have made to you at the point and time of the data collection.
7 Where Data is Transferred
AdvanceCRE LLC is headquartered in the United States of America (USA). The information that you provide or that we collect as a result of your interaction with the websites or platforms or your use of our Services is transferred to the USA or to another country where we have affiliates or where we have engaged service providers. As a result, your Personal Data may be subject to data protection and other laws that may differ from your country of residence. Your Personal Data may be disclosed in response to inquiries or requests from governmental or regulatory authorities in the countries in which we or our service providers operate.
8 How Long Data is Stored
Different retention periods apply for different types of Personal Data and, in determining the appropriate retention period, we consider several criteria, including, but not limited to, the purpose for which we retain your Personal Data, our legal, accounting, reporting, or regulatory obligations in relation to that Personal Data (e.g., financial or tax reporting obligations, whether our relationship with you is ongoing, any specific request you may have made with respect to the retention of your Personal Data, or where we have a legitimate interest in relation to the management of our own rights). In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with AdvanceCRE, we will retain and securely destroy your Personal Data subject to the foregoing and in accordance with applicable laws and regulations. If you indicate that you do not wish to receive further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
9 Data Subject Access Rights
A Data Subject Rights
i Depending on applicable law, you may have the following rights with respect to your Personal Data:
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Your Rights |
What You Can Request |
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Right to Information |
An explanation of which Personal Data we retain about you and how we use it. |
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Right of Access |
To be provided with a copy of your Personal Data (subject to certain restrictions). |
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Right of Rectification |
That we correct any incomplete or inaccurate Personal Data we retain about you, though we may need to verify the accuracy of any new data that you provide to us. If you have a User account with us, you may also correct your information directly in your account. |
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Right to Withdraw Consent at Any Time |
You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will notify you if this is the case at the time you withdraw your consent. |
ii If you have any complaints about how AdvanceCRE handles Personal Data, please send an email to admin@advancecre.com. We welcome the opportunity to help you with any concern or questions you may have about the use of our services, and we will respond to your request within a reasonable timeframe.
iii For Users located in Nevada: Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit such a request to admin@advancecre.com. However, please note that AdvanceCRE does not currently sell data triggering the opt-out requirements under Nevada Revised Statutes Chapter 603A.
B Procedure for Requesting Information
i If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to admin@advancecre.com, with your specific request. We will respond to your request within a reasonable timeframe.
ii You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances and, in such case, we will notify you within a reasonable timeframe regarding our reasons for refusing to act on your request.
iii Once we receive your Access Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access the Personal Data requested (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person without a right to access it. If we are not clear as to what you are requesting, we may also need to contact you for clarification so that we can more fully respond to your request. If we cannot locate any records about you, we may also ask you for additional information to assist us in locating records, if such records exist.
iv We try to respond to all legitimate requests within the timeframes required under applicable law. Occasionally, it may take us longer than the time period required under applicable law if your request is particularly complex or if you have made a number of requests. In this case, we will inform you of the reason for delay.
C Deleting a User Account
If you would like to delete your account, you may do so through your account settings or you may send an email to admin@advancecre.com and request that your account be deleted. If you close or delete your account, we may still retain certain information for analytical purposes and record-keeping integrity, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary pursuant to technical and legal requirements, and as dictated by constraints related to the security, integrity, and operation of our Services.
10 California Privacy Rights
California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes unless we provide them with an ability to exercise choice regarding such disclosures. We comply with this law by providing California residents with the ability to opt out of, or prospectively withdraw their consent if they have previously opted into, the disclosure of personal information to third parties for direct marketing purposes. If you are a California resident and wish to receive confirmation of how we comply with this law, make a request, or opt out at any time, please contact us at admin@advancecre.com or by mail at the address provided below. Any request must include “California Privacy Rights Request” in the first line of the description, as well as the name, street address, city, state, and ZIP code for the person making the request.
11 Marketing Communications
We may use your Personal Data to send you information about the services provided by AdvanceCRE if we first obtain consent to do so where required by applicable law. You may unsubscribe from our marketing e-mails by clicking "unsubscribe" in any promotional e-mail communications that we have sent to you. As permitted by applicable law, you may not opt out of non-marketing notices that pertain to the Services.
12 Cookies and Tracking Technologies
A AdvanceCRE and third parties may use cookies or similar tracking technologies (e.g., pixels, beacons, scripts, etc.) (“Tracking Technologies”) to analyze trends, administer the websites or platforms, track Users’ movements around the websites or platforms, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level but, if you choose to disable cookies, it may limit your use of certain features or functions on our websites or platforms.
B If you are accessing the websites or platforms from a location outside the EEA or U.K., you understand that we apply U.S. law and the U.S. advertising industry self-regulatory program to Tracking Technologies associated with the websites or platforms.
C We may partner with third parties to display advertising on our websites or platforms or to manage our advertising on other sites. Our third-party partner(s) may use cookies or similar technologies in order to provide you with advertising that is based upon your browsing activities and interests. If you wish to opt out of any interest-based advertising, you may contact us at admin@advancecre.com. Please note that you will continue to receive generic ads.
D We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your mobile device. This software may record information such as how often you use the Mobile Software, the events that occur within the Mobile Software, aggregated usage, performance data, and the website from which the Mobile Software was downloaded.
E To the extent permitted by applicable law, we may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure that you receive proper notifications, we will need to collect certain information about your device, such as operating system and user identification information.
F Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. AdvanceCRE websites or platforms, Services, and Mobile Software do not currently support Do Not Track requests at this time.
13 Data Security
A We use appropriate technical and organizational measures to protect Personal Data that we process or retain. However, we cannot guarantee that any transmission of information via the Internet or wireless network will be absolutely secure. As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations relative to the Internet that are beyond our control and, accordingly, the security, integrity, and privacy of data exchanged between you and AdvanceCRE through the websites or platforms cannot be guaranteed. We have implemented procedures for dealing with any suspected breach of Personal Data and will notify you of a breach where we are legally required to do so.
B The safety and security of your Personal Data is also dependent on you. Where we have given you (or where you have chosen) a password for access to certain parts of our websites or platforms, you are responsible for keeping this password confidential. We encourage you not to share your login or account credentials with anyone and to keep your account information secure. We urge you to be careful about giving out information in public areas of the websites or platforms, like message boards, where information will be available to other Users. If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.
14 Links to Third-Party Sites or Social Media Features
A Our websites or platforms may, from time to time, contain links to third-party services such as websites, locations, platforms, or applications operated by third-parties. If you follow a link to, or otherwise access, any of these third-party services, these third-party services may use their own cookies, web beacons, or other Tracking Technologies to independently collect information about you and may solicit Personal Data from you. Please note that these third-party services have their own privacy policies and we do not accept any responsibility or liability for these parties’ policies or practices. Please check these policies before you share any Personal Data with these third-party services.
B We may offer you the opportunity to connect one or more of your social media account when interacting with our websites and platforms. If you do so, please be aware that you may be sharing your profile information with us. The Personal Data that is shared will depend on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your Personal Data is shared and used in this context.
C Social media features may also collect your IP address and information regarding which pages you visit on our websites or platforms, and may set a cookie or other Tracking Technologies to enable the applicable social media feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing such features.
D The websites or platforms may include tools provided by us or third-parties that enable you to send a message to another User. If you utilize any such tools, please ensure that you only contact Users to whom you have permission to send messages. Absent the recipient’s consent, we will only use whatever Personal Data about that User is provided to use by you and is necessary to facilitate such messages.
15 Public Forums
You should be aware that when you voluntarily disclose any Personal Data in a public forum on the websites or platforms, this information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Privacy Policy does not apply to such information. You accept that you, and not AdvanceCRE, are responsible for providing such information in any public forum. Any submissions on public areas on the websites or platforms are posted by you with the understanding that such forums are accessible to all third parties. If you do not want your comments or content to be viewed by third parties, you are advised not to make any submissions. Please be careful and responsible.
16 Invitation Service
A If you choose to invite a friend to use our Services, we will provide you with a link to share with your friends or spread the word on Linkedin, Facebook, or Twitter. We provide you with a unique link ID so that you earn credit for each friend that joins the site by following your link, where applicable. Your friend may contact us to request that we remove this information from our database at admin@advancecre.com.
B If you wish to invite a friend to view our blog posts, we may ask you for that person's email address and automatically send an email invitation. AdvanceCRE may store this information to send this email, to register your friend if your invitation is accepted, and to track the success of any invitation service. Your friend may contact us to request that we remove this information from our database at admin@advancecre.com.
17 Minors and Children
Our Services, websites or platforms, and Mobile Software are not intended for use by persons under the age of eighteen (18) years old. AdvanceCRE does not knowingly collect or solicit Personal Data from anyone under the age of thirteen (13) years old or knowingly allow such persons to register to use our Services, websites or platforms, or Mobile Software. In the event that we learn that we have collected Personal Data for a child under the age of thirteen (13), we will delete that data to the extent required by applicable law as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of thirteen (13), please contact us at admin@advancecre.com.
18 Changes to the Privacy Policy
We reserve the right to change this Policy at any time. If we intend to make any material changes, we will notify you by posting a notice on the websites or platforms, or by circulating an e-mail to the e-mail addresses provided by registered Users before the changes become effective. You acknowledge that it is your responsibility to maintain a valid e-mail address as a registered User and to review the websites or platforms and this Policy periodically in order to be aware of any modifications. If you object to any changes to the revised Policy, you can stop using the Services and close your account with us. However, if you continue to use the Services (including the websites or platforms and the Mobile Software) after we publish a new or updated Policy, you acknowledge that such continued use means that the treatment of your Personal Data will be subject to the new or updated Policy.
19 Questions or Complaints
If you have any questions regarding our Personal Data practices, or would like to unsubscribe, please contact us at the addresses below.
Via mail: AdvanceCRE LLC
1124 Rexford Drive
Los Angeles, CA 90035
Via e-mail: admin@advancecre.com