Last updated Feb 27, 2012

INTRODUCTION

AGENTSHQ TAKES PRIVACY SERIOUSLY. Please read the following to learn more about our privacy policy ("Privacy Policy"). This Privacy Policy applies to the use of AgentsHQ (as defined below), including by both consumers and real estate professionals (real estate professionals including, without limitation, REALTORS® , agents, providers of moving-related services, products or information, homebuilders, lenders, brokers, remodelers, home service professionals and other non-consumer service professionals, are referred to as "Professionals"). Except as otherwise indicated, Professionals, consumers and other persons using AgentsHQ are individually and collectively referred to as "you", and Refina LLC. and its subsidiaries and affiliates are referred to as, "AgentsHQ", "we", "us" and "our." We use AgentsHQ to provide you with information, resources, tools, products and services specific to the real estate industry and related markets, and to provide you with information about us and our advertisers, and our respective products and services.

AgentsHQ operated on behalf of Refina LLC are committed to implementing policies and procedures designed to protect your privacy and security, in addition to providing you with the best possible online experience. To that end, we want you to understand what kinds of information we gather about you, how this information, particularly Personal Information (defined below), is used and safeguarded, and how you can control its use.

WHAT INFORMATION IS COLLECTED FROM ME?

Information You Give Us: Information collected from you will vary, depending on how you use AgentsHQ and what information you may choose to provide to us (whether through email or otherwise). It may be possible to browse various sections of AgentsHQ without submitting any personally identifiable information. Personally identifiable information ("Personal Information") means individually identifiable information about you that we collect online, including, but not limited to, your full name, a user name and password, email address, phone number, physical address, financial information, and for certain e-commerce transactions your credit card information. Information in a form that is aggregated with other information so as not to be reasonably identifiable with you, and information in a form that otherwise is detached, combined, organized, segmented, modified or processed so as not to be reasonably capable of being associated with you, will not be considered Personal Information, and will not be restricted by this Privacy Policy as to use, sharing or otherwise. If you choose to take advantage of some of our products and/or services, or to access certain of our tools or AgentsHQ functionality, you may be asked to provide Personal Information. For certain Professionals, you may also be requested to provide your license or MLS ID#. Whenever we ask for Personal Information, we strive to provide a link to this Privacy Policy to help you understand how Personal Information will be used before you decide whether to disclose it. You can choose not to provide us with Personal Information, but then you may not be able to fully take advantage of certain features of AgentsHQ and we may not be able to provide you with certain requested information, products and/or services.

Automatic Collection of Information: Like many Web sites on the Internet, we automatically track certain information about you as you visit and use AgentsHQ to help us (i) better understand, improve and modify AgentsHQ, (ii) better understand how AgentsHA is used and experienced and (iii) better understand how we can enhance your or others overall experience on one or more of the sites, including providing advertising and other information that is relevant to you. This tracked or automatically gathered information may include, among other things, your computer's IP address (Internet Protocol address), the URLs and AgentsHQ pages you've visited, sections of or content on AgentsHQ pages on which you click or in which you are interested, the number of times you visit AgentsHQ page, what downloads and/or search queries you have made, how long you spent on AgentsHQ, and your browser type. This automatically gathered data includes information provided through the use of "cookies" (which is described in more detail below).

Information from Cookies: Cookies are small files that we send to and store on your computer so that we can recognize it as a unique machine the next time you visit AgentsHQ. You are always free to decline any cookies we use if your browser permits. Some of our advertisers and third-party service providers may also utilize their own cookies. In addition, we and our service providers sometimes use "clear GIFs" in connection with cookies and other website functions. Clear GIFs perform administrative functions without detracting from your online experience. They may be used to perform statistical and administrative tasks including measuring site and page traffic, verifying advertising avenues and positioning images on the web. Clear GIFs are not designed to collect Personal Information.

INFORMATION SHARING DISCLOSURE - HOW IS INFORMATION ABOUT ME USED AND SHARED?

The use of information about you depends on the context in which it is collected. Therefore, pay special attention to the categories below that relate to the features of AgentsHQ that you wish to utilize.

Personal Information

We may share the Personal Information we collect from you only with your consent or under the following circumstances.

User-Requested Services and Information: Certain features, products or services of AgentsHQ may seek Personal Information from you, which may be used in the following ways:

For information, features, products and services provided by AgentsHQ, the information you submit is used by us to provide the information, feature, product or service you've requested. We may also share this information with others, but Personal Information will be shared only to fulfill your request or to facilitate your use of the information, features, products or services, or as otherwise outlined in this Privacy Policy. When sharing Personal Information in such a manner, we may also share your Internet Protocol (IP) address. In addition, we may use and share any registration information that you submit as set forth in the "Registration Information" section below.

We may use other companies and individuals (1) to perform supporting functions for the various tools, functionality, information, products and services offered through AgentsHQ on our behalf, (2) to perform or support various tasks or initiatives instrumental to the business of, or related to operating or improving, AgentsHQ or (3) to assist us in testing, maintaining or improving the features, content or effectiveness of AgentsHQ or in performing research or development. These service providers may be permitted to receive from us and use information collected from you but will not be authorized by us to use Personal Information for any other purpose other than in connection with performing the support functions for Refina LLC or such other tasks, initiatives or assistance for AgentsHQ.

For information, features, products and services marketed or offered to you jointly or on a coordinated basis by us and a third party, Personal Information may be shared with or independently gathered by the third party. In these situations, Refina LLC will use Personal Information only to facilitate such information, features, products and services (or information about them) being made available to you or as outlined in this Privacy Policy, but the third party may use the information in different ways. You typically can tell when information, features, products or services are marketed or offered jointly or in coordination with a third party because a page or area of AgentsHQ often will be "co-branded" in such cases, will display the third party's logo and/or name (whether or not along with our own), will describe or reference the relationship between Refina LLC and the third party or will be set up so that you can contact or be linked to the third party or its Web site to initiate, complete or learn more about the transaction. Please be aware that each company we do business with has its own policies regarding its use, sharing and protection of information about you and that such policies may differ from those outlined in this Privacy Policy.

User-Initiated Communication: From time to time, portions of AgentsHQ may enable you to send email and other types of messages to us or to third parties and to participate in bulletin boards and discussion groups. All such emails and messages, and all such postings to bulletin boards and discussion groups, become our property once you submit them. Your Internet Protocol (IP) address may be included in any email that you send, whether to us or to third parties. Whenever you choose to initiate these kinds of communication with us, or anyone else, you may be contacted in return. Also, remember that our bulletin boards and discussion groups are open to the public, and, therefore, your postings can be seen by anyone and are not protected by us or any other entity. Please use your own discretion when deciding whether and what to post and whom to contact. We reserve the right, in our sole discretion, to edit or delete postings from our bulletin boards and discussion groups. This reservation of rights shall not under any circumstances obligate us to conduct such edits or deletions, nor shall it cause us to be liable for any such edits or deletions.

Referrals: If you participate in any referral service we may offer:

Consumers: We may use the information you submit to determine which of our participating Professional(s) may be able to serve your needs. We may forward information relating to you, which may include Personal Information obtained through our sign-up form or otherwise, to certain Professional(s). Those Professionals or their designees may contact you regarding your needs.

Professionals: You might receive information from, or originating from, consumers seeking your products or services or related information. These information submissions or related inquiries or leads might include, without limitation, Personal Information. Because protecting personal privacy is important, we require that you treat data received from Refina LLC consumers as if it was still on AgentsHQ and in accordance with this Privacy Policy. You may only use the information sent to you via AgentsHQ for the purposes of providing the consumer products and/or services about which the consumer inquired. We require that you not make any other use of any such data and that you otherwise not share or transmit this information with or to any third party without the consumer's consent.

Protection of rights: We will release Personal Information or other information we collect from you if we believe that such action is appropriate to: (1) comply with legal process; (2) enforce the Terms of Use agreement for the applicable AgentsHQ; (3) identify, contact or bring legal action against persons or entities who are or we believe have caused or might cause injury to us or a third party, (4) defend or respond to claims brought or threatened against Refina LLC, its employees, directors, suppliers or service providers, AgentsHQ users or others or (5) otherwise protect or assert the rights, property, interests or personal safety of Refina LLC, its employees, directors, suppliers or service providers, AgentsHQ users or others. Any such release decisions may be made by us in our sole discretion.

Asset transfers: We continue to develop our business and in doing so might choose to buy or sell businesses or assets. Personal Information and other information we collect from you is generally one of the assets acquired or transferred in such transactions.

Registration Information: The Personal Information you provide when you become a registered user or customer of AgentsHQ is used primarily to help us customize or enhance your or others' online experience, increase the convenience of accessing new or existing tools, products and services, and, if applicable, provide the information, features, products and/or services you purchase or request. This Personal Information may also be shared among AgentsHQ to make use of AgentsHQ more convenient by, for example, limiting the number of times you have to register with us. Your email address serves as a unique identifier in our record system, and together with your password is designed to help us prevent unauthorized access to information you choose to store on AgentsHQ. The data you give us about your personal preferences and demographics (e.g., your age, ZIP code, occupation or the like) may be used to help us offer content, advertisements, products, and services that we believe will be of interest to you. In addition, we may share this information, in aggregate or other protected form (see "Information You Give Us," above) or under confidentiality terms, with our current and potential advertisers and service providers so that they, or we, can present and deliver advertisements more effectively. If you forget your password for any registered area of AgentsHQ, we have an automated password recovery system, which can be accessed by clicking on the "Forgot Password?" link on the sign-in page.

Consumers: Unless you specify that you'd prefer not to hear from us, we may use the email address you provide at the time of registration to contact you for promotional or other purposes. You may have these communications terminated at any time by opting out through your member profile on AgentsHQ, or by clicking on any "unsubscribe" link contained in a promotional email. Please be aware that opting out or canceling, may not opt you out from all newsletters or mailings unless that option is specifically provided. If you would like to request to opt out with respect to all of mailings please email privacy@agentshq.com with your requests.

Professionals: We may offer a newsletter, electronic flyer or similar material to keep you abreast of the products and services on AgentsHQ or other professional products and services. Information such as your license number or personal financial information will not be shared with third parties except to complete a transaction or as outlined in this Privacy Policy.

When sharing Personal Information in accordance with this Privacy Policy, we may also share your Internet Protocol (IP) address.

Non-personal Information

Automatically Gathered Information: Information that is automatically gathered, including through the use of cookies, may be shared with other third parties, including listing providers, advertisers, service providers and others, so that we may better understand how AgentsHQ is used, to enhance the overall experience on AgentsHQ and otherwise in connection with our operation of AgentsHQ and conducting related business. But when so shared with third parties, any Personal Information will be included only if first put in aggregated or other protected form (see "Information You Give Us," above) or the third party will be contractually restricted from using such Personal Information for any purpose other than in connection with the purpose for which it was shared by Refina LLC.

HOW CAN I ACCESS AND CHANGE PERSONAL INFORMATION?

To view, edit or delete the Personal Information that you submitted on AgentsHQ during registration or during the purchase of a product or service, or that you otherwise submitted as described above:

Consumers and Professionals: Follow the instructions found in the "My Account" area of AgentsHQ where you registered or submitted Personal Information. If you would like us to no longer use or share with our affiliates, partners or other service providers, Personal Information we may gather from you to market information to you, please send a request to Privacy@agentshq.com.

Any change you request regarding Personal Information may adversely affect or otherwise change the availability, deliverability or quality for you of information, features, products or services in which you are interested or your experience on or relating to the AgentsHQ.

HOW IS PERSONAL INFORMATION PROTECTED?

Whenever Personal Information is stored on our computers (which may be for an indefinite period, or a more limited time based on obsolescence or other factors), that information is protected from unauthorized access or use by way of passwords or other industry-acknowledged means. In addition, servers of ours that store this information are located behind a firewall. Since your financial information and certain other Personal Information is especially sensitive, we take special care to keep it secure. We will only electronically transmit or ask for this information over secure Internet connections using SSL (Secure Sockets Layer) encryption, an accepted standard for online security, and security keys. In addition, we require password authentication from any third parties you have authorized to receive this information. Finally, to the extent that we may ask for and will store for a period of time Personal Information consisting of your credit card number or financial information, this information will be stored on secure designated servers where access is limited to individuals in departments charged with using such information only in connection with processing your orders and/or payment for products and services purchased; provided, however, that those orders and/or payments processed by our business partners, marketing allies and/or service providers that provide or participate in providing the service or product requested or participate in the payment process may store such information on their servers which are governed by such third party's privacy policy and security procedures.

Of course, we appreciate your help in safeguarding the integrity of your own and others' privacy. We hope you'll use common sense whenever you disclose Personal Information over the Internet. Just as importantly, we encourage you to let us know immediately if you suspect that Personal Information you share with us is being used in any way contrary to this Privacy Policy. Finally, unfortunately no data transmission over the Internet nor any storage of information on servers or other media can be guaranteed or made to be 100% secure; and while we strive to protect Personal Information, as outlined in this Privacy Policy, we cannot promise, guarantee or warrant the complete security of information. To contact us, please send an email to: privacy@agentshq.com.


EFFECTIVE DATE AND MODIFICATIONS

This Privacy Policy is effective as of the date first written above and may be updated and modified from time to time by us in our sole discretion. If we choose to update or modify this Privacy Policy, such updated or modified policy shall become effective five (5) business days after its posting. Accordingly, we encourage you to periodically review this Privacy Policy in order to keep apprised of our current privacy practices. If you do not agree to any provision of this Privacy Policy, or any update or modification of it, please do not use AgentsHQ.

CONTACTING US

If you have concerns about this Privacy Policy or our privacy practices in general, contact us at:

Privacy Administrator
Refina LLC
230 Franklin Rd, Suite 12Q
Franklin, TN 37064
Email: privacy@agentshq.com