Last Revised: September 29, 2016
Lucro Global, LLC ("Lucro", "we", "us" or "our") values you as a user and recognizes that privacy is
Please note that information submitted to the Service via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.
The Service may provide you the opportunity to submit a variety of information, such as property descriptions, data, assumptions, financial models, photographs, videos, questions, comments, suggestions or other content in connection with a project (collectively, "User Content"). If you choose to share User Content such as a project through the Service, the recipient may be able to re-share the content, and that ability will not be subject to your control or Lucro’s control. Lucro is not responsible for your choice to share User Content or another user’s choice to re-share your User Content.
If you receive a project on the Service and add that project to your Lucro account, the user who originally shared the project will be able to see that you added the project to your account but will not be able to see any changes you made to the project. For example, if a broker shares a project with you, the broker could see that you accessed the project, but would not receive information about the changes you made to the financial model, unless you consent to such sharing. Please note that the user who originally shared the project may not be the person who sent you the project. For example, your colleague may have copied and pasted the link to the project into an email to you, even though the broker originally shared the project; in this scenario, the broker, not your colleague, would be able to view that you accessed the project.
Additionally, the Service may enable users to communicate or interact with each other. If you choose to connect to or “trust” another user on the Service, that user may be able to view certain information about you, including Personal Information (such as your full name and contact information).
We may aggregate your User Content such as your project information (other than content that would identify you or the project) into Lucro’s broader data pool and share it with Lucro’s users or third parties. For example, we may aggregate project data to calculate the average cap rate for projects in a given metropolitan area.
If you contracted directly with Lucro to access the Service, Lucro provides you with the option of whether to aggregate your User Content. The default setting is to opt-in to User Content aggregation; thus, if you make no choice, your User Content will be aggregated. You can choose to opt-out, but that may result in you being unable to use certain features of the Service. To opt-out, you must [ADD OPT-OUT INSTRUCTIONS]. Once your User Content has been aggregated into Lucro’s data pool, it cannot be removed, even if you delete your account. If you have opted-in to aggregating your User Content into Lucro’s data pool and later choose to opt-out, Lucro will no longer aggregate your User Content that is created after you opt-out.
If your company has provided you with access to the Service, your company will control whether your User Content will be aggregated into Lucro’s data pool, and you will not receive the option whether to aggregate your User Content.
We may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from Lucro, that website will forward your contact and other information to us so that we may contact you as requested.
In addition to any Personal Information or other information that you choose to submit to the Service, we and our third party service providers, including any third party content providers, may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Service ("Usage Information"). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Service, the search terms you entered into a search engine that lead you to our Service (if applicable), all of the areas within our Service that you visit, and the time of day you visited the Service, among other information. We may use Usage Information for a variety of purposes, including enhancing or otherwise improving the Service and our products and services. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device (any, a “Device”) you may use to access the Service. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
The methods that may be used to collect Usage Information include the following:
Cookies. A cookie is a data file placed on a Device when it is used to visit a Service or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. A Flash cookie is a data file placed on a Device via the Adobe Flash plugin that may be built-in to or downloaded by you to your Device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies or to adjust your Flash privacy settings on your Device, some features of the Service may not function properly.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
You also may request, sometimes through your use of an interactive feature or third party application, that we share information about you or one of your projects with a third party and we will typically do so under those circumstances. Once you have chosen to share information with a third party, you may not ‘un-share’ that information.
If your company has provided you with access to the Service, we may share any and all information about your use of the Service, including your Personal Information and Usage Information, with your company or its agents.
We may use third party vendors to perform certain services on behalf of the Service, such as providing consumer affairs services, fulfilling and processing orders and payments, tracking Service analytics, or performing other administrative services. We may provide these companies with access to user information, including Personal Information, needed to perform their functions. They may transfer this information to third parties where required to do so by law, or where such third parties process the information on the service providers’ behalf, but are not permitted to share or use such information for any other purpose.
Lucro may share Personal Information with its parent, subsidiaries and affiliates, primarily for business and operational purposes. Lucro also reserves the right to disclose and transfer all information related to the Service, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Lucro’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.
Although the Service currently does not display ads from third parties, Lucro works with network advertisers, ad agencies, third party traffic measurement services and other vendors to provide us with information regarding traffic on the Service, to serve our advertisements on other websites, within third party applications, and across the Internet, and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. For example, if you clicked on a Lucro advertisement that led you to our Service, our service provider(s) may be able to tell us which Lucro advertisement you clicked on and where you were viewing the advertisement. In connection with providing analytics and advertisement services, our service providers may collect certain information about your visits to this or other websites. We do not share Personal Information with these service providers, but they may set and access their own tracking technologies on your Device (including cookies and web beacons) and may otherwise collect or have access to information about you (such as your general interest in real estate and Usage Information). Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, you may wish to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, including the “opt-out” procedures of NAI members.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may update your contact information using the “My Account” section of the Service. If your company has provided you with access to the Service, your company or its agents may also change your information and preferences.
Lucro will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. Note, however, that information may persist internally for Lucro’s administrative purposes and that residual data may remain on backup media or for other reasons. Also, if you have made any public postings on the Service, such as in a Community Forum, these communications generally will not be removed.
You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) and these transactional account messages may be unaffected if you opt-out from marketing communications.
Lucro takes commercially reasonable security measures to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information such as a credit card number and CVC2 number on our checkout forms, that information is encrypted using secure socket layer (SSL) technology, to help protect the communications between you and our payment partners.
However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect. You use our Service and provide us with your information at your own risk.
The Service is not intended for users under the age of 18 and the Service does not knowingly collect Personal Information from users under the age of 18. If Lucro discovers that it has inadvertently collected Personal Information from anyone under the age of 18, it will delete that information.
The Service is operated in the United States. If you are visiting the Service from outside the United States, please be aware that information we collect will be transferred to, stored, and processed in the United States. By using the Service, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Attn: Privacy Officer
Lucro Global, LLC
321 North Clark Street
Chicago, IL 60654