Effective 10/1/2019

Team Pulte, Inc. (“Team Pulte” in this Privacy Policy) respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how Team Pulte handles your personal information after receiving it.  This Privacy Policy governs Team Pulte use of your information both on the Team Pulte website (www.teampulte.com)

Please read this Online Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

This website is not intended for children and we do not knowingly collect data relating to children.

1. Types of Information Collected and Stored

1. Personal Information Summary.

When you engage in activities such as sign up to receive a Team Pulte publication, make donations to Team Pulte, shop on our website, or otherwise use the Team Pulte website, Team Pulte may gather your personally identifiable information (“Personal Information”).  

Your Personal Information may generally include, but is not limited to, your name, address, phone number, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Team Pulte or its authorized agents.  

By using the Team Pulte website, you agree to allow Team Pulte and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

2. Specific types of data we collect about you.  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data.  When you use the Team Pulte website to shop or to make donations to Team Pulte, Team Pulte utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Team Pulte concerning your payment.  Team Pulte and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information.  Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant.  Team Pulte does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary.  For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.  
4. Transaction Data includes details about payments to and from you and other details of Team Pulte products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, browser type and version, 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 this website.
6. Profile Data includes your Team Pulte donations, Team Pulte purchases or orders made by you, your interests, preferences, feedback and survey responses where applicable.  
7. Usage Data includes information about how you use the Team Pulte website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9. Aggregated Data / Analytics Information.  We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Team Pulte website, Team Pulte gathers this Aggregated Data related to individuals’ website visits.  This information is used solely to measure and improve our website and services and to better serve our members and customers.  Team Pulte uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Contact Data, Technical Data, and/or Marketing and Communications Data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:  

1. Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.
2. Non-personal information, such as language, zip code, area code, location, and the time zone.
3. Team Pulte website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Team Pulte website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.

3. Sensitive Information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. Cookies and Browser “Do Not Track” Notice

1. Team Pulte may use cookies on your computer.  A cookie is a small piece of data sent from a website and stored in a user's web browser while the user is browsing that website.  Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user's previous activity.  Third parties that advertise on the Team Pulte website do not have access to Team Pulte cookies, but they may use their own cookies on your computer.  Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies.  Team Pulte does not correlate its use of cookies with your Personal Information.  Please see our cookie policy at https://teampulte.com/cookie-policy/
2. Team Pulte does not respond to browser Do Not Track (“DNT”) Signals.   Team Pulte websites may utilize page tags or web beacons to track information related to user visits as a part of Team Pulte data analytics processes and user experience customization as described below.  Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website.  Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website.  Such technologies enable us to improve and customize user experiences while users visit our website.  Team Pulte does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.  
3. Team Pulte may employ third party data analytics firms to track and analyze traffic on the Team Pulte website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking.  Team Pulte’ third party analytics firms, as described in this section, do not receive your Personal Information.
4. Third parties that may advertise on Team Pulte websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Team Pulte website.  Such information may contain a visitor’s IP address.  Third parties may not collect identifying Personal Information from the Team Pulte website unless you provide it to such third parties.  
5. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5. Keeping Information Updated

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

2. Security of Personal Information

Team Pulte takes the security of your Personal Information very seriously.  When your Personal Information is stored by Team Pulte, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure.  While Team Pulte will use all reasonable means to protect your Personal Information, Team Pulte cannot guarantee the security of your transmissions of such Personal Information, and you use the Team Pulte website at your own risk.  If you suspect your Personal Information has been compromised, please notify Team Pulte Customer Service using the contact information provided below.  

3. How we Collect Your Personal Information.  We use different methods to collect data from and about you including through the following methods.  

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us feedback or contact us.

2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3. Technical Data from the following parties:

1. analytics providers such as Google;
2. advertising networks; and
3. search information providers.

4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
5. Identity and Contact Data from data brokers.
6. Identity and Contact Data from publicly available sources.

4. How Team Pulte Uses and Shares Your Information

1. General Information and Your Rights.  Team Pulte limits its use of your Personal Information to the stated purposes for which such information is collected.  In some cases, Team Pulte may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  You have the right to the following regarding your Personal Information transferred to Team Pulte:  

1. To know the types of Personal Information Team Pulte collects;
2. To know the purposes for which it collects and uses your Personal Information;
3. To know type or identity of third parties to which Team Pulte discloses your Personal Information, and the purposes for which it does so;
4. To access and update your Personal Information; and
5. To know the choices and means Team Pulte offers you for limiting the use and disclosure of your Personal Information.

2. Team Pulte Services to Team Pulte ID Holders.

When using the Team Pulte Website, you may have opportunity to create a Team Pulte ID.  When you create a Team Pulte ID, we may use information collected from technologies such as cookies, web beacons, and page tags, as described herein, to improve your experience of our website.  For example, by saving information concerning the pages you visit and products you purchase, we will be able to provide you with information on other Team Pulte goods and services that may be of interest to you. Furthermore, by creating an account with Team Pulte, there is a possibility of receiving content from third parties through Team Pulte, as discussed under Section 4.5, below.  

Based on the information we gather, we may use targeted advertising from third party vendors, customized to reflect your interests.  For example, if you purchase certain materials from Team Pulte, Team Pulte may display advertisements from vendors of similar materials.  To accomplish this, we may use cookies and other technologies in order to recognize your computer at the time we display an advertisement to you.  Team Pulte may tailor advertisements based on your use of our website, such as tracking the pages you visit, the searches you make, or the goods or services your purchase.   Team Pulte does not correlate activities described in this section with your Personal Information, and we will not provide advertisers with your Personal Information when you view a targeted advertisement.  However, through your interaction with a targeted advertisement, you consent that an advertiser may infer that you meet certain targeting criteria for the display of the advertisement.  

In creating a Team Pulte ID, and as a condition of having a Team Pulte ID, you expressly consent to Team Pulte’ use of your Personal Information and non-personally identifiable information as described in this section.  Moreover, in using a Team Pulte ID you expressly acknowledge and agree to our collection and use of such information as described in this section.

You can opt-out of the use of your Personal Information as described in this section by deleting your Team Pulte ID.  To delete your Team Pulte ID, please contact Team Pulte Customer Service using the contact information provided below.  

3. Other Team Pulte Services.

Team Pulte may use your Personal Information to provide services to you upon your request.  Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Team Pulte website, emailing you updates concerning Team Pulte products and services, and personalizing your visits to Team Pulte website.  

You may opt-out of the use of your Personal Information as described in this Section by contacting Team Pulte Customer Service using the contact information provided below.  

4. Team Pulte Internal Data Sharing 

Team Pulte may also share your Personal Information with other Team Pulte offices or Team Pulte subsidiaries in the country in which you reside and in other countries.

5. Information Sharing with Third Parties

1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. Team Pulte may utilize third-party service providers that process your Personal Information solely on Team Pulte’ behalf (“Agents”).  When Team Pulte transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes.  Team Pulte will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the Principles.  Team Pulte remains responsible and liable if the Agents that Team Pulte engages to process your Personal Information on Team Pulte’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Team Pulte proves that it is not responsible for the event giving rise to the damage.
3. Team Pulte may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.
4. Team Pulte uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services.  All parties with which Team Pulte shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.
5. Team Pulte may partner with third parties to provide other specific services, including, but not limited to registration for Team Pulte conferences and other Team Pulte programs and educational materials.  When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services.  Team Pulte may auto-populate forms utilized by these third parties with data contained in Team Pulte managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services.  All parties with which Team Pulte shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.

6. Other Possible Disclosures.

In addition to the other disclosures stated herein, Team Pulte may share your information in the following ways:

6. To comply with applicable laws, regulations, legal processes, or government enforced orders,
7. To enforce applicable terms of service, protect our legal rights or defend against legal claims,
8. To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,
9. To guard against harm (whether actual or potential) to the legal rights, property or safety of Team Pulte, our visitors or the general public as required or permitted by law.

5. Team Pulte Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or member.	(a) Identity (b) Contact	Performance of a contract with you
To register you for Team Pulte events and programs.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e)  Financial (f)  Transactional	a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services)
To process and deliver your order including: (a) Manage donations, payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c)  Managing Team Pulte member services.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e)  Financial (f)  Transactional	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products / services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products / services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products / services and grow our business)

6. How to Access or Change Your Personal Information

1. To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may make changes and updates by logging into your user profile and making such changes.  Alternatively, you may request such changes by contacting Team Pulte Customer Service using the contact information provided below.  
2. In your request, clearly state what information you would like to have changed or updated.  Team Pulte will try to comply with your request as soon possible.
3. The deletion of Personal Information and other changes to the data retained by Team Pulte as described above may result in the deletion or limitation of other services Team Pulte provides. Team Pulte may retain certain Personal Information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce agreements.

7. Notices of Changes to Privacy Policy

In the event of any change to the Team Pulte Online Privacy Policy, notice of such changes will be posted on the Team Pulte website.  Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Team Pulte website. Your use of the Team Pulte website following these changes means that you accept the revised Online Privacy Policy.

8. Contact Team Pulte

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Team Pulte Customer Service
info@teampulte.com