At Plum, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Plum. This policy explains our privacy practices for Plum.com (which we’ll refer to as the “Site”) and other services provided by Plum CoOwnership, Inc. dba Plum (“Plum,” together with “we,” “us,” and “our”). We’ll refer to the Site and our other services as the “Services.” This policy does not apply to the practices of third parties who may also collect or receive data in connection with your use of the Services.
This policy was published on August 15, 2021.
By using the Services, you acknowledge that Plum will use your information in the United States, and any other country where Plum operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the “Transfers” Section of this policy.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our vendors and suppliers that help provide Plum services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. Plum uses the personal information it receives and collects in accordance with the purposes described in this policy.
Registration, Account Setup, Service Usage: In order to use the Services, you will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as a class name, billing and payment information (including billing contact name, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. For example, we need a physical postal address if you are buying something on the Site for delivery. We may store credit card information and other information provided to us during checkout, for billing and payment purposes, and to process your transaction.
Profile: You may provide your name and other personal information in connection with your account and activity. You can edit or remove this information through your account settings. From time to time, we may also ask you about certain demographic information, such as your race, ethnicity, sexual orientation, or gender identity, in relation to specific marketing and advocacy projects and campaigns. Providing this demographic information is entirely voluntary and at the time we ask we will also seek your consent to use it.
Automated Information: Plum automatically receives and records information from your browser or your mobile device when you visit the Site or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Plum may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a device such as a voice-activated assistant or SmartTV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We also automatically collect device-specific information when you access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers.
Data from Plum Vendors and Suppliers: We also receive information from our vendors and suppliers about you. This information can include customer service interactions, payments information, shipping information, and information shared in Plum’s forums.
Data from Advertising and Marketing Partners: As described below, Plum receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to Plum comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.
Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for Plum’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Apps or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also upload photographs to Plum.
Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the Apps, what happens within the Apps, aggregated usage, performance data, app errors and debugging information, and where the Apps were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
Non-Member Information: Plum receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered Plum member (a “non-member”) in connection with certain Plum features, such as when a non-member chooses to subscribe to an Plum newsletter, a member invites a non-member to visit the Site, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to Plum, for purposes necessary to the functioning of Plum’s Services or where Plum has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorized by a member or the non-member.
3. Messages from Plum
On occasion, Plum will need to contact you. Primarily, these messages are delivered by email, text Messages, or by push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Plum may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, Plum may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, or to provide you with information about services and features that you may find of interest.
Some messages from Plum are service-related and necessary for members and Guest Checkout users. You understand and agree that Plum can send you non-marketing emails, Plum Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions and correspondence with Plum’s Support team (including by chat interface or the other methods of communication as described above).
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in marketing emails or messages. Please note that some changes to your account settings may take a few days to take effect.
Plum is a marketplace and a community. Please use common sense and good judgment when posting in community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you. We engage certain third parties to assist in providing community services to you and, in the context of that relationship, we need to share some of your information with such third parties in order to provide that service. This may include, for example, information from your Plum account that is publicly available, your account’s status, the properties you’re interested in, your posts and co-ownership group memberships, your Plum username name, the display name you’ve optionally chosen to share publicly in your Plum account, avatar image, the date that you registered on Plum, as well as your language and regional settings on the Site. If you close your Plum account, your Community account, which allows you to post in Forums, will also be closed and related personal information will be deleted. However, your posts may remain public after your account is closed, although your name will no longer be displayed alongside the post. You are responsible for the personal information that you choose to post in community spaces through the Services. You can set your privacy preferences and download your data in your Community Settings, and close or delete your Community account by submitting a request to Plum.
Another member may follow your public activity on the Site to receive updates, such as when you add a house to your public Favorites. You may choose to make certain activities private through your account settings. You have the option to block any member with whom you do not wish to share your updates.
5. Information Uses, Sharing, & Disclosure
We respect your privacy. Plum will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.
When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
- You have consented to the processing, which you can revoke at any time;
- Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
- Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
- You have expressly made the information public;
- Necessary in the public interest, such as to prevent crime; and
- Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury). We principally rely on consent (which can be withdrawn at any time) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our partners may advertise our Services or our partners’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy. These partners have their own privacy policies and consent mechanisms for their customers, in addition to Plum’s controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them, in our Cookies and Similar Technology Disclosures.
Plum may also use first party data (e.g. your prior browsing patterns on our Site), and may combine it with other data collected from you, such as your location, or publicly available information, to permit us to create targeted audiences based on your known or inferred demographic and/or interests to provide you with more relevant and useful content on our site, in our direct marketing channels (like email), or with our off site marketing partners, like Google and Facebook, subject to their terms and privacy notice you agreed to with such partners.
Our Legitimate Interests
Where we process your information on the basis of legitimate interests, we do so as follows:
Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help partners find the best ways to market and sell their services on Plum.
Providing Marketing Communications: We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for Plum’s advertising programs (including Plum’s on-site advertising and marketing).
Keeping our Services Safe and Secure: We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Plum’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our case resolution process, we may use information you provide to resolve disputes with Plum or other members.
Site Customization: We may learn about the types of homes and co-owners that you’re interested in from your browsing and usage behavior on (and off) the Site or Apps and use such information to suggest potential matches as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help partners find the best ways to market and sell their services on Plum.
If Plum receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Plum may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details.
Aggregated Information: Plum may share demographic information with business partners, but it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers: Plum also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Plum not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services) that Plum does not own or control or individuals that Plum does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Plum requires these third parties to follow Plum’s privacy and security requirements, Plum does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Plum is not responsible for the privacy or security practices of these partners or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these partners, third party providers are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.
Necessary for the Performance of the Contract between Plum and its Members
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.
If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Plum will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Plum member account), or as needed to provide the Services to you. If you no longer want Plum to use your information to provide the Services to you, you may close your account. Plum will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Plum partners may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address or username for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
9. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Plum gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Plum account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.
- Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Plum.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that Plum “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information). If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us by submitting a message through our contact form. Once you contact us to exercise any of your rights, we will confirm receipt of your request. Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact Plum through one of the channels listed below under “Contact”. We will respond to your request within a reasonable timeframe.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
Email & Messages
You may also control the receipt of certain types of communications from Plum in your account settings. Plum may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from Plum” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies.
Additional Disclosures for California Residents
Notice of Collection
In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:
- Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
- Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
- Demographics, such as your age or gender, or, where you have provided such information to Plum voluntarily, demographic information about your race, ethnicity, sexual orientation, or gender identity, provided in relation to specific marketing and advocacy projects and campaigns.This category includes data that may qualify as protected classifications under other California or federal laws.
- Commercial information, including purchases and engagement with the Services.
- Internet activity, including your interactions with our Services and what led you to our Services.
- Sensory visual data, such as pictures posted on our Service.
- Geolocation data provided through location enabled services such as WiFi and GPS.
- Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.
Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
Plum does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.
To opt-out of receiving interest based advertising, you can exercise your choice by using your account privacy settings, or the general privacy settings link located at the footer of our homepage and most pages of the Site. The right to opt-out of interest based advertising is available to all Plum users.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to partners on Plum (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of Plum, or unless you request us to or consent to it, Plum does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below.
If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section.
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ platform. We encourage you to check back regularly and review any updates.
If you have any questions:
Contact Plum’s Support team
Send an email to Plum’s Data Protection Officer at email@example.com
Write to us at:
1319 Watts St
Durham, NC 27701