Effective Date: April 11, 2025
1. Data Policy
1.1 Introduction
Commercial Integrity NW (“CINW,” “we,” “us,” or “our”) is a commercial real estate advisory firm serving individuals and entities engaged in commercial real estate investment. We value and respect your privacy and are committed to protecting your personal data. This Data Policy explains how we collect, use, share, and safeguard personal information.
1.2 Information We Collect
- Contact details: name, phone number, email address, mailing address
- Communication history: emails, phone calls, and SMS messages exchanged with CINW
- Client preferences and interests: property and investment interests
- Transactional information: real estate activity, engagement terms, financial documentation (excluding sensitive personal financial account details)
- Website activity: data collected via cookies or tracking technologies
- Marketing consent and opt-in preferences
We do not collect or process health-related data.
1.3 How We Use Personal Information
- Deliver real estate advisory and brokerage services
- Match clients with relevant investment opportunities
- Maintain communication via email, phone, or SMS (with consent)
- Maintain records for legal, operational, and transactional purposes
- Improve services and website experience
1.4 Cookie Notice & Consent
We use cookies and similar technologies to enhance your experience on www.cinw.com. These technologies help us understand user behavior, personalize content, and improve website performance.
Types of cookies we use:
- Essential Cookies: Required for website functionality
- Performance Cookies: Analyze site usage
- Functional Cookies: Remember user preferences
- Targeting/Advertising Cookies: Deliver relevant ads
Consent Options:
- Accept all cookies
- Customize cookie preferences
- Decline non-essential cookies
You may withdraw consent at any time via the Cookie Preferences link.
1.5 SMS/Text Communication
We may send property updates, appointment reminders, or follow-ups via SMS:
- Only with explicit opt-in consent
- Opt out by replying “STOP” or emailing privacy@cinw.com
- Message and data rates may apply
1.6 Data Sharing & Third Parties
We do not sell personal data. Data may be shared with:
- Authorized partners
- CRM, SMS, analytics, and marketing platforms
- Legal and regulatory bodies as required
All vendors are under confidentiality and data processing agreements.
1.7 Data Security
- SSL/TLS encrypted communications
- Controlled access
- Periodic audits and retention reviews
- Timely notification in the event of a data breach
1.8 Data Retention
Data is retained only as long as necessary or legally required, then securely deleted or anonymized.
1.9 Privacy Rights by State
California: Rights under CCPA/CPRA include access, deletion, correction, and opt-out of data sharing. Oregon, Washington, Idaho: Right to access and deletion, breach notifications. Texas: Compliance with data protection and breach laws.
2. Data Processing Statement
2.1 Legal Basis for Processing
- Consent: For SMS and marketing
- Contractual necessity: For providing services
- Legitimate interest: For improving services
- Legal obligation: For compliance requirements
2.2 International Transfers
We do not transfer personal data outside the United States.
3. Terms & Conditions
3.1 Scope of Services
By engaging with CINW, clients agree to the terms outlined in engagement documentation and communications policies.
3.2 Communication Consent
Clients authorize communication via email, phone, and SMS (if opted in). Consent may be revoked at any time.
3.3 Confidentiality and Professional Responsibility
CINW keeps client data confidential and provides services based on professional experience, without guaranteeing outcomes.
3.4 Limitation of Liability
CINW is not liable for indirect damages. Liability is limited to fees paid within 12 months prior to any claim.
3.5 Governing Law
These terms are governed by the laws of Oregon. Disputes are resolved in Multnomah County, Oregon, unless otherwise agreed.
3.6 Dispute Resolution
Disputes will first be resolved informally, then submitted to binding arbitration under the rules of the American Arbitration Association.
4. Contact Us
Privacy Team
Commercial Integrity NW
Email: privacy@cinw.com
Website: www.cinw.com