Royal LePage Real Estate Services
Privacy Policy
At Royal LePage Real Estate Services ("Royal LePage"), we respect the privacy
of our clients and we are committed to keeping your personal information accurate,
confidential, secure, and private. We have adopted the following Privacy Policy
to ensure that Royal LePage continues to meet its commitment to your privacy.
The following sections, read as a whole, constitute the Royal LePage Privacy
Policy:
1. Introduction
2. The
Ten Principles of Privacy
3. Application
of the Ten Principles
4. Questions,
Concerns and Complaints About the Royal LePage Privacy Policy
Introduction
Royal LePage provides a variety of products and services to the public, including,
but not limited to, real estate brokerage services, real estate agency services,
advising with respect to real estate purchase and sale, home leasing, property
management, real estate brokerage franchising services, and other real estate
advisory services.
In the course of providing these products and services, Royal LePage may collect
certain personal information about its clients with their consent.
"Personal Information" means information about an identifiable individual.
This may include, without limitation, the individual's name, home address,
age, income, credit history, or other financial information, credit card information,
personal preferences, and other information about his or her family. Personal
Information does not include the name, title, business address, or telephone
number of an employee of an organization.
The Royal LePage Privacy Policy is based on, and complies with, Canada's Personal
Information Protection and Electronic Documents Act ("PIPEDA"), which includes
the Ten Privacy Principles outlined in the Canadian Standards Association Model
Code for the Protection of Personal Privacy. For more information about this
legislation, please visit the official Web site of the Privacy Commission of
Canada at http://www.privcom.gc.ca/index_f.asp.
This Privacy Policy describes the ten principles that Royal LePage follows
to ensure that we protect your Personal Information when we collect, use, or
disclose it in the course of carrying on commercial activities in Canada. All
of our employees who have access to Personal Information must adhere to the
Royal LePage Privacy Policy and related procedures. To this end, Royal LePage
has appointed a privacy officer to ensure compliance by all Royal LePage employees
and to address your privacy concerns.
The following ten principles govern our actions as they relate to the use of
Personal Information:
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Accountability
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Identifying purposes
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Consent
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Limiting collection
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Limiting use, disclosure, and retention
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Accuracy
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Safeguarding personal information
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Openness
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Access
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Addressing complaints
Principle 1: Accountability
Royal LePage is accountable for all Personal Information in its possession
or custody, including Personal Information disclosed to third parties for
purposes of providing services requested by you.
Principle 2: Identifying purposes
Royal LePage will inform you of the purposes for which it is collecting any
Personal Information, before or at the time the information is collected.
Principle 3: Consent
Royal LePage will obtain your consent before or when it collects, uses, or
discloses your Personal Information.
Consent can be express, implied, or given through an authorized representative.
You may withdraw your consent at any time (subject to any legal consequences
of which you will be informed). Royal LePage, however, may collect, use, or
disclose Personal Information without your knowledge or consent in exceptional
circumstances where such collection, use, or disclosure is permitted or required
by law.
Principle 4: Limiting collection
The information collected by Royal LePage will be limited to those details
necessary for the purposes it has identified to you or to perform the services
you have requested. Information will be collected by fair and lawful means.
Principle 5: Limiting use, disclosure, and retention
Personal Information will only be used or disclosed for the purpose for which
it was collected unless you have otherwise consented. Personal Information
may only be retained for the amount of time needed to fulfill the purpose
for which it was collected.
In certain exceptional circumstances, Royal LePage may have a legal duty or
right to disclose Personal Information without your knowledge or consent with
respect to matters that concern the company's or the public's interest.
Principle 6: Accuracy
Royal LePage will keep Personal Information as accurate, complete, and current
as necessary to fulfill the identified purposes for which it was collected.
You may have this information amended where it is found to be inaccurate
or incomplete.
Principle 7: Safeguarding personal information
Personal Information is safeguarded using measures appropriate to the sensitivity
of the information.
Principle 8: Openness
Royal LePage will make information available to its clients, employees, and
Royal LePage brokers about the policies and procedures Royal LePage uses
to manage Personal Information. You have access to this information through
our website, or through alternative means if requested.
Principle 9: Access
Upon written request, you will be informed of the existence, use, and disclosure
of your Personal Information, and will be given access to it. Royal LePage
will respond to such requests as efficiently as possible. If Royal LePage
is prohibited from providing such access they will explain the reasons for
the lack of access, except where prohibited by law.
Principle 10: Addressing complaints and suggestions
You may challenge Royal LePage compliance with this Privacy Policy. Royal LePage
has policies and procedures to receive, investigate, and respond to complaints
and questions regarding this Privacy Policy and our collection, use, and
disclosure of Personal Information. You may contact the Royal LePage Privacy
Officer to express any concerns or to request access to your Personal Information.
The contact information for this individual is provided at the end of this
document.
Application
of the ten Privacy Principles – How we treat your personal information
The kind of information we collect
Royal LePage gathers and uses Personal Information in order to provide you
with the products and services you have requested, namely: information that
is required to effectively market and sell the property of sellers or lessors;
to locate, assess, and qualify properties for buyers; to evaluate independent
broker applicants; and to otherwise provide professional and competent real
estate services to clients as well as to ensure that you are satisfied with
the products and services we have provided. Royal LePage may also use your
Personal Information to update you about our services and to offer you additional
products or services that you may be interested in, so that we may continue
to serve your real estate needs.
We may be required to collect your social insurance number if the federal
government obligates us to do so pursuant to the Income Tax Act.
If you visit Royal LePage Web sites, we do not collect personally identifiable
information about you unless you provide it. All information that you do provide
us with is securely maintained and kept strictly confidential. This Privacy
Policy does not apply to aggregated data from which it is not possible to determine
the identity of a specific individual. Royal LePage reserves the right to use
aggregated data in any way that it determines appropriate.
How we use your information
At Royal LePage we use Personal Information for three general purposes:
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To communicate with you in order to provide you with our products and
services.
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For inclusion in documentation relating to your particular real estate
transaction.
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Transactional information to monitor our level of service and report
back to you to ensure your satisfaction with the provision of such services.
We will only use Personal Information for the purpose that we have disclosed
to you. If we want to use your information for a different purpose, we will
notify you and ask for your consent first.
When we are permitted to disclose your information
Royal LePage is obliged to keep your Personal Information confidential except
under the following circumstances:
(i) When authorized by you
Many of the services offered by Royal LePage require us to obtain Personal
Information about you in order to perform the services you have engaged us
to provide. We will always obtain consent from you first, and we will never
use the information for purposes other than those we have told you about.
You may withdraw your consent at any time, subject to any legal implications
(which we will inform you about). In some cases, if you do not consent to our
use or disclosure of certain Personal Information, we may be unable to continue
to provide all or part of the services you have requested.
(ii) When required by law
The type of information we are legally required to disclose usually relates
to government tax reporting requirements. In some cases, however, such as
under a court order, we may be required to disclose certain information to
persons specified in the court order. We will only provide the specific information
requested and only upon being satisfied that the authorities have legitimate
grounds to request the information.
(iii) When permitted by law
The legislation has provided certain situations where Royal LePage is legally
permitted to disclose Personal Information without your consent. Examples
include situations involving the collection of debt in arrears, medical emergencies,
or suspicion of illegal activities.
With whom we may share your information
(i) Royal LePage employees
In the course of daily operations, access to sensitive Personal Information
is limited to those employees with a legitimate reason for accessing it.
As a condition of their employment, Royal LePage employees are required to
follow all applicable laws and regulations, including this Privacy Policy.
Unauthorized use or disclosure of confidential client information by any
Royal LePage employee is prohibited and may result in disciplinary measures.
(ii) Royal LePage affiliates
In order to better meet your needs, we may share some of your Personal Information
with our affiliates. We will only do this with your express consent and you
may withdraw this consent at any time. The procedure for withdrawing consent
is outlined below under the section "Opting Out."
(iii) Royal LePage third-party suppliers
As you may know, we may engage and coordinate third-party suppliers to provide
you with certain services offered through Royal LePage. Such suppliers are
only given the information that is needed to provide the specific service
for which we contract them to provide. Suppliers are obliged to protect the
confidentiality of your Personal Information and are prohibited from doing
anything with this information that we have not authorized them to do. They
are required to treat your Personal Information in a manner consistent with
the Royal LePage Privacy Policy.
(iv) Sale of Business
We may transfer your personally identifiable information to a third party in
connection with a sale, merger, or other disposition (whether of assets,
stock, or otherwise) of our business.
How we safeguard information
Royal LePage has extensive controls in place to maintain the security of its
information and information systems. Client and independent broker files
are stored according to the sensitivity of the information contained therein.
Appropriate controls (such as restricted access) are placed on our computer
systems and data processing procedures. Physical access to areas where Personal
Information is gathered, processed, or stored is limited to authorized employees.
When you telephone a Royal LePage employee to speak about your file, you may
be asked for some personally identifying information. This type of safeguard
is designed to ensure that only you, or someone authorized by you, has access
to your file.
Website security
In order to serve you better, Royal LePage offers clients access to certain
information through its websites.
http://www.royallepage.ca provides general information about Royal LePage
and the products and services it offers.
The Royal LePage Web site contains links to other Web sites, including those
of its business partners. Royal LePage is in no way responsible and cannot
guarantee the content or privacy of other sites linked to www.royallepage.ca.
Accessing and amending your information
As a client or Royal LePage broker, you have the right to access the Personal
Information we keep in your file and you have the right to verify or amend
the information if it is shown to be inaccurate. If you would like to view
the Personal Information held in your file, please make a written request
to the Privacy Officer at the address listed below, under "Questions, Concerns,
and Complaints". We will respond to your request as efficiently as possible.
To make a change, please make a similar request in writing to the Privacy
Officer.
Opting out
In order to provide you with our services and products, Royal LePage will,
with your consent, share your personal information with other Royal LePage
affiliates. Should you not want to receive promotional materials from or
have your Personal Information shared with these companies please contact
the Privacy Officer at the address, phone number, or e-mail address provided
at the end of this document.
Anonymous information and "cookies"
Royal LePage may collect anonymous information about you. This means that the
information collected cannot be traced back to a specific person. For example,
our Web servers may record certain information automatically when you visit
Royal LePage websites. This information is collected using "cookies" and
might include the pages you visited, your IP (Internet protocol) address
and other site usage statistics. This anonymous information is used for research
and analytical purposes only (like evaluating how many visitors our Web sites
receive or which pages they visit most often). It does not reveal any Personal
Information about you, the user. This aggregate data may be disclosed to
third parties, but never with personally identifying information.
"Cookies" are small text files that contain a unique identification number
that allows our computers to identify your Web browser (but not you) each time
you visit one of our Web sites that uses cookies. The information helps Royal
LePage improve the functionality of the site and enhance the navigation and
security of your session. Most major Web sites use this technology and most
browsers are set up to accept them.
You may configure your browser to notify you when you receive a cookie, and
you may refuse to accept them entirely. However, if you refuse to accept cookies,
you may limit the functionality that we can provide to you when you visit our
site.
Questions, Concerns, and
Complaints
If you have any questions, concerns, or complaints about your Personal
Information, or about the Royal LePage Privacy Policy, contact our privacy
officer using the contact information provide below:
Max M. Cohen
General Counsel and Secretary
Royal LePage Real Estate Services
41 Wynford Drive,
Don Mills, Ontario M3C 1K1
Tel.:
(416)
380-7551