At Royal LePage (“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, comprise the Royal LePage Privacy Policy:
1. Introduction 2. The Ten Principles of Privacy 3. Application of the Ten Privacy Principles – How we treat your personal information The Kind of Information We Collect How We Use Your Information Web Site Usage Information, Location, and Cookies When We are Permitted to Disclose Your Information With Whom We May Share Your Information Third Party Web Sites Accessing and Amending Your Information Opting Out 4. Updates 5. Questions, Concerns and Complaints
1. Introduction Royal LePage provides a variety of 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, property leasing, property management, and other real estate advisory services, including the selling or referring of services associated with real estate.
In the course of providing these services, Royal LePage may collect, with consent, certain personal information about its clients, employees and Royal LePage brokers and agents.
“Personal Information” means information about an identifiable individual. This may include, without limitation, the individual‘s name, home address, age, date of birth, income, credit history or other financial information, credit card information, personal preferences and other information about their family. Business contact information is also personal information, but consent is not required to collect, use or disclose this information for the purpose of communicating or facilitation communication with an individual in their business capacity.
The Royal LePage Privacy Policy is based on Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the National Standard of Canada entitled Model Code for the Protection of Personal Information. For more information about this legislation, please visit the official web site of the Office of the Privacy Commissioner of Canada at http://www.priv.gc.ca.
This web site is governed by Canadian law. If you are located in a jurisdiction outside of Canada and have questions on the application of the laws of your country to our collection, use or disclosure of your personal information, then please contact your local privacy commissioner or data supervisory authority.
GDPR and Prohibition of Use by European Residents – Royal LePage is based in Canada and its services are currently designed to facilitate real estate transactions within Canada. It does not knowingly or intentionally collect personal data from residents of the European Union, Switzerland, or any other individual protected by the European General Data Protection Regulations (the “GDPR,” and such residents, collectively, “European Residents”). Notwithstanding any other provision of this Privacy Policy, and given that Royal LePage may not comply with GDPR requirements, European residents are prohibited from using Royal LePage’s website(s) and its products and services to the extent that the GDPR would apply to the collection of such European Residents’ personal data by Royal LePage. Royal LePage may block European IP addresses and take other measures designed to ensure that it does not collect personal data from European Residents. To the extent a European Resident attempts to evade such measures (for example, through the use of a Virtual Private Network (VPN)) or otherwise violates this Privacy Policy or Royal LePage’s Terms of Use, such European Resident agrees to fully indemnify Royal LePage for any liability which it suffers due to such European Resident’s actions (including, without limitation, with respect to any fines assessed by European authorities against Royal LePage or its affiliates pursuant to the GDPR). If a European Resident believes, or would like to otherwise verify whether any of their personal data has been transmitted to Royal LePage, then such European Resident may contact Royal LePage using the information contained in the last section of this Privacy Policy. Royal LePage will immediately delete any such personal data of European Residents.
This Privacy Policy describes the ten principles that Royal LePage follows to 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 and contractors 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 Chief Privacy Officer to ensure compliance by all Royal LePage employees and to address your privacy concerns.
2. The Ten Principles of Privacy The following ten principles govern our actions as they relate to the collection, use and disclosure of Personal Information:
Principle 1 – Accountability
Royal LePage is accountable for all Personal Information in its possession or control, including Personal Information transferred to third parties for processing.
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
As required under Canadian law, Royal LePage will obtain your consent before or when it collects, uses or discloses your Personal Information.
Consent can be express or implied. In certain cases, consent may be given through an authorized representative. You may withdraw your consent at any time on reasonable prior notice (subject to any legal or contractual restrictions of which you will be informed). In certain exceptional circumstances Royal LePage may collect, use or disclose Personal Information without your knowledge or consent 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 we have identified to you or to perform the services you have requested. Information will be collected by fair and lawful means. Data will not be shared with third parties for marketing or promotional purposes.
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 consented to use or disclosure for other purposes. Personal Information will be handled in accordance with our document retention policies and will generally only be retained for the amount of time needed to fulfil the purpose for which it was collected, unless a longer period is required or permitted under applicable law.
In certain exceptional circumstances, Royal LePage may have a legal duty or right to collect, use or 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 fulfil the identified purposes for which it was collected. You may have this information amended or supplemented 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 and agents about the policies and procedures Royal LePage uses to manage personal information. You have access to this information through our Web site, or through alternate 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, except where prohibited by law. Royal LePage will respond to such requests as efficiently as possible. If Royal LePage is prohibited from providing such access we will explain the reasons for the lack of access, except where prohibited by law.
Principle 10 – Challenging Compliance
Individuals have the right to express their concerns with an organization’s compliance with these privacy principles. 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 Royal LePage to express any concerns with Royal LePage’s adherence with this Privacy Policy or to request access to your Personal Information. The contact information for our Chief Privacy Officer is provided at the end of this document.
3. Application of the Ten Privacy Principles – How we treat your personal information The Kind of Information We Collect
Royal LePage gathers a variety of information from and about you and your devices and uses this information, including Personal Information, in order to provide you with the products and services you have requested and to comply with applicable legislative requirements. Some of this information identifies you directly (like an email address) while some of it is associated with you through your account, profile, or device (like the homes you choose to save or your location data). The following is a representative list of the types of information that we collect:
• information about you to evaluate independent broker applicants; and • information required to otherwise provide professional and competent real estate services to clients and to ensure that you are satisfied with the products and services we have provided.
We do not collect personal information about you when you visit this web site (except for IP address, described below under “Web Site Usage Information and Cookies”) 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 anonymous, aggregated data in any way that it determines appropriate.
How We Use Your Information
At Royal LePage we use Personal Information for the following purposes:
• to verify your identity; • to market your real property for sale or lease; • to assist you in finding real property for sale or lease; • to communicate with you in order to provide you with our products and services, which includes providing you with updates about our services and offering you additional products or services that you may be interested in; • for inclusion in documentation relating to your particular real estate transaction; • to monitor our level of service and report back to you to ensure your satisfaction with the provision of our services; and • to consider your application for employment or engagement as a Royal LePage agent. • Communicating with you and connecting with others
We use the contact information you provide us, like your phone number and email address, to communicate with you about our services. This includes things like responding to comments, questions, and requests you send us. It also includes notifying you of transaction or service updates and changes. We may also inform you about our services, offers, promotions, news, and other updates we think may be of interest to you
• To personalize your experience with Royal LePage
We use the information we collect about you and your activity on our services to personalize the services we offer. We also use it to show advertising, content, or features that we think you might like. This includes things like customized search results that match your preferences and prior search criteria and, if you ask us to, connecting you to a real estate professional best suited to help you
Other uses of your information may include:
• Providing and improving our services
We use your information to provide our services to you. We also use your information to improve our existing services and develop new ones. For example, we track how you use our websites and apps and use that information to troubleshoot issues and adjust things to improve your experience.
If you ask us to, we also use your information to connect you to real estate professionals, like when you want to contact an agent to discuss a home you find for sale on our platform.
• We also use your data to detect, investigate, and prevent fraudulent transactions and other illegal activities and to protect the rights and property of Royal LePage, its customers, and others.
We will only use Personal Information for the purpose that we have disclosed to you and for which you have provided your express or implied consent, unless use for another purpose without your consent is permitted or required under applicable law. If we want to use your information for a different purpose, we will notify you and ask for your consent first.
Occasionally, there may be a reason we’d like to use your information in a way that isn’t described here. If that happens, we’ll let you know so you can decide if you’re comfortable with it.
Web Site Usage Information, Location, and Cookies
Royal LePage may collect information about your usage of this web site. For example, our web servers may record certain information automatically when you visit the web site.
This web site information is collected using “cookies” (discussed below) and might include the pages you visited, your IP (Internet Protocol) address, your home search history, homes you view, purchase activity, what you’ve clicked on and other uses of our features, and the amount of time you spend looking at different parts of our websites, and other site usage statistics. This 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). This aggregate data may be disclosed to third parties, but never with personally identifying information. When you contact us or a real estate professional using our platform, we collect data about your call or text, including the date and time of the call or text, your phone number, and the content of the call or text.
If you enable location services on your mobile device, Royal LePage collects the location of your device. We use that information to provide you with location-based information and ads, like homes and real estate professionals in your area, and to offer location-based services. If you don’t want to use these features, you can turn off location services on your device. We also collect location information for similar purposes from your browser if you enable it. You can disable access through your browser settings.
Cookies are small text files that contain a unique identification number that allows our computers to collect and identify data about your web browser or device model and settings, operating system, and the version of the app you’re using (but not you) each time you visit our web sites. We also collect data about how your browsers and devices interact with our services, including IP address, crash reports, system activity, and the date, time, and the URL of the site you visited before our website. The information helps Royal LePage improve the functionality of the site and enhance the navigation and security of your session and helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis, such as your favorite homes. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own cookies or similar tools. 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.
If you use social media logins (like Google and Facebook) to log in to Royal LePage, we may access your public social media profile information. You can always limit this sharing using your social media service settings.
When We are Permitted to Disclose Your Information
Royal LePage is obliged to keep your Personal Information confidential except under the following circumstances:
• 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. For example, we will share your property and ownership information when referring you to a Royal LePage agent.
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 unless use for another purpose without your consent is permitted or required under applicable law.
You may withdraw your consent at any time on reasonable prior notice, 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.
• When Required by Law
The type of information we are legally required to disclose usually relates to government tax and financial transaction reporting requirements. However, in some cases, 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.
• When Permitted by Law
Canada’s privacy legislation has provided for 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
• Real Estate Brokers, Agents and Employees
In the course of daily operations, we may disclose Personal Information to Royal Lepage real estate brokers and agents. For example, if we know you’re working with a particular Royal LePage real estate agent, we may share information about your saved homes and searches with that agent to let them serve you more effectively. Our employees will also have access to Personal Information. Access to Personal Information is limited to those brokers, agents and employees with a legitimate reason to use it. As a condition of their engagement, all Royal LePage brokers, agents and 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 broker, agent or employee is prohibited and may result in disciplinary measures.
• Royal LePage Third Party Suppliers and Service Providers
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 for them to provide the specific services that we have contracted them to provide and they are restricted from using this information for any other purpose. Suppliers and service providers are obliged to protect the confidentiality of your Personal Information and they are required to treat your Personal Information in accordance with this Privacy Policy.
• Sale of Business
We may disclose your personal information to a third party and their professional advisors in connection with a sale, merger or other disposition (whether of assets, stock or otherwise) of our business. In this event we will require that the information be maintained as confidential and only used for the purposes of evaluating and completing the transaction.
How We Safeguard Information
Royal LePage has organizational, technical and physical controls in place that are designed to maintain the security of its information and information systems. Files containing Personal Information 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 and contractors.
When you telephone a Royal LePage agent or employee to speak about your file, you may be asked for some Personal Information to identify you. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
As a further means of safeguarding your Personal Information, we follow commercially reasonable document retention practices and securely destroy your Personal Information once the purposes for which we collected it have been fulfilled, unless a longer period is permitted or required by law.
Third Party Web Sites
In order to serve you better, Royal LePage offers clients access to certain information about third party products and services through links on this web site to other third party web sites, including social media web sites. Royal LePage is in no way responsible and cannot guarantee the content or privacy of other web sites linked to www.royallepage.ca
Accessing and Amending Your Information
You have the right to access the Personal Information we keep about you and have the right to verify or amend the information if it is shown to be inaccurate or incomplete. If you would like to view the Personal Information held in your file, please make a written request to the Chief Privacy Officer at the address listed below, under “Questions, Concerns and Complaints”. We will respond to your request as efficiently as possible. Please note that we will request Personal Information from you to verify your identity before providing you with access. Please also note that your right of access is not absolute; there are circumstances under which we may refuse access as provided under applicable law.
Opting Out
Should you wish to withdraw you consent to our collection, use or disclosure of your Personal Information, please contact the Chief Privacy Officer at the address, phone number or email address provided at the end of this document. While we can accommodate your request in respect of the promotional materials you receive from us, if you wish to withdraw your consent for the other business purposes for which we collect, use and disclose your Personal Information, we may not be able to provide our services to you that are based on the use and disclosure of this information.
4. Updates
We may update this Privacy Policy from time to time, so please check back often to review the latest version. Following each update we will assume that you have familiarized yourself with the current version of our Privacy Policy and we will assume that we may collect, use and disclose your Personal Information in accordance with the updated Privacy Policy unless you advise us otherwise in writing.
5. Questions, Concerns and Complaints
If you have any questions, concerns or complaints about your Personal Information, or about the Royal LePage Privacy Policy, please contact Royal LePage using the contact information provide below:
