Royal LePage Solutions 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 Solutions 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, email address, social media account names, 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 ten principles of privacy
The following ten principles govern our actions as they relate to the use of Personal Information:
- Identifying purposes
- Limiting collection
- Limiting use, disclosure, and retention
- Safeguarding personal information
- Addressing complaints
Principle 1: Accountability
Royal LePage Solutions 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 Solutions 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 Solutions 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 Solutions, 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 Solutions 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 Solutions 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 Solutions 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 Solutions will make information available to its clients, agents and employees, about the policies and procedures Royal LePage Solutions 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 Solutions will respond to such requests as efficiently as possible. If Royal LePage Solutions 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
Application of the ten privacy principles
The kind of information we collect
Royal LePage Solutions 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 Solutions 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.
When you use the “Inquire” feature on the Royal LePage Solutions Website to request more information about a property from an agent, you agree to provide Royal LePage Solutions and the agent receiving the request with your browser history (recently performed searches on http://www.royallepagesolutions.com/ recently viewed listings) along with any searches or listings saved to your account where an account has been set up by you on the Royal LePage Solutions Website.
How we use your information
At Royal LePage Solutions we use Personal Information for three general purposes:
- To communicate with you in order to provide you with our products and services.
- For inclusion in documentation relating to your particular real estate transaction.
- 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 purposes that we have disclosed to you and by entering personal information into forms on the Website or in other communications you are giving your consent to our using it for the above purposes. 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 Solutions 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 Solutions 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 Solutions 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 Solutions employees
(ii) Royal LePage Solutions 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 Solutions third-party suppliers
If you access Royal LePage Solutions Websites from third-party websites, including any partner or referral sites, you authorize Royal LePage Solutions to collect and use any Personal Information about you that you provide to us while visiting Royal LePage Solutions Websites and to share with the third-party any Personal Information collected. You also authorize any such third-party to use any Personal Information or any content you may provide while using Royal LePage Solutions Websites for preparing, using and distributing statistical, profiling, performance or operation reports.
(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 Solutions 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 Solutions 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.
Accessing and amending your information
As a client or Royal LePage Solutions 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.”
To request a change of inaccurate information, please make a similar request in writing to the Privacy Officer.
We will respond to such requests as efficiently as possible.
Should you not want to receive promotional materials from Royal LePage Solutions please contact the Privacy Officer at the address, phone number, or e-mail address provided at the end of this document.
Website security and privacy
In order to serve you better, Royal LePage Solutions offers clients access to certain information through its website.
http://www.royallepagesolutions.com/ (the “Website”) provides general information about Royal LePage Solutions, the products and services it offers and the agents that represent it.
The Royal LePage Solutions Website contains links to other websites, including those of its business partners. Royal LePage Solutions is in no way responsible and cannot guarantee the content or privacy of other sites linked to www.royallepagesolutions.com.
Anonymous information, Google AdWords and Cookies
Royal LePage Solutions may collect anonymous information about you when you visit the Website. 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 the Website. 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 Websites 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.
The Website uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site and to “similar audiences” as that term is defined by Google. It could mean that we advertise to:
- previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry; and
- individuals that Google identifies as part of a “similar audience” to past visitors to our site.
We may, at times, use data we’ve collected through Google Analytics to create “remarketing lists” which are used to advertise to previous visitors to our Websites and similar audiences on third-party sites, including Google. This includes advertisements on Google search results pages or on sites in the Google Display Network.
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.
Third Party Website/Social Media Links
To the extent that the Website includes links to third party websites or to social media platforms, you acknowledge that by clicking on those links you may be providing certain information to the operators of such websites or platforms, some of which may be personally identifying. For example, clicking on a button to follow Royal LePage Solutions on a social media platform will presumably personally identify you to that platform by reference to your relevant social media account and would allow that platform to determine that you have connected from the Website, which information may be recorded and used in accordance with that platform’s privacy policies. If you access third-party websites or social media platforms using the links provided, the operators of such sites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from Royal LePage Solutions’. Royal LePage Solutions encourages you to review the privacy policies of those third-party websites or social media platforms so that you understand if/how they collect and/or use information from you or your computer. Royal LePage Solutions itself does not collect personally identifying information from your clicks on such links, but does track which outbound links are clicked by each user to collect aggregate data about the activity that the Royal LePage Solutions Website generates to those other sites or platforms. To the extent that Royal LePage Solutions receives any information back from those third party sites or platforms, such data is subject to all of the privacy obligations and the consents to its use contained in this document.
Questions, concerns, and complaints