DATE: Prepared: October 14, 2004 Revised: May 3, 2010
2. The Ten Principles of Privacy
3. Application of the Ten Principles
i) The kind of information we collect
ii) How we use information
iii) When can we disclose personal information?
iv) Who we share information with
v) How we safeguard information
vi) Web site security
vii) Opting out
We provide a variety of products and services to the public, including, but not limited to: Real estate brokerage services; real estate agency services, advising clients with respect to the purchase, sale and lease of real estate, or other real estate advisory services.
In the course of providing these products and services, we may collect, with their consent, certain personal information about our clients.
Personal Information means information about an identifiable individual client. This may include without limitation, the individual’s name, home address, e-mail address, age, gender, income, personal preferences and other information about his or her family. Personal information does not include the name, title or 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 our clients’ personal information:
Principle 1 – Accountability
Principle 2 – Identifying Purposes
Principle 3 – Consent
Principle 4 – Limiting Collection
Principle 5 – Limiting Use, Disclosure and Retention
Principle 6 – Accuracy
Principle 7 – Safeguarding Personal Information
Principle 8 – Openness
Principle 9 – Client Access
Principle 10 – Addressing Client Complaints
PRINCIPLE 1 – ACCOUNTABILITY
We are accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees.
PRINCIPLE 2 – IDENTIFYING PURPOSES
We will inform our clients of the purposes for which we are collecting any personal information, before or at the time the information is collected.
PRINCIPLE 3 – CONSENT
Our policy is to require our agents to obtain consent from our clients before or when we collect, use or disclose their personal information. A client’s consent can be expressed, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. We may, however, collect, use or disclose personal information without the client’s 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 from the client will be limited to those details necessary for the purposes we have identified to the client. 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 the client has otherwise consented, or when it is required or permitted by law.
In certain exceptional circumstances, we may have a legal duty or right to disclose personal information without client knowledge or consent with respect to matters that concern the company’s or the public’s interest.
PRINCIPLE 6 – ACCURACY
We will keep personal information as accurate, complete and current as necessary to fulfil the identified purposes for which it was collected. Clients 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
We will make information available to our clients about the policies and procedures we use to manage personal information. Clients have access to this information through our Web site, or through alternate means if requested.
PRINCIPLE 9 – CLIENT ACCESS
Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. We will respond to such requests as efficiently as possible. If we are prohibited from providing such access we will explain the reasons for the lack of access, except where prohibited by law.
PRINCIPLE 10 – ADDRESSING CLIENT COMPLAINTS AND SUGGESTIONS
APPLICATION OF THE TEN PRIVACY PRINCIPLES – HOW WE TREAT PERSONAL INFORMATION:
THE KIND OF INFORMATION WE COLLECT
We gather and use personal information in order to provide our clients with products and services they have requested; namely, personal information required to effectively market and sell the property of sellers, to locate, assess and qualify properties for buyers; and to otherwise provide professional and competent real estate services to clients. We may also use personal information to offer additional products or services that may be of interest to our clients. Providing us with personal information is client’s choice, however, we may not be able to provide certain products or services if certain information is not provided.
We may keep a file with a client’s contact history to be used for inquiry purposes so that we may ensure that they are satisfied with the products and services which we have provided to them and can continue to serve their real estate needs.
HOW YOUR INFORMATION IS USED
At C&W we use personal information for three general purposes:
1.To communicate with clients in order to provide them with our products and services. Some services may be provided by third party suppliers to better serve their needs.
2. To monitor our level of service and report back to clients to ensure they are satisfied with the provision of such services.
3. For inclusion in documentation relating to a client’s particular real estate transaction.
We will only use personal information for the purpose that we have disclosed. If we want to use clients’ information for a different purpose, we will notify them and ask for consent.
WHEN CAN WE DISCLOSE PERSONAL INFORMATION?
We are obliged to keep clients’ personal information confidential except under the following circumstances:
(i) When Authorized by the client
(ii) When Required by Law
(iii) When Permitted by Law
WITH WHOM WE MAY SHARE INFORMATION
Unauthorized use or disclosure of confidential client information by one of our employees is prohibited and may result in disciplinary measures.
(ii) Third Party Suppliers
(iii) Sale of Business
We may transfer a client’s 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
C&W has extensive controls in place to maintain the security of its information and information systems. Client 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.
Web Site Security
In order to serve our clients better, we offer access to certain information through our global Web site.
Our Web site provides general information about C&W and the products and services it offers.
In order to provide clients with our services and products, we may, with their consent, share their personal information with other C&W affiliates. Should a client not want to receive promotional materials from or have their personal information shared with these companies please contact C&W at the address, phone number or email address provided below:
Address: 33 Yonge Street, suite 1000, Toronto, Ontario M5E 1S9 Canada
Phone Number: (416) 359-2365
Email Address: email@example.com
Anonymous Information and “Cookies”
When using our Web site, we may collect anonymous information. 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 anyone visits our Web site. This information is collected using cookies and might include the pages they have visited, 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 the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.
Each person may configure their browser to notify them when a cookie is received, which may be refused entirely. However, if cookies are refused, the functionality of our site may be limited.
Questions, Concerns and Complaints
Privacy Officer: Darlene Marin
Contact Information: (613) 236-7777 or firstname.lastname@example.org