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Royal LePage Relocation Services Privacy Policy
At Royal LePage Relocation Services
Limited ("RLRS"), we respect the privacy of our customers and we are committed
to keeping your personal information accurate, confidential, secure and private.
We have adopted the following Privacy Policy to ensure that RLRS continues to
meet its commitment to your privacy.
The following sections, read as a whole, comprise the RLRS Privacy Policy:
| 1. |
Introduction |
| 2. |
The Ten Principles of Privacy |
| 3. |
Application of the Ten Principles
| i) |
The kind of information we collect. |
| ii) |
How we use your personal information. |
| iii) |
When we disclose your personal information. |
| iv) |
With whom we share your personal information. |
| v) |
How we safeguard your personal information. |
| vi) |
Web site security. |
| vii) |
Accessing and amending your personal information. |
| viii) |
Opting - out. |
| ix) |
Cookies. |
|
| 4. |
Questions, Concerns and Complaints About the RLRS Privacy Policy |
1. Introduction
RLRS provides a variety of relocation services to the public, including, but
not limited to: property valuation and appraisal review, home sale or home sale
assistance, financial assistance, equity advances and expense coordination, property
management, lease cancellation, interim living arrangements, furniture moving
and storage coordination, orientation, home finding, home purchase or rental
assistance, guidance regarding mortgages and taxation, home and neighbourhood
information, education and elder care connections.
In the course of providing these products and services, RLRS may collect, with
their consent, certain personal information about its customers.
"Personal Information" means information about
an identifiable individual customer. This may include without limitation, the
individual's name, address, age, gender, income, employment status, credit history,
debts and liabilities, 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 RLRS 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.
This Privacy Policy describes the ten principles that RLRS follows to ensure
that we protect our customers' 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 RLRS Privacy Policy
and related procedures. To this end, RLRS has appointed a Privacy Officer to
ensure compliance by all RLRS employees.
2. The Ten Principles of Privacy
The following ten principles govern our actions as they relate to the use of
customer 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 – Customer Access
Principle 10 – Addressing Customer Complaints
Principle 1 – Accountability
RLRS is accountable for all personal information in its possession or custody,
including personal information disclosed to third parties for processing.
Principle 2 – Identifying Purposes
RLRS will inform its customers of the purposes for which it is collecting any
personal information, before or at the time the information is collected.
Principle 3 – Consent
RLRS will obtain consent from its customers before or when it collects or uses
the personal information.
A customer's consent can be express or implied. A customer can withdraw consent
at any time (with certain exceptions). RLRS, however, may collect, use or disclose
personal information without the customer'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 customer will be limited to those details
necessary for the purposes it has identified to the customer. 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 customer has otherwise consented, or when it is required
or permitted by law. Personal information may only be retained for the amount
of time needed to fulfil the purpose for which it was collected.
In certain exceptional circumstances, RLRS may have a legal duty or right to
disclose personal information without customer knowledge or consent with respect
to matters that concern the company's or the public's interest.
Principle 6 – Accuracy
RLRS will keep personal information as accurate, complete and current as necessary
to fulfil the identified purposes for which it was collected. Customers 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
RLRS will make information available to its customers about the policies and
procedures RLRS uses to manage personal information. Customers have access to
this information through our web site, or through alternate means if requested.
Principle 9 – Customer Access
Upon written request, a customer will be informed of the existence, use and disclosure
of their personal information, and will be given access to it. RLRS will respond
to such requests as efficiently as possible. If RLRS is prohibited from providing
such access they will explain the reasons for the lack of access, except where
prohibited by law.
Principle 10 – Addressing Customer Complaints
and Suggestions
Customers may challenge the RLRS compliance with its Privacy Policy. RLRS has
procedures to receive, investigate and respond to customers' complaints and questions.
Customers may contact the RLRS Privacy Officer to express any concerns or to
request access to their personal information. The contact information for this
individual is provided below.
3. Application of the Ten Privacy Principles – how
we treat your personal
information:
The kind of information we collect
RLRS gathers and uses personal information in order to provide you with the relocation
services you have requested (through your employer) or to offer additional products
or services you may be interested in. Providing us with your personal information
is your choice, however, we may not be able to provide you with certain products
or services if you do not provide us with certain information. For example, we
cannot provide you with relocation services if we do not know where you live.
The nature of your request will determine the kind of personal information we
might ask for.
Information that is typically required to provide you with relocation services:
- Name
- Address
- Phone number(s)
- Mortgage information
- Information relating to the condition of your property
- Family information
- Special requirements relating to your needs at your point of destination
- Bank account and other financial information
- If there are tax implications related to your financial activities, the
federal government requires that we ask for your Social Insurance Number
for tax reporting purposes pursuant to the Income Tax Act.
RLRS may keep a file with your contact history to be used for customer inquiry
purposes so that we may ensure that your are satisfied with the relocation services
which we have provided to you.
If you visit an RLRS web site, 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.
How we use your personal information
At RLRS we use personal information for two general purposes:
- To communicate with you during the course of your relocation and to provide
you with our products and services. Some services may be provided by
other service providers (such as movers or consultants) to better serve
your relocation needs.
- 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 disclose your personal information
RLRS is obliged to keep your personal information confidential except under the
following circumstances:
| (i) |
When authorized by you |
| (ii) |
When required by law |
| (iii) |
When permitted by law |
(i) When authorized by you
Many of the services offered by RLRS require us to obtain personal information
about you in order to perform the services we have been engaged to provide. We
will use this information to tailor programs to meet your needs and objectives.
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.
For example, if we are providing you with orientation services in your new community,
we may need to know information about your family that will help us tailor an
orientation program. This might include information about your children's educational
requirements or information about your health care needs. Or we may reimburse
you for mileage or other incidentals that would require you to provide us with
your receipts. We will always obtain your consent before we collect, use or disclose
this information. You may also withdraw your consent at any time, subject to
any legal implications (which we will inform you about). For example you cannot
withdraw your consent with respect to a promissory note you have signed.
(ii) When required by law
The type of information we are legally required to disclose usually relates to
government tax reporting requirements. However, in some cases, such as under
a court order, we may be required to disclose certain information to authorities.
We will only provide the specific information requested and only upon being satisfied
that the authorities have legitimate grounds to request the information.
(iv) When permitted by law
The legislation has provided certain situations where RLRS is legally permitted
to disclose personal information without your consent. Examples include, but
are not limited to, situations involving the collection of debt in arrears, medical
emergencies, or suspicion of illegal activities.
With whom we share your personal information
(i) RLRS employees
In the course of daily operations, access to sensitive personal information
is limited to those employees and professional advisors (such as RLRS
lawyers, auditors, etc.) with a legitimate reason for accessing it. As a
condition of their employment, all RLRS employees are required to follow all
applicable laws and regulations, including the Privacy Policy we have
established. Where required, RLRS employees will hold and maintain
appropriate security clearance.
Unauthorized use, disclosure of confidential client information by an employee
of RLRS is prohibited and may result in disciplinary measures inclusive of dismissal.
(ii) RLRS affiliates (not applicable to Government Services and IRP program)
To ensure that all your relocation needs are met, and where we have your permission,
we may share some of your personal information with our affiliates (unless we
are contractually prohibited from doing so). 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) RLRS service providers
As you may know, we often engage and coordinate other service providers to deliver
to you the vast array of relocation services offered through RLRS. For example,
we maintain a network of lawyers, movers and consultants who assist families
in purchasing, moving and settling in to their new homes.
Such service providers are only given the information that is needed to provide
the specific service for which they are engaged to provide. Our network of Service
Providers are also bound by strict contractual means to protect the confidentiality
of your information, and they 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 RLRS Privacy Policy.
How we safeguard your personal information
RLRS have extensive controls in place to maintain the security of their information
and information systems. Client files are stored according to their sensitivity.
Appropriate controls (such as restricted access) are placed over our computer
systems and data processing procedures. Physical access to areas where personal
information is gathered, processed or stored, is limited to authorized employees.
Where requested by your employer, your file will be returned to your employer
after your file has closed.
When you telephone or meet with an RLRS employee to speak about your file, you
may be asked for some personally identifying information. This kind of safeguard
is designed to ensure that only you, or someone authorized by you, has access
to your file.
Web site security
In order to serve you better, RLRS offers customers access to certain information
through its secure web sites. RLRS is committed to your privacy and will ensure
that any information you access or provide through this site remains secure.
To safeguard against unauthorized access to your account, you are required to "sign-on" using
an encrypted password to gain access. If you are unable to provide the correct
password, you will not be able to access your account.
Accessing and amending your personal information
As a customer, 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 relocation services and products, RLRS will, with
your consent, share your personal information with other RLRS affiliates (unless
we are contractually prohibited from doing so). Should you not want to receive
promotional materials from, or have your personal information shared with, these
companies, please:
Contact us at rlrs.gs.privacy@royallepage2.com
Anonymous information and "cookies"
RLRS may collect non-personal information about you. This means that the information
collected cannot be traced back to a specific person. For example, our web servers
record certain information automatically when you visit RLRS web sites. This
information is collected using "cookies" - a small text file that contains a
unique identification number identifying your web browser (but not you) to our
computers every time you visit one of our web sites that uses cookies. They may
indicate pages you visited, your IP (Internet Protocol) address and other site
usage statistics. They help RLRS to improve the functionality of the site and
to enhance the navigation and security of your session. This information may
also be used for research and analytical purposes only (like evaluating how many
visitors our web sites receive). 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.
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. For example, the www.relodialogue.com web site requires cookies to recognize
clients with valid access to the database. If your browser does not accept cookies,
the site will not grant you access via the login and password.
Questions, Concerns and Complaints
If you have any questions, concerns or complaints about your personal information,
or about the RLRS Privacy Policy, please call please contact our Chief Privacy
Officer using the contact information provide below:
RLRS's Chief Privacy Officer is Kevin Von Bargen
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