Mullin Group – Royal LePage RCR Realty Privacy Policy

At Mullin Group – Royal LePage RCR Realty (“Mullin Group”), 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 RCR Realty continues to meet its commitment to your privacy. This policy applies to all Royal LePage RCR Realty (“the Brokerage”) workers, which for the purposes of this Policy, includes employees, independent contractors and sub-contractors (including

sales representatives / brokers and sales assistants), consultants and volunteers that do work on behalf of the Brokerage.

The following sections read as a whole, comprise the Mullin Group – Royal LePage RCR Realty Privacy Policy:

Introduction

Royal LePage RCR Realty provides a variety of products and services to the public, including but not limited to: real estate franchise services, 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.

In the course of providing these products and services, Royal LePage RCR Realty may collect, with consent, certain personal information about its clients, employees and Royal LePage RCR Realty brokers and agents.

“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, her or 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 RCR Realty 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. All of our information handling practices complies with federal and applicable provincial laws, including those in the Provinces of Alberta, British Columbia and Québec, which have private-sector privacy laws deemed substantially similar to PIPEDA.

This website 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.

This Privacy Policy describes the ten principles that Mullin Group – Royal LePage RCR Realty 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 and contractors who have access to Personal Information must adhere to the Mullin Group – Royal LePage RCR Realty Privacy Policy and related procedures. To this end, Royal LePage RCR Realty has appointed a Chief Privacy Officer to ensure compliance by all Royal LePage RCR Realty employees and to address your privacy concerns.

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

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 – Access

Principle 10 – Addressing Complaints

Principle 1 – Accountability

Royal LePage RCR Realty is accountable for all Personal Information in its possession or control, including Personal Information transferred to third parties for purposes of providing services requested by you.

Principle 2 – Identifying Purposes

Royal LePage RCR Realty 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 RCR Realty 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 RCR Realty 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 RCR Realty 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.

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 RCR Realty 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 RCR Realty 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 RCR Realty will make information available to its clients, employees and Royal LePage brokers and agents about the policies and procedures Royal LePage RCR Realty 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 RCR Realty will respond to such requests as efficiently as possible. If Royal LePage RCR Realty 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 about an organization’s compliance with these privacy principles.  Royal LePage RCR Realty 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 RCR Realty Privacy Officer to express any concerns with Royal LePage RCR Realty’s adherence to this Privacy Policy or to request access to your Personal Information. The contact information for our Privacy Officer is provided at the end of this document.

Application of the Ten Privacy Principles – How we treat your personal information

1. The Kind of Information We Collect

Royal LePage RCR Realty 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; evaluate independent contractor applicants, and to otherwise provide professional and competent real estate services to clients and customers and to ensure that you are satisfied with the products and services we have provided. Royal LePage RCR Realty 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 RCR Realty 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 RCR Realty reserves the right to use aggregated data in any way that it determines appropriate.

1. How We Use Your Information

At Royal LePage RCR Realty 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, including to match you with a Royal LePage agent or brokerage;
• 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 Mullin Group – Royal LePage RCR Realty agent.

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.

iii. When We are Permitted to Disclose Your Information

Royal LePage RCR Realty 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 RCR Realty require us to obtain Personal Information about you in order to perform the services you have engaged us to provide. For example, in the course of your search for real estate, we will share your contact information with prospective Mullin Group – Royal LePage RCR Realty agents to assist you.

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 RCR Realty 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.

1. With Whom We May Share Your Information

• Royal LePage RCR Realty Workers

In the course of daily operations, we may disclose Personal Information to Royal LePage RCR Realty real estate brokers and agents.  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 RCR Realty 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 RCR Realty broker, agent or employee is prohibited and may result in disciplinary measures.

• Royal LePage RCR Realty 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 RCR Realty. 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.

In some cases our service providers may be located outside of Canada in countries where the law provides for a different level of protection for Personal Information than that which is available under Canadian law.  If you would like to obtain more information about our policies and procedures regarding the use of service providers located outside of Canada, please contact our Privacy Officer at the address listed at the end of this document.

• 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.

1. How We Safeguard Information

Royal LePage RCR Realty has extensive 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 workers. When you telephone a Royal LePage RCR Realty worker 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.

1. Web Site Security

In order to serve you better, Mullin Group – Royal LePage RCR Realty offers clients access to certain information through its Web site. https://www.mullingroup.ca  provides general information about Mullin Group – Royal LePage RCR Realty and the products and services it offers. The Mullin Group – Royal LePage RCR Realty Web site contains links to other Web sites, including those of its business partners. Mullin Group – Royal LePage RCR Realty is in no way responsible and cannot guarantee the content or privacy of other sites linked to www.mullingroup.ca 

vii. Accessing and Amending Your Information

As a client or 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 Chief Privacy Officer at the address listed at the end of this document, under “Questions, Concerns and Complaints”. We will respond to your request as efficiently as possible. To make a change, please make a written request to the Chief Privacy Officer. 

viii. 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.

1. Anonymous Information and “Cookies”

Royal LePage RCR Realty 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 RCR Realty Web sites. 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 RCR Realty 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.

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.

This Privacy Policy was last updated on November 1, 2022

5. Questions, Concerns and Complaints

If you have any questions, concerns or complaints about your Personal Information, or about the Royal LePage RCR Realty Privacy Policy, please contact our Privacy Compliance Officer at:

Brenda Vanwoudenberg

Royal LePage RCR Realty

75 First Street, Suite 14

Orangeville, Ontario

L9W 2E7

Email: [email protected]

Phone: 519-941-5151

Information That We Collect & Why We Collect It

When you visit this site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the site, we collect information about the individual web pages or listings that you view, what websites or search terms referred you to the site, and information about how you interact with the site.

This information is collected to improve the quality of our website, enhance or tailor the information we offer and make the experience of our website as valuable and efficient as possible.

Your Personal Information

We use return email addresses or phone numbers to answer the request we receive.

Disclosure in Business Transfers

In the event, whether of illness, absence or any other reason deemed necessary, an additional Licensed REALTOR® is required to assist us regarding client-related communications or transactions, this Licensed REALTOR® is understood to be as one and the same for all purposes pursuant to the protection of privacy relative to both the client’s personal information and his or her Buyer’s Agency Agreement.

Links to Other Web Sites

Please be aware that when you click on links that take you to third-party websites, you will be subject to their respective privacy policies. While we support the protection of privacy on the Internet, we cannot be responsible for the actions of third parties. We encourage you to read the posted privacy statement whenever interacting with any other website.

Use of Cookies

“Cookies” are data files placed on your device or computer and often include an anonymous unique identifier. For more information about cookies and how to disable cookies, visit http://www.allaboutcookies.org

If you leave a comment on our site, you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

“Log files” track actions occurring on the site, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and indicates the post ID of the article you just edited. It expires after 1 day.

Third-Party Advertising Services

We may use third parties such as advertising networks, ad exchanges, and analytics service providers to help us serve, optimize and measure the performance of our advertisements across the Internet and mobile applications. You may see our ads on other websites because these third parties’ services may track your online activities across multiple websites, online services and mobile applications over time by collecting information through automated means, such as cookies, and they use this information to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. To learn more about the third-party cookies and technologies we use on our Site, see our Cookie Notices.

These third-party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Except for the disclosures about third parties in our Cookie notice, statements in this Notice regarding our privacy practices do not apply to the methods for collecting information used by these third-party providers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice.

The relevant third parties’ terms of service, privacy policies, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or providers of tracking technologies or related third parties. You may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members.

You may also be able to opt-out of receiving interest-based ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/control, the Digital Advertising Alliance of Canada (“DAAC”) at https://youradchoices.ca/en/tools, or the European Digital Advertising Alliance (“EDAA”) website at www.youronlinechoices.com. Similar limitations may apply to the opt-outs provided by these organizations. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.

Opting out of these organizations only means that those members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit their opt-out pages, or you subsequently erase your cookies, use a different device or change web browsers, your opt-outs may not, or may no longer, be effective. Additional information is available on each organization’s website accessible by the above links.

Embedded content from other websites

Pages on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves similarly as if the visitor has visited another website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

We use Google Analytics to help us understand how our clients use the site–you can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the site.

Tag Management

This type of service helps manage tags and scripts on the site in a centralized fashion. This results in the User’s Data flowing through these services, potentially resulting in the retention of this data.

Who We Share Your Data With

We may share your data with third parties for advertising & marketing purposes or to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful requests for information we receive, or to otherwise protect our rights.

How Long Do We Retain Your Data

We will retain Personal Information for the period necessary to provide our Services or fulfill the purposes for which it was collected, or as otherwise required by our contracts or by law.

When determining how long we should keep data, we consider the length of time we will have a relationship with you and our customers to whom we provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, and the risk of harm from unauthorized use or disclosure of your Personal Information.

We may also anonymize or de-identify Personal Information for research or analytical purposes so that it is no longer associated with you. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.

Where we hold and process Personal Information for a customer as part of our Services, our retention or deletion of data will be subject to that customer’s instructions, and in such cases the customer’s retention and deletion preferences may apply.

What 3rd Parties We Receive Data From

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of the site and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Your Rights

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if it is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if the Owner is processing Data, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract of which the User is part or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Rights of EU, UK and Swiss Data Subjects

Subject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Information. As noted above, where we are acting as a processor for our customer, we may refer your requests to our customer for response.

• Right of access: If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Information that we control is inaccurate or incomplete, you are entitled to have it rectified or completed. Note that we may not be able to rectify data obtained from a third party such as a governmental agency or other data that we do not control, and you will need to contact that third party directly. If we have shared your Personal Information with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your Personal Information with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of that Personal Information or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Information with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
• Right to data portability: With respect to Personal Information that we possess on or after 25 May 2018, you have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform a contract with you, to the extent it is available. We will give you your Personal Information in a reasonable format given the nature of the information requested and complexity of providing it.
• Right to object: You may ask us at any time to stop processing your Personal Information, and we will do so if we are processing your Personal Information for the Services, for direct marketing, or otherwise. However, if we are relying on a legitimate interest to process your Personal Information and we demonstrate compelling legitimate grounds for the processing we may continue; or you may exercise your rights by contacting us as directed in the “How To Contact Us” section above. Note you will be asked to verify your identity when submitting a request.
• Rights in relation to automated decision-making and profiling: You have the right to be free from decisions that we make based solely on automated processing of your Personal Information, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
• Right to withdraw consent: If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. Your withdrawal of consent will not apply to or affect prior processing of data that was processed prior to our receipt of your withdrawal of consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns.

If you have an account with us, we may instruct you to exercise some of your rights above through account settings or features, or by deleting your account.

Data Subjects may contact us as directed.

International Data Transfers

Visiting our Site and Using our Services from Outside of the United States & Canada

Our Site and Services are hosted and managed in the USA & Canada, so the Personal Information we process will be transferred to and processed in the USA & Canada. The USA or Canada may have data protection laws that are different than the laws of your country, but we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice. In particular, regarding the transfer to and processing in the United States of Personal Information from the European Economic Area (EEA) member countries, the United Kingdom (UK) and Switzerland, we rely on the Standard Contractual Clauses (SCCs, also known as the EU Model Clauses) to help safeguard such Personal Information and as our lawful transfer mechanism under GDPR.

The SCCs are a set of terms and conditions published by the European Commission (EC), and approved for use by the UK, that apply to Controllers and Processors that transfer Personal Information to countries that are not covered by an adequacy decision, such as the USA. In June 2021, the EC published new SCCs, which will replace the SCCs previously adopted by the EC following a transition period. We will use existing SCCs for international data transfers during the transition period and plans to use the new SCCs when applicable and as required by EC rules. You can learn more about the SCCs here. If there is any conflict between the terms of this Policy and the SCCs, the SCCs will govern.

We commit to resolving complaints about your privacy and our collection or use of your Personal Information. European Union, UK or Swiss individuals with inquiries or complaints regarding this privacy policy are encouraged to first contact us at the contact information provided. You may refer any unresolved privacy or data use concern that we have not addressed satisfactorily to your local data protection authority, and we will work with them to resolve your concern.

When we transfer Personal Information about EU, UK or Swiss individuals to other third parties, it will do so in accordance with the requirements of GDPR applicable to such transfers, including for onward transfers of Personal Information to third parties in other countries that are not covered by an adequacy decision, such as the USA. In these cases, we are potentially liable if such third parties do not provide the same level of protection as GDPR.

Retention of EU Data

For information on our data retention practices, see the “Data Retention and Destruction” section below, which applies to Personal Information of EU data subjects.

How We Treat “Do Not Track” Requests

Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by 3rd parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including ours, do not alter their behaviour or change their services when they receive a “do-not-track” flag or signal.

By using our website, you consent to our collection and use of your information as described in this policy. If updates to this privacy policy, such changes will be posted on this page, therefore, you are always aware of what information is collected and how we use it, we recommend that you review this page regularly.

This privacy policy was last updated on November 1st, 2022. If you have any questions feel free to contact us directly.