Privacy Policy

Realty ONE Group Canada PRIVACY POLICY

Effective: June 1, 2022

  1. Scope of this Policy
  2. Agreement to Terms
  3. Effective Date and Changes to this Policy
  4. The Information We Collect
  5. Cookies
  6. Children’s Privacy
  7. How We Use Your Personal Information
  8. How We Share Your Personal Information
  9. Your Privacy Choices
  10. How We Store and Safeguard Your Personal Information
  11. Additional Disclosures for California Residents
  12. Additional Disclosures for Canadian Residents
  13. Additional Disclosures for European Residents (including the United Kingdom)
  14. Third-party Links
  15. Contact Us

 

Scope of this Policy

Realty ONE Group Canada is owned and operated by RO Master Franchise Inc.. (referred to herein as “Realty ONE Group” “ROG, “us”, “our”, “we” ). We are committed to respecting privacy rights and concerns and have established and implemented this Privacy Policy to inform users of our websites, our clients, our agents, brokers, franchisees, partners, and our applicants of what personal information we collect, and how we use, share, and protect such information. If you have any questions regarding this information or our privacy practices, please see the section entitled Contact Us at the end of this Privacy Policy.

Realty ONE Group provides a variety of products and services to the public, including, but not limited to, real estate brokerage services, real estate agency services, real estate franchising, advising with respect to real estate purchase and sale, home leasing, property management, various real estate related ancillary services, and other real estate advisory services.

 

Agreement to Terms

If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of any of the Realty ONE Group websites and/or our agent/broker/franchisee onboarding websites (collectively, the “Sites”), our mobile application (the “App”) and/or our services (collectively with the Sites and the App, the “Services”) without providing us any personally identifiable information.

 

Effective Date and Changes to this Policy

This Privacy Policy is effective as of the date above and will remain in effect until a new policy supersedes it. We may choose to update this Privacy Policy at our discretion, so you should check this page periodically as the terms may change from time-to-time. The most recent version of the Policy will be reflected by the “Effective” date noted at the top of the page. In the event of a material change to this Privacy Policy, we will provide a conspicuous message either through the Services or via an email address associated with your account if you have one with us,  informing you of the change. Your affirmative consent or continued use of the Services will constitute your acknowledgment of this Policy in its current version and your understanding of the terms of this Policy.

The following sections, read as a whole, constitute Realty ONE Group Privacy Policy:

A.PIPEDA Compliance

Realty ONE Group 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 https://www.priv.gc.ca/.

Definition of Personal Information

“Personal information” is any information about an identifiable individual, other than an individual’s business contact information that is used to communicate with the individual in relation to their business, employment or profession. Thus, personal information includes, but is not limited to, your name, contact information, date of birth, credit card details or other financial information, hours of availability, schedule, personal preferences, family size, income, employment details, opinions, purchase patterns and other demographics that help Realty ONE Group service your specific needs.

Personal information does not include anonymous or aggregated information that cannot be tracked back to you personally. For example, we may use aggregate data to improve the quality and efficiency of our products and services, and to enhance our marketing efforts.

The Ten Principles of Privacy

The following ten principles govern our actions as they relate to the use of Personal Information:

1: Accountability: Realty ONE Group 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.

2: Identifying Purposes: Realty ONE Group collects personal information for specific purposes and identifies these purposes at or before the time the information is collected.

2.1 Personal information is collected for purposes such as the following:

- To understand the needs of individuals and respond to requests for information, products or services;
- To verify an individual’s identity;
- To complete a business transaction such as the sale of a franchise,  the lease, purchase and/or sale of a property, to provide real estate related information and/or data;

-  To establish relationships, provide support, as well as communicate about Realty ONE Group project updates, service developments or other Realty ONE Group news;
- To conduct customer satisfaction surveys;
- To provide safety and security services; and
- To meet legal or regulatory requirements imposed upon Realty ONE Group from time to time.

2.2 Unless otherwise permitted or required by law, Realty ONE Group shall make reasonable efforts to only collect and use personal information that is necessary for the purposes identified in section 2.1.

2.3 Upon request, representatives of Realty ONE Group collecting personal information shall explain the purposes for which such information will be used, or refer the individual to another Realty ONE Group representative who can explain the purposes.

3: Consent: Realty ONE Group will obtain your consent before or when it collects, uses, or discloses your Personal Information.

3.1 Unless otherwise permitted or required by law, Realty ONE Group shall not use or disclose personal information for any new purpose that is not outlined in section 2.1 without first identifying and documenting the new purpose and obtaining the express consent of the individual.

 

3.2 Consent can be obtained in person, by phone, by mail, or via the Internet. Consent is only implied or assumed if the collection, use or disclosure of personal information is obvious based on the individual’s actions or inactions, and the personal information is non-sensitive in nature and context.

 

3.3 Realty ONE Group will only require individuals to consent to the collection, use or disclosure of personal information as a condition to the supply of a product or service if such collection, use or disclosure is required to fulfil the identified purposes.

 

3.4 Your provision of personal information to Realty ONE Group means that you agree to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with these terms, please do not provide any personal information to Realty ONE Group.

 

3.5 If you provide Realty ONE Group or its service providers with personal information about another person, it is your responsibility to obtain consent from such person to enable us to collect, use and disclose such information for the purposes set forth in this Policy.

 

3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. For example, you are always given the ability to opt-out of receiving promotional electronic messages from Realty ONE Group by using the available “unsubscribe” link. Realty ONE Group will inform customers of the implications of withdrawing consent, as we may be limited or unable to provide information, products or services as a result.

 

4: Limiting collection:  The information collected by Realty ONE Group 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.

4.1 Every Realty ONE Group department or business unit or agent is responsible for ensuring that all information collected is limited, both in amount and type, to what is needed to fulfil the identified purposes.

4.2 For the most part, personal information is collected directly from the individual who it is about, for example through applications and supporting documentation provided.

4.3 Only with the authorization of the individual or where permitted or required by law, Realty ONE Group may also collect personal information from references, financial institutions, credit reporting agencies or other third parties.

 

 

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 fulfil the purpose for which it was collected. In certain exceptional circumstances, Realty ONE Group 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.

 

6: Accuracy: Realty ONE Group 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 where it is found to be inaccurate or incomplete.

7: Safeguarding personal information: Personal Information is safeguarded using measures appropriate to the sensitivity of the information.

8: Openness: Realty ONE Group will make information available to its clients, employees, and Realty ONE Group brokers about the policies and procedures Realty ONE Group uses to manage Personal Information. You have access to this information through our website, or through alternative means if requested.

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. Realty ONE Group will respond to such requests as efficiently as possible. If Realty ONE Group is prohibited from providing such access they will explain the reasons for the lack of access, except where prohibited by law.

10: Addressing Complaints and Suggestions: You may challenge Realty ONE Group compliance with this Privacy Policy. Realty ONE Group 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 Realty ONE Group Privacy Officer to express any concerns or to request access to your Personal Information. The contact information for this individual is provided at the end of this document.

B.The Kind of Information We Collect

The types of personal information we may collect and process about you can include:

  • Personal identifiers, such as your first and last name, email address, phone number, billing and home shipping address, location, demographic information, such as your age or gender, screen name, online identifier, Internet Protocol address, unique device identifiers, date of birth, account name and password, social security number (used as a passcode for private documents, or if you are an agent), driver’s license or other national identifier, agent license, signature, and payment card and/or other banking information, marketing preferences, correspondence and chat information 
  • Internet or other electronic network activity information, including browsing history and search history, and information regarding your interaction with a website;
  • Professional or employment-related information and history, including but not limited to your resume or potential onboarding information (for example, when you submit an application), any onboarding information including but not limited to tax forms, hire date, emergency contact information, referring agent, agent home office and office address, agent franchise/brokerage membership, MLS identifiers, license information, and tax information, agent biography, agent transactions/homes sold, background and credit checks of franchisees (where permitted by applicable law); languages spoken; and any professional social media links; 
  • Third Party Information, including any personal information that is contained in or on any accounts that you have with third parties that you use in connection with your access to or use of the Services and/or the services that are available on or through the Services (eg. using Facebook or Google account to sign up for an account with us;
  • Commercial information, such as your purchase history for merchandise and/or event tickets;
  • Geolocation information;
  • Visual information such as a photo used on your agent profile or otherwise used on our Services; 
  • Hobbies or other interests, when included in your profile;
  • Characteristics of protected classifications, such as age;
  • Survey information, including referring agent, broker or office, or when you complete any forms, or respond to a survey or questionnaire, we collect the personal information you provide; and
  • Inferences drawn from any information to create a profile about you reflecting your preferences or behaviour.

 

As a general rule, we collect such personal information directly from you when you visit the Services; provide information to one of our agents; submit registration forms, feedback forms, order forms, franchisee forms, or an application; participate in a survey; or when you otherwise contact us.

We may also collect some personal information about you from third parties, including social media networks when you post reviews or comments on our social media pages, references from past employers when you submit an application to us to participate as an agent, broker, or franchisee, or background and credit checks for franchisees.

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 any of the Realty ONE Group affiliated Sites or Services, we do not collect Personal 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. Realty ONE Group reserves the right to use aggregated data in any way that it determines appropriate.

When you use any of the inquiry features on the Realty ONE Group Sites or Services to request more information, you agree to provide Realty ONE Group and the agent receiving the request with your browser history (recently performed searches on Realty ONE Group Sites recently viewed pages and/or listings) along with any searches or listings saved to your account where an account has been set up by you on a Realty ONE Group Site.

 

C.How We Use Your Personal Information

We use or otherwise process your personal information to:

  • Manage your relationship with us;
  • Respond to your inquiries or requests, and request feedback;
  • Provide goods or services requested by, or reasonably anticipated by, you; 
  • Create or develop new technologies or features of the Services;
  • Provide you with relevant promotional materials or information about the company, our services, and opportunities to get more involved;
  • Deliver targeted advertising to you;
  • Administer promotions, events, or surveys;
  • Evaluate your eligibility for becoming an agent, partner, or franchisee;
  • Provide you with useful tools for executing your responsibilities as an agent;
  • Analyse your use of the Services;
  • Tailor the Services to you, including retaining your login, shopping cart, and interests; 
  • Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible; 
  • Comply with legal requirements, to establish or exercise our rights, and to defend against a legal claim; and
  • To provide and maintain the functionality of the App, including debugging to identify and repair errors that impair existing intended functionality.

D. When We Are Permitted to Disclose Your Information

Realty ONE Group is obliged to keep your Personal Information confidential except under the following circumstances:

(i) When authorised by you:  Many of the Services offered by Realty ONE Group 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 Realty ONE Group 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.

E.With Whom We May Share Your Information

We share your personal information with the following categories of third-parties, where applicable:

  • Affiliated and Parent companies of Realty One Group and their employees, in the course of daily operations, access to sensitive Personal Information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Realty ONE Group employees are required to follow all applicable laws and regulations, including this Privacy Policy. Unauthorised use or disclosure of confidential client information by any Realty ONE Group employee is prohibited and may result in disciplinary measures.  The same applies to employees of our Affiliates and parent companies, Realty ONE Group International, Inc., and Realty ONE Group Affiliates, Inc., 
  • Third Party Suppliers, if you access Realty ONE Group Sites and Services from third-party websites, including any partner or referral sites, you authorise Realty ONE Group to collect and use any Personal Information about you that you provide to us while visiting Realty ONE Group Web sites and to share with the third-party any Personal Information collected. You also authorise any such third-party to use any Personal Information or any content you may provide while using Realty ONE Group Sites or Services for preparing, using and distributing statistical, profiling, performance or operation reports
  • Advisers and financial institutions, including, legal, tax, auditors, risk and compliance, notaries, and business continuity support services;
  • Service providers and suppliers, including, IT outsourcing, marketing, shipment processing, client management, event management, applicant management, and payment processors. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites;
  • Advertising networks, including but not limited to Google, Facebook, Instagram, Twitter, TikTok, LinkedIn, and Bing to provide you with relevant marketing;
  • Other users of the Sites, when your agent or member bio, contact information, photo, or interests are published;
  • Other users of the App, if you choose to engage in the opportunity to post comments, or reviews, in a public forum. If you decide to submit information in this manner, that information may be publicly available.
  • Where permitted by applicable laws, with third parties in connection with a corporate restructuring, sale, transfer or assignment of assets or business, merger, divestiture, or other changes to the company’s control or financial status (or any of our affiliates); and
  • Government bodies and dispute resolution and law enforcement organisations, as applicable.

If you have questions about the parties with which we share personal information, please contact us as specified below.

App Behaviour

Our App uses first party cookies and other methods to track App activity. We also use third party cookies and other methods to track App activity and disclose it with third parties. First party cookies are used to provide you with a better in-App experience. Third party cookies gather information to engage in behaviour-based advertising and capture analytics.

Device Information

Similar to cookies, we may automatically collect certain information about the device you use to access the Services. For example, we may collect and analyse information such as IP addresses, geolocation information, unique device identifiers, browser types, browser language, operating system, domain names, access times, the state or country from which you accessed the Services, and other information about your mobile phone or other device(s). In addition to analytical purposes, this information helps us diagnose problems with our server, administer the Services, and display the content according to your preferences.

 

F.How We Safeguard Information

Realty ONE Group has extensive controls in place to maintain the security of its information and information systems. Client, Agent and Franchisees 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 authorised employees.

 

When you telephone a Realty ONE Group 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.

 

G.Accessing and Amending Your Information

As a client or Realty ONE Group Agent, Broker and/or Franchisee, 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 at privacy@realtyonegroupcanada.com

H.Opting out

You are not required to provide all personal information identified in this Privacy Policy to use our Services, or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to respond to your requests, perform a transaction with you, engage you as an agent, partner or franchisee, or provide you with marketing that we believe you would find valuable.

In order to provide you with our Services and Products, Realty ONE Group will, with your consent, share your personal information with other Realty ONE Group affiliates. Should you not want to receive promotional materials from or have your Personal Information shared with these companies please contact the Privacy Officer at the address, phone number, or e-mail address provided at the end of this document.

If you no longer want to receive our newsletter, emails or other marketing communications, you may unsubscribe at any time by following the “unsubscribe” link at the bottom of our emails, by responding with “STOP” to any text message you receive from us, by accessing the email preferences in your account settings page, or by emailing us as detailed below. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or inquiries placed through the Services.

I.Anonymous information and “cookies”

Realty ONE Group 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 Realty ONE Group websites. 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 Realty ONE Group improve the functionality of the site and enhance the navigation and security of your session. Most major Websites use this technology and most browsers are set up to accept them.  Some cookies are necessary to operate a website, while others can be functional, analytical, or used for targeted advertising (as discussed in more detail below). More information about cookies and how they work is available at www.allaboutcookies.org

Cookies on our Sites are generally divided into the following categories:

  • Strictly Necessary Cookies: These are required for the operation of our Sites.  They include, for example, cookies that enable you to log into secure areas.  These cookies are session cookies that are erased when you close your browser.
  • Analytical/Performance Cookies: These allow us to recognize and count the number of users on the Sites and understand how such users navigate through the Sites (e.g., when and which pages are visited, in what order the pages are visited, how long a user may stay on a particular page, and where a user is located).  This helps to improve how the Sites work, for example, by ensuring that users can find what they are looking for easily.  These cookies are session cookies which are erased when you close your browser. We use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ and www.google.com/analytics/learn/privacy.html. You can opt-out of Google Analytics' collection and use of data generated by your use of the Sites by going to http://tools.google.com/dlpage/gaoptout. 
  • Functional Cookies: These improve the functional performance of the Sites and make it easier for you to use.  For example, cookies are used to remember that you have previously visited the Sites and asked to remain logged into them (e.g., saves your username and/or shopping cart).  These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to the Sites.  You can delete these cookies as detailed below.
  • Targeting Cookies: These record your visit to the Sites and the pages you have visited and the links you have followed, to recognize you as a previous visitor and to track your activity on the Sites and other websites you visit.  These cookies qualify as persistent cookies, because they remain on your device for us to use during your next visit to the Sites. You can delete these cookies as detailed below.  

You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help” or “Internet Options.”  Some browsers are listed below for more detail:

 

If you disable or delete certain cookies in your Internet browser settings, you may still access the Sites, however, you might not be able to access or use important functions or features of the Sites, and you may, for example, be required to re-enter your log-in details.  

To learn more about certain cookies used for interest-based advertising by third-parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile application.

J.Questions, concerns, and complaints

If you have any questions, concerns, or complaints about your Personal Information, or about the Realty ONE Group Privacy Policy, contact our privacy officer using the contact information provided below:

 

K.Contact Us

If you have questions or comments regarding this Privacy Policy or our privacy practices, or would like to inquire about or exercise your rights, please contact us at:

Realty ONE Group Canada, 

1377 The Queensway, Suite 101, Toronto, Ontario M8Z 1T1

647-715-1111

For Agent, Broker, or Franchisee Requests: info@realtyonegroupcanada.com 

For All Other Requests: privacy@realtyonegroupcanada.com

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