Last Updated January 26, 2022
2. The Ten Principles of Privacy
3. Application of the Ten Privacy Principles – How we treat your personal information
The Kind of Information We Collect
How We Use Your Information
Web Site Usage Information, Location, and Cookies
When We are Permitted to Disclose Your Information
With Whom We May Share Your Information
Third Party Web Sites
Accessing and Amending Your Information
5. Questions, Concerns and Complaints
Royal LePage provides a variety of services to the public, including but not limited to: real estate brokerage services, real estate agency services, advising with respect to real estate purchase and sale, property leasing, property management, and other real estate advisory services, including the selling or referring of services associated with real estate.
In the course of providing these services, Royal LePage may collect, with consent, certain personal information about its clients, employees and Royal LePage brokers and agents.
“Personal Information” means information about an identifiable individual. This may include, without limitation, the individual‘s name, home address, age, date of birth, income, credit history or other financial information, credit card information, personal preferences and other information about 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.
This web site 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.
The following ten principles govern our actions as they relate to the collection, use and disclosure of Personal Information:
Principle 1 – Accountability
Royal LePage is accountable for all Personal Information in its possession or control, including Personal Information transferred to third parties for processing.
Principle 2 – Identifying Purposes
Royal LePage 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 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 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 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 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 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 will make information available to its clients, employees and Royal LePage brokers and agents about the policies and procedures Royal LePage 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 will respond to such requests as efficiently as possible. If Royal LePage 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
Royal LePage gathers a variety of information from and about you and your devices and uses this information, including Personal Information, in order to provide you with the products and services you have requested and to comply with applicable legislative requirements. Some of this information identifies you directly (like an email address) while some of it is associated with you through your account, profile, or device (like the homes you choose to save or your location data). The following is a representative list of the types of information that we collect:
• information about you to evaluate independent broker applicants; and
• information required to otherwise provide professional and competent real estate services to clients and to ensure that you are satisfied with the products and services we have provided.
At Royal LePage 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;
• 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 Royal LePage agent.
• Communicating with you and connecting with others
We use the contact information you provide us, like your phone number and email address, to communicate with you about our services. This includes things like responding to comments, questions, and requests you send us. It also includes notifying you of transaction or service updates and changes. We may also inform you about our services, offers, promotions, news, and other updates we think may be of interest to you
• To personalize your experience with Royal LePage
We use the information we collect about you and your activity on our services to personalize the services we offer. We also use it to show advertising, content, or features that we think you might like. This includes things like customized search results that match your preferences and prior search criteria and, if you ask us to, connecting you to a real estate professional best suited to help you
Other uses of your information may include:
• Providing and improving our services
We use your information to provide our services to you. We also use your information to improve our existing services and develop new ones. For example, we track how you use our websites and apps and use that information to troubleshoot issues and adjust things to improve your experience.
If you ask us to, we also use your information to connect you to real estate professionals, like when you want to contact an agent to discuss a home you find for sale on our platform.
• We also use your data to detect, investigate, and prevent fraudulent transactions and other illegal activities and to protect the rights and property of Royal LePage, its customers, and others.
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.
Occasionally, there may be a reason we’d like to use your information in a way that isn’t described here. If that happens, we’ll let you know so you can decide if you’re comfortable with it.
Royal LePage may collect information about your usage of this web site. For example, our web servers may record certain information automatically when you visit the web site.
This web site information is collected using “cookies” (discussed below) and might include the pages you visited, your IP (Internet Protocol) address, your home search history, homes you view, purchase activity, what you’ve clicked on and other uses of our features, and the amount of time you spend looking at different parts of our websites, and other site usage statistics. This 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). This aggregate data may be disclosed to third parties, but never with personally identifying information. When you contact us or a real estate professional using our platform, we collect data about your call or text, including the date and time of the call or text, your phone number, and the content of the call or text.
If you enable location services on your mobile device, Royal LePage collects the location of your device. We use that information to provide you with location-based information and ads, like homes and real estate professionals in your area, and to offer location-based services. If you don’t want to use these features, you can turn off location services on your device. We also collect location information for similar purposes from your browser if you enable it. You can disable access through your browser settings.
Cookies are small text files that contain a unique identification number that allows our computers to collect and identify data about your web browser or device model and settings, operating system, and the version of the app you’re using (but not you) each time you visit our web sites. We also collect data about how your browsers and devices interact with our services, including IP address, crash reports, system activity, and the date, time, and the URL of the site you visited before our website. The information helps Royal LePage improve the functionality of the site and enhance the navigation and security of your session and helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis, such as your favorite homes. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own cookies or similar tools. 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.
If you use social media logins (like Google and Facebook) to log in to Royal LePage, we may access your public social media profile information. You can always limit this sharing using your social media service settings.
Royal LePage 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 require us to obtain Personal Information about you in order to perform the services you have engaged us to provide. For example, we will share your property and ownership information when referring you to a Royal LePage agent.
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 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.
• Real Estate Brokers, Agents and Employees
• Royal LePage Third Party Suppliers and Service Providers
• 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.
How We Safeguard Information
Royal LePage has organizational, technical and physical 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 employees and contractors.
When you telephone a Royal LePage agent or employee to speak about your file, you may be asked for some Personal Information to identify you. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
As a further means of safeguarding your Personal Information, we follow commercially reasonable document retention practices and securely destroy your Personal Information once the purposes for which we collected it have been fulfilled, unless a longer period is permitted or required by law.
In order to serve you better, Royal LePage offers clients access to certain information about third party products and services through links on this web site to other third party web sites, including social media web sites. Royal LePage is in no way responsible and cannot guarantee the content or privacy of other web sites linked to www.royallepage.ca
You have the right to access the Personal Information we keep about you and have the right to verify or amend the information if it is shown to be inaccurate or incomplete. 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 below, under “Questions, Concerns and Complaints”. We will respond to your request as efficiently as possible. Please note that we will request Personal Information from you to verify your identity before providing you with access. Please also note that your right of access is not absolute; there are circumstances under which we may refuse access as provided under applicable law.
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.
Chief Privacy Officer