Privacy Statement for Royal LePage Real Estate Services Ltd.

Last Updated September 20, 2023

We respect the privacy of our clients and we are committed to keeping your personal information accurate, confidential, secure and private. This privacy statement sets out how we collect, store, use and safeguard your personal data. It applies to the personal data we collect through this website.

For your information and convenience, our website may contain links to other websites or apps run by other organizations, which we do not control. This privacy statement does not apply to those other websites and apps, so we encourage you to read their privacy statements to stay informed of how they use your personal data.

Which personal data we collect

The personal data we collect depends on how you interact with this website and may include the following:

• Your name, address and contact details, including email address and telephone number.
• Passwords, password hints, answers to security questions, and similar credentials used for authentication and account access.
• Your location, including the location derived from your IP address.
• Your interests and preferences including your preferred official language, and saved searches, favourite real estate listings and other similar data that helps us build up a picture of your interests and preferences.
• Data about your device (including device identifiers) and how you and your device interact with our website.
• Other information you provide to us and the content of messages you send to us when you submit information or service requests by completing various contact forms on the website.

We do not knowingly collect personal data from anyone under the age of 16.

How we collect your personal data

We collect your personal data from you, from third parties and through cookies.

• Data obtained from you from this website: You provide personal data directly to us when you create an account on this website, submit a request for information via a form on this website, request value estimate for a property at a specific address, execute searches for properties, view and/or like/favourite specific property listings, or update your website Client Portal account information and preferences.
• Log information - we log information about your website visits, including your IP address, pages visited and property searches performed.
• Data obtained from third parties: We obtain personal data about you from service providers that help us determine a location based on your IP address.
• Data obtained through cookies: We also collect personal data about you by using cookies to record how you interact with our Sites.

What are cookies?

Cookies are small files placed on your computer or mobile device when you access our website.

They allow us to remember your preferences and give us information on how you interact with our site. They recognize your device and store certain information on your preferences or actions. If you authorize cookies, they are stored on your device and we can access them on your next visit. This makes for an easier and more personalized user experience that better meets your needs. Certain cookies are also used for web analytics (providing depersonalized visit counts and page visits).

What kind of information do we collect with cookies?

Cookies collect a range of information that may be linked to your use of our sites, your preferences, or your device.

This information generally cannot identify you directly, but it may include personal information if you provide such information while interacting with our sites. All personal information collected is governed by our Privacy Policy.

For example, cookies may collect information on:

• Date and time of visits
• Pages visited
• Your browser or operating system
• How you access or interact with the site

Types of cookies

We divide cookies into four categories, depending on their function and intended purpose: necessary cookies, statistics cookies, preferences cookies, and marketing cookies.

Necessary cookies

These cookies are essential for our website to function. Without these cookies, you would not be able to navigate our website or operate its basic functions. They may:

• Show you the site in the language of your choice
• Enable website navigation
• Make our site easier to use
• Authenticate and identify you
• Remember your username when connecting
• Improve our site security

Necessary Cookies may not be disabled in our consent management tool. You can configure your browser to block essential cookies, but the site may not work properly.

Statistics cookies

These cookies collect information about how you use our website. We use Google Analytics to collect, analyze, measure, and report data from these cookies to understand our web traffic and page views in order to improve the performance of our websites and your user experience. For example, the cookies record which browser and operating system you used, which parts of the websites you visited, your number of visits, and the average duration of your visits. They do not collect information that would allow us to identify you. The collected information is aggregated and, therefore, remains anonymous.

Preferences cookies

These cookies store information that you have already entered, such as your language selection and your location, in order for your experience to feel more personalized when you return to our websites. These cookies collect anonymous information and cannot track your movements on other websites.

Marketing cookies

These cookies register your activity on our website. We may allow a limited number of trusted third party advertising partners to install cookies to build a profile of your interests based on information about you, such as your page views on our website or your information requests on our website.

Our website may include third-party advertising, links to other websites and/or social plugins. Social plugins are buttons that let you share your experiences on our websites with other people on social media platforms (including but not limited to Facebook, LinkedIn, Instagram, Twitter/X, Pinterest and YouTube ). When you share your experiences through social plugins, social media platforms install their own cookies on your device.

These cookies do not store information about you but they uniquely identify your browser and device. Together with other information about you collected by our advertising partners or social media companies, your browser and device information could be used by third parties to identify you.

How to control which cookies we set

You can find out the details of the cookies used under the Cookie Settings section of our cookie banner.

We will automatically set necessary cookies in order for our website to work correctly but we will only set statistics and preference cookies with your consent. By default these cookies will be switched off. If you would like to set any of these types of cookies or accept all cookies, you can do so in the Cookie Settings section of the cookie banner. You can revise your selection at any time by clicking the Cookies link on our webpage.

You can also manage cookies through your browser or device settings.

Most browsers provide guidelines on cookie management. You can choose to authorize or reject cookies. You can even erase cookies.

If you disable all cookies through your browser, our website (and others) may not function properly.

How we make changes to this cookie policy

Should we elect to change this cookie policy, we will post the changes here, so please check this page from time to time to ensure that you are informed of any changes.

Why we collect your personal data and our lawful bases for processing it

We use your personal data for different purposes, including:

• To allow a REALTOR(®) to contact you to provide information expressly requested by you..
• To inform the website owner of user interests, popular features, website traffic and generated consumer inquiries.
• To create, maintain, customize and secure your account on this website.
• To provide you with support and to respond to inquiries, including investigating and addressing your concerns and monitoring and improving response.
• To personalize your website experience and to deliver content and product and service offerings relevant to your interests.
• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To improve our Websites so the content is presented most effectively for you and your device.
• As part of our efforts to keep our Websites secure.

We will only use your personal data where we have lawful bases for doing so. Lawful bases include, among others, each one of the following:

• Consent (where you have given consent).
• Legal obligation (where using your personal data is necessary for compliance with laws that apply to us).
• Legitimate interests (where we have legitimate interests and they do not outweigh your privacy rights).

Where we rely on your consent to use your personal data, you have the right to withdraw or decline your consent at any time. Please see the ‘Your rights regarding your personal data’ section for further details on how you can do this.

If you have any questions about, or objections to, the lawful bases upon which we use your personal data, please contact our data privacy officers in any of the ways described at the end of this privacy statement.

Marketing

We may use your personal data to send you marketing information directly from us by post, email or SMS, where you gave your consent to such use.

Where we rely on your consent to use your personal data, you have the right to withdraw or decline your consent at any time. Please see the ‘Your rights regarding your personal data’ section for further details.

How we store, process, transfer and protect your personal data

The personal data we collect about you will be stored in a range of different places, including on our servers and in our information management systems and databases (e.g. marketing databases, customer support systems and transaction management systems).

We only share your personal data on a need-to-know basis as follows:

• Internally, with various functions, including, for example sales representatives, finance and legal support personnel.
• Externally, with third parties that help us run our business, including, for example, third parties that manage our IT systems.

To ensure that your personal data is adequately protected no matter where it is processed, we have internal policies and controls in place to prevent your personal data from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties under contract.

Your rights regarding your personal data

You have a number of rights regarding your personal data.

• Accessing your personal data. You can request a copy of the personal data we hold about you.
• Correcting and updating your personal data. You can ask us to correct or update your personal data at any time if you discover that any of it is inaccurate or out of date.
• Erasing your personal data. You can require that we erase personal data in certain circumstances and we will take reasonable steps to inform other controllers that are processing the data that you have requested the erasure of any links to, copies or replication of the data. Your personal data will be removed from our systems within a reasonable time and will be deleted. However, we may retain a copy of your personal data (i) if and as long as required to complete any current business transactions on your behalf (ii) by law, regulation, administrative or court order or for internal auditing purposes, or (iii) as electronic data stored due to automatic archiving and back-up procedures.
• Objecting to or restricting the processing of your personal data. You can ask us to stop using all or some of your personal data (e.g. if we have no lawful basis to keep using it) or restrict how we process it.
• Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal data, you can withdraw your consent at any time and you can prevent further processing if there is no other legal basis upon which we can process your personal data.
• Porting your personal data. You can ask us to transfer the personal data that we hold about you to a third party electronically.

If you would like to exercise any of these rights or raise a complaint about our data processing practices please see the ‘How you can contact us about this privacy statement or make a complaint’ section below.

How long we keep your personal data

The period for which your personal data is held is determined by a number of factors including the purpose for which we use that personal data, the nature of our ongoing business relationship with you, and our legal obligations.

How we make changes to this privacy statement

Should we elect to change this privacy statement, we will post the changes here, so please check this page from time to time to ensure that you are satisfied with any changes.

How you can contact us about this privacy statement or make a complaint

If you have any questions or suggestions about this privacy statement or about how we use your personal data, please contact:

Myron Dylynsky
416.236.1871
dylynsky@pathcom.com

Please let us know if you are unhappy with how we use your personal data. We will respond to your complaint within 30 days.

If you are not satisfied with the way we handled your complaint, you may refer your complaint to your local data protection regulator. For example, in Canada this is the Office of the Privacy Commissioner (https://www.priv.gc.ca/en/). For a complete list of data protection regulators within the European Union, please visit https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.