Privacy Policy
Purpose
The External Communications and Privacy Code Policy ("Privacy Code") sets forth the policies of icon1 Reality Services Inc; Brokerage and its affiliated entities (collectively, “icon1 Reality Services Inc; Brokerage”) regarding how icon1 Reality Services Inc; Brokerage representatives may communicate with our clients, and other non-icon1 Reality Services Inc; Brokerage third parties, in a consistent, accurate, fair and timely manner and aligned with all Canadian legislative regulations.
This Privacy Code sets out the principles that govern the collection, use and disclosure of our Clients’ personal information and applies to all icon1 Reality Services Inc; Brokerage employees, directors, officers, consultants and contractors.
General Policy
It is icon1 Reality Services Inc; Brokerage policy that all its communications with third parties comply with the requirements of Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Canada’s Anti-Spam Legislation, passed in 2010 and effective July 1st 2014 (“CASL”), and our own commitment to protecting our clients’ privacy.
Objective
The primary objective of this Privacy Code is to inform our clients about our privacy practices, why icon1 Reality Services Inc; Brokerage collect personal information, and how such information is protected. In addition, we want to ensure that icon1 Reality Services Inc; Brokerage continues to have our clients’ consent to continue to collect, use and disclose our clients’ personal information for those explicit purposes.
Definitions
Personal Information means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.
Process
1. Why does icon1 Reality Services Inc; Brokerage collect personal information?
Under Canada’s privacy laws, marketers are required to identify to individuals, either through a dialogue box or prominent notice backed up by a more detailed privacy policy, why Personal Information is being collected and the intended purpose(s) for said Personal Information. This information must be presented to an individual prior to or at the time of Personal Information collection. Any disclosure of clients’ Personal Information outside of icon1 Reality Services Inc; Brokerage is made on a confidential basis, with said information to be used only for the purpose for which it was disclosed.
icon1 Reality Services Inc; Brokerage collects Personal Information for the following purposes:
1.1. To establish and maintain a responsible commercial relationship with our clients and to provide ongoing professional services. For example, when a client applies for our services, icon1 Reality Services Inc. collect information that allows it to confirm the client’s identity and billing information so that icon1 Reality Services Inc. can accurately bill for its services and comply with FINTRAC anti-money laundering legislation.
1.2. To better understand our client’s needs and preferences, icon1 Reality Services Inc. maintains a record of professional services that our clients receive from icon1 Reality Services Inc. and we may ask for additional information (for example, through surveys and feedback requests) so that we can better meet those needs, and continue to develop improved services to our clients.
1.3. To meet legal and statutory requirements. For example, this will include information required by the Canadian Radio-television and Telecommunications Commission.
2. Why and when do we disclose Personal Information?
icon1 Reality Services Inc. may disclose Personal Information for the following purposes:
2.1. icon1 Reality Services Inc. may disclose its clients’ Personal Information to a person who is a legitimate representative of the client.
2.2. Subject to provincial Real Estate Act Legislation, clients’ Personal Information may be shared among icon1 Reality Services Inc. offices and business units to help us serve our clients better and to provide them with professional services.
2.3. icon1 Reality Services Inc. may disclose a client’s Personal Information to:
2.3.1. Another Commercial Real Estate Services provider who are party to the client’s prospective transaction.
2.3.2. A company or individual employed or associated with icon1 Reality Services Inc. in order to perform or fulfill services on its behalf, such as research, design or marketing.
2.4. icon1 Reality Services Inc. may disclose a client’s Personal Information to meet legal or regulatory requirements. For example, when responding to a court order or a government institution, if required to do so, by law.
2.5. As part of any sale, merger or amalgamation of any part of our business, a client’s Personal Information will normally be a part of such transactions and therefore will be disclosed only for such a purpose.
3. How does icon1 Reality Services Inc; Brokerage protect its Clients’ Personal Information?
3.1. icon1 Reality Services Inc. will not collect, use or disclose our clients’ Personal Information for any purpose other than those identified above, except with the client’s consent.
3.2. icon1 Reality Services Inc. will protect our clients’ Personal Information with appropriate security measures.
3.3. icon1 Reality Services Inc. will comply with any reasonable and lawful client request to access their Personal Information.
3.4. icon1 Reality Services Inc. will protect the confidentiality of our clients’ Personal Information when dealing with third party companies.
3.5. icon1 Reality Services Inc. will endeavor to keep our clients’ Personal Information as accurate and up-to-date as necessary for the purposes listed above.
Personal Information collected by icon1 Reality Services Inc. may be stored and processed in Canada or another country. In either case, such information is protected with appropriate security measures, but may be available to government agencies under applicable law.
4. Collecting Clients’ Personal Information?
icon1 Reality Services Inc. professional staff must receive explicit consent from our client contacts, prior to sending any marketing email correspondence to our clients.
A client may choose to be excluded from our external communications and withdraw consent at any time, subject to legal or contractual obligations.
icon1 Reality Services Inc. has developed information systems to help manage unsubscribing client data centrally in Canada.
5. icon1 Reality Services Inc. Anti-Spam Policy
icon1 Reality Services Inc. has a strict zero-tolerance policy against spamming. All professionals must refrain from using our operating and messaging systems, including but not limited to email, instant messaging, or texting (collectively, “Electronic Address”) to distribute any unsolicited commercial electronic messages for which consent has not been received. This includes all one-to-one email communications with clients and mass emailing. Our professionals are prohibited from sending unsolicited electronic messages of any kind, including mass emails, in connection with the marketing of our programs, products and services or to encourage the participation in any commercial activities.
icon1 Reality Services Inc. considers spamming to be any activity whereby a professional, directly or indirectly, transmits an electronic message to any Electronic Address for which prior consent of such electronic message has not been granted.