Since January 1, 2004, all organizations collecting, using or disclosing personal information in Canada in the course of commercial activities have been required to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any applicable “substantially similar” provincial legislation.
The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have certain rights, including:
- The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
- The right to know the business purposes for sharing personal information;
- The right to know the categories of third parties with whom we’ve shared personal information; and
- The right to access the specific pieces of personal information we’ve collected; and
- The right to delete your information.
- California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.
To learn more about these rights, your personal information under the CCPA, or to exercise your rights, you can also email us at email@example.com.
Personal information is defined in PIPEDA as information that can identify you, or by which your identity could be deduced. If we did not collect and use your personal information, we would not be able to provide you with the RELNKS portal’s services.
Under the CCPA, “Personal information” does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.
CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
COLLECTION OF PERSONAL INFORMATION
Generally, we collect your personal information directly from you at the start of or during the course of your enrollment with the RELNKS portal’s services. You might supply us with such information as your name, address, email address and telephone number. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features. Depending on the services you use, we may also obtain personal information about you from other sources, such as when securing legal or mortgage assistance: your insurance company, from your financial institution; your real estate agent; from a government agency or registry; your employer, if we are acting for you, at its request; or your accountant.
We use your personal information to facilitate your access to obtaining legal services from lawyers who also use the RELNKS portal, to issue invoices and to maintain our database of clients.
We may also use your personal information so that we may communicate with you about recent developments in the housing and mortgage market, to keep you aware of RELNKS news and invite you to RELNKS events.
We may offer tools such as a mortgage calculator, Canada child benefit calculator, RESP calculator, TFSA Room calculator, and credit card finder. If you use these tools, we collect information you provide (such as your income, RESP balance, credit score, etc.) in order to provide you with the features and functions of the tools. Unless you provide consent, none of the information provided will be shared with any other users of the portal or our services.
- Auto Insurance: If you request a quote for auto insurance, we collect personal information such as details about your vehicle (e.g. year, make, and model, number of kilometers driven per year), driver-related information (e.g. date of birth, sex, marital status, job status, driving history, license class, whether you are insured, name of current insurer, price of current insurance per month, details regarding any accidents or insurance violations you have been involved).
- Home Insurance: If you request a quote for home insurance, we collect information such as details regarding your property (e.g. address, type of property, occupation and rental information, and mortgages on the property), occupant details (e.g. first and last name, date of birth, job status, years of property insurance, email address, and damage claims history), and property construction details (e.g. year property was built, type of exterior, number of bathrooms, property’s estimated replacement cost, and square footage).
If you complete a mortgage application form on RELNKS, we collect personal information including your first and last name, email address, phone number, province, date of birth, address history, annual income, financial institution, employment status and other employment-related information, and financial assets. We will also obtain your consent for RELNKS to obtain your credit report from a credit reporting agency. We share your credit report and other information provided on your application form with potential mortgage lenders so that they can assess your eligibility for a mortgage, and we may also share information with financial intermediaries and mortgage insurers as necessary to provide services to you. Your credit report may include information such as the types and amounts of credit advanced to you, payment histories, negative banking items, collection actions, legal proceedings, previous bankruptcies and other information reported by your creditors. You authorize credit reporting agencies to provide such information to us. If we are unable to obtain your credit report based on your name, date of birth and mailing address alone, we may request you to provide other information, such as your social insurance number, on an optional basis which we will use to help us identify you with a credit reporting agency.
Certain third party products and services are only available in certain areas, and therefore we may ask for your location, either by requesting your postal code, city, and/or address.
MARKETING COMMUNICATIONS AND PRODUCT RECOMMENDATIONS
If you sign-up to receive marketing communications from us, we collect your name and email address to send you information about our product and services and those of our partners that may be of interest to you. We may also use the information we have about you as well as information obtained from third parties in order to provide you with personalized product recommendations on RELNKS. You may withdraw your consent to receiving marketing communications or product recommendations from us at any time by following the opt-out instructions in each communication, or by contacting our customer service department at firstname.lastname@example.org.
We also collect statistics about your use of third party products and services that you request information about through the portal. This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
Advertisements appearing on the portal may be delivered by us or one or more third-party web advertisers. These third party web advertisers may set cookies or other technologies on the portal. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you.
We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our portal in order to provide you with tailored advertisements on our portal and across the Internet. These companies may collect information about your activity on our portal and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
We may also share your Personal Information with third parties with your consent such as if you request information about third party products or services or if you apply for products or services offered by third parties through RELNKS.
Our servers (and certain service providers) are also located in Canada and accordingly your Personal Information may be available to the Canadian government or its agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.
From time to time we may employ third parties to help us improve the portal. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the portal and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.
SHARING OF PERSONAL INFORMATION
Generally, we do not disclose your personal information to third parties without your consent unless permitted or required by applicable law. There are some situations in which we may disclose your personal information without your consent. For example:
In some cases, your consent will be implied. For example, when the services we are providing to you require us to provide your information to a third party (such as to a lender in a real estate mortgage transaction) we would rely on your implied consent to the disclosure. Lastly, from time to time we may transfer your personal information to RELNKS’ service providers. Under PIPEDA, a transfer to a service provider is not considered to be a disclosure for which your consent is required; however, we will use contractual or other means to ensure that the third party service provider is bound by obligations regarding privacy that are consistent with this Policy and our obligations under PIPEDA. Examples of transfers to service providers would be situations in which we contract with third parties to provide us with services such as archival file storage or insurance. Service providers may be located in various countries, so please be aware that authorized officials of governments in those countries may be lawfully able to access your personal information without your knowledge or consent pursuant to the laws of such countries. To the extent that we are permitted to do so by applicable law, we will notify you if we are advised that this access has occurred.
We might share your data with third parties for business purposes or for any of these reasons:
- Detecting fraud
- Providing services
- Internal research
- Quality control
With your consent, we might share your personal information with third parties, including our affiliates, mortgage partners and service providers, for these reasons:
- Business purposes
- Pre-populating your information to make your experience easier
To opt out of sharing your data, please contact us by email at email@example.com.
ACCURACY OF YOUR PERSONAL INFORMATION
It is important that the personal information that we have on file be accurate, complete and up-to-date. If, during the course of any matter through which you are using the RELNKS portal, any of your personal information changes, please inform us so that we can make any necessary changes. We may also ask you from time to time whether your personal information is up-to-date.
COOKIES AND OTHER WEBSITE TECHNOLOGIES
The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer.
RELNKS uses various administrative and technological safeguards to ensure that your personal information is protected against loss, theft, misuse, unauthorized access, disclosure, copying or alteration. These include: security of our physical premises; lawyer user’s professional obligations; security software and firewalls to prevent unauthorized computer access or “hacking”; and internal passwords that restrict access to our electronic files.
ACCESS TO YOUR PERSONAL INFORMATION
You have a right to challenge the accuracy and completeness of your personal information and to have it amended, as appropriate. You also have a right to request access to your personal information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal personal information about another individual, your access may be limited or denied. If your request for access is denied, RELNKS will notify you in writing of the reason for the denial. RELNKS does not use your social insurance number as a way of identifying or organizing the information we hold upon you.
Like most other organizations, we may monitor traffic patterns, site usage and related site information. We may provide aggregated information to third parties, but this does not include any personally identifiable information.