Transitions Realty Inc. and its affiliates, subsidiaries, divisions and brands (collectively, “TRI”) respect your privacy and are committed to maintaining the privacy, accuracy, and security of your Personal Information in accordance with applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act, the General Data Protection Regulation, and best industry practices. We have posted this Privacy Policy to let you know what information we collect, how it is handled and with whom it may be shared.
“Personal Information” is information about you, as an identifiable individual, that is protected by applicable privacy legislation. All Personal Information received by us shall be maintained and used only in accordance with this Privacy Policy.
In this Privacy Policy, “we”, “our”, and “us” mean TRI; “you” and “your” mean an individual who visits our websites and/or provides us with Personal Information, whether through our websites or otherwise, in order to request information, purchase products or services or otherwise. Any reference to “Affiliate” refers to any entity, individual, firm, or corporation, directly or indirectly, through one or more intermediaries, controlling, controlled by, or under common control with TRI. Any reference to “Marketing Agents” refers to any individual person, company, or organization that participates in the TRI Marketing Program, which allows HTML linking between Marketing Agent’s websites and the TRI website, as well as coupon code referrals for the purpose of referring potential customers to TRI for a commission.
Accountability
We train our employees to manage your Personal Information properly and have designated an individual as Chief Privacy Officer who is accountable for compliance with this Privacy Policy.
Collecting your Personal Information
We collect information only by lawful and fair means and not in an unreasonable or obtrusive way. We collect Personal Information such as your name, address, telephone number and email address when you create and open an account and/or request information. By submitting Personal Information to TRI, you agree that we may use or disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law. You may also be required to provide other
Personal Information such as name, company name, email and mailing addresses, telephone number, login, password details, and credit card number to TRI and any third-party payment provider when you purchase products or services. We may partner with other companies for payment processing, wherein the payment information you submit is collected and used by them in accordance with their privacy policies. We do not, however, sell your Personal Information to others except in the context of a sale of TRI, as mentioned below.
We may also collect technical information such as your internet protocol (IP) address and the date and time you accessed our websites. We may also use cookies to help us provide you with better service. A cookie is a small piece of information that is sent by a website and stored on your device and contains information needed to interact with a user. If you disable or refuse to accept cookies, you may not be able to access and use many of the tools offered on our websites.
In addition to cookies, we may collect other technical tracking information such as web beacons and other unique identifiers. This information is used to track your session on our websites and to customize website content. This information may also be obtained from emails or newsletters that we send to you in order to gather email statistics, such as date and time emails are opened and whether they are forwarded or printed from a device. Finally, we may use third-party click tracking analytical tools and third-party retargeting networks that display TRI advertisements to you on other sites to collect non-identifiable information or other aggregate information.
We limit our collection of your Personal Information to only those details necessary to fulfill the purposes for which it was collected, unless you have otherwise consented.
Use and Disclosure of Your Personal Information
TRI may use and disclose your Personal Information for the following purposes:
We may share your Personal Information with Affiliates service providers that help with our business operations, such as website hosts and management companies, third party payment processors, Affiliates and marketing services providers. We may disclose Personal Information in connection with a prospective purchase or merger or sale involving TRI. In the event of a sale of TRI, you agree that we may assign, sell, license or transfer any of your Personal Information to such buyer.
We may use third-party providers to facilitate our services and/or to assist us in managing client information. To the extent necessary, we may disclose Personal Information collected to one or more trusted partners or Affiliates for the specific function and not for any other purpose. Third parties and Affiliates have agreed to hold this information in confidence. Such third parties include customer relationship management providers, credit card payment processors, or independent contractors. For example, we use Activecampaign for customer relationship management. You can read more about how Activecampaign uses your Personal Information here: https://www.activecampaign.com/legal/privacy-policy.
We may also share aggregate and/or non-identifiable information with third parties, including, but not limited to, Affiliates, Marketing Agents, advertisers and investors, for the purpose of advertising the number of visitors to our websites, or using such information to recognize customers referred to TRI or its Affiliates by Marketing Agents.
Except where collection, use, or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose such information without consent, we will not use or disclose your Personal Information for purposes other than those for which it was collected as set out above.
Direct Marketing
If your Personal Information is used for direct marketing, you have the right to object to such processing at any time free of charge by writing to us at the address provided below under “Requests for Access and Complaints”.
Consent to Collection, Use, and Disclosure
Your knowledge and consent are required for the collection, use and/or disclosure of Personal Information. By submitting Personal Information to us or our suppliers and agents, you agree that we may collect, use, and disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law and explicitly consent to such collection, use, and disclosure.
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use, or disclosure of Personal Information, or you may withdraw your consent to our further collection, use, or disclosure of your Personal Information at any time by delivering written notice to us at the address listed below under “Requests for Access and Complaints”. If you choose not to provide Personal Information or to withdraw your consent, you may not be able to use certain features of TRI’s websites or to access and use the websites at all.
We will act on your instructions as quickly as possible, but there may be certain uses of your Personal Information that we may not be able to stop immediately.
Access to, and Accuracy of, Personal Information
You have the right to request an electronic copy of your Personal Information we have on record and in our possession. Such requests may be sent to the address listed
below under “Requests for Access and Complaints”. Upon our receipt of a written request from you, and subject to any applicable exemptions, we will inform you of the existence, use, and disclosure of your Personal Information and will give you a copy of such information and the opportunity to correct any inaccurate Personal Information that is in our possession. Such access to Personal Information may be denied when:
We rely on you to help us keep your Personal Information accurate and complete. You can access or update your Personal Information, including contact and account information, on our websites if you have an online account or by contacting us at the address listed below, identifying your contact information and your requested changes.
If we deny your request for a copy of your Personal Information or refuse a request to correct information, we will explain why.
Erasure of Personal Information
You have the right to have your Personal Information erased and no longer processed where (i) the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed, (ii) you have withdrawn your consent or object to the processing of your Personal Information; or (iii) the processing does not otherwise comply with applicable law. If you request for us to erase your Personal Information, you may not be able to use certain features of TRI’s websites or to access and use the websites at all. If we have shared your Personal Information in accordance with this Privacy Policy, we shall inform any other data processors to erase any links to, or copies of or replications of your Personal Information.
Safeguarding Personal Information
The security of your Personal Information is one of our top priorities. In that regard, we have implemented appropriate administrative, technical and physical security
procedures to help protect Personal Information. We use encryption when transmitting Personal Information and employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to Personal Information. When you place orders on our websites, all of your order information, including address and credit or debit card number, is transmitted through the Internet using Secure Sockets Layer (SSL) technology, an industry standard security protocol.
While we do our very best to protect your Personal Information, we cannot guarantee the security or confidentiality of the Personal Information transmitted. We encourage you to use caution when using the Internet. As you are responsible for protecting the security of your Personal Information, you should not share your log-in information with any other person and should log out of your account at the end of each session. You are responsible for any activities which occur under your account. We are not liable for any loss or damage resulting from your failure to protect your log-in and account information. You must notify us immediately of any unauthorized use of your account or any other breach of security – whether suspected or otherwise.
Openness
We are committed to providing you with understandable and readily available information on our policies and practices related to management of your Personal Information.
Links
TRI’s websites may contain links to other sites which may have privacy practices and policies that differ from our own. We are not responsible for the content or
practices of any linked site. We recommend that you review the privacy policy of any site that you access through our websites. The inclusion of a link to a third-party site on our websites should not be construed as our endorsement of such website.
Retention of Personal Information
Personal Information is retained only as long as is reasonably necessary or relevant for the purposes identified above or as required by law. We may retain certain data as needed to prevent fraud or for other legitimate business purposes. Any retained Personal Information remains subject to this Privacy Policy. Once Personal Information is no longer reasonably necessary or relevant for the above-noted purposes, or as required by law, your Personal Information will be destroyed, erased, or de-identified.
Breach Notification
We will notify you of any involuntary disclosure of your Personal Information resulting from a data breach without undue delay and in any event within 72 hours of us first becoming aware of such data breach.
Changes to our Privacy Policy
From time to time we may make changes to this Privacy Policy. When changes are made, we will post an updated copy on our website and will post the date our Privacy Policy was last updated at the top of the Privacy Policy. Please check our Privacy Policy periodically for updates.
Requests for Access and Complaints
If you have additional questions, or to access, update or correct inaccuracies in your Personal Information, write to us at
Email: info@transitionsre.ca
Attention: Chief Privacy Officer
We will respond to your questions, concerns and complaints regarding this Privacy Policy in a timely manner. If you are not satisfied with our response to a privacy related matter, you may contact the office of the Privacy Commissioner of Canada.