(Last updated 12/1/2024)
This Privacy Statement covers the website https://www.RealNex.com. By accessing, using or registering with RealNex' website, you accept and agree to RealNex' Privacy Statement. RealNex provides a variety of online services for commercial real estate professionals. RealNex values your privacy, feedback and candor very highly. Any user information we collect is considered private and we do not use it or share it except as permitted herein, without the user's permission. We use this personal content at RealNex to provide the best quality service possible. The following privacy statement summarizes RealNex' protection and use of any personal content provided by visitors to the RealNex website.
This Statement does not apply to any public area of RealNex' website or services. In the event you submit personal content to contact another member, contact a listing party about a listing, create a listing, add a contact, such information becomes publicly available and RealNex is not responsible for the personal content you choose to submit to these services, forums, listings, or persons.
RealNex collects user information from several areas of the RealNex website including the new member registration area (where RealNex collects each user's name, street address, telephone number, and email address); products; business services; the adding and editing of property listings; the adding and editing of professional profiles; email forms; and any surveys or contests that RealNex may sponsor. RealNex may collect individual user search activity for statistical, archival, and business purposes. RealNex collects financial information (such as billing address, credit card number, expiration date) for billing payment and credit card authorization purposes. RealNex may track the IP address of a user's computer or place a "cookie" in the browser files of a user's computer. This is required by RealNex services to provide automated features.
Specifically, we collect the following information you provide to us:
Collected information helps RealNex better understand its users' needs in order to improve its product and service offerings. Email addresses are used to communicate with members, convey useful information, distribute promotional emails and alliance partner emails and for website administration purposes. Users may be deleted from RealNex email lists at their request. Users must affirmatively opt-in in order to receive SMS/text messages and must confirm that they agree to receive SMS/text messages from RealNex, LLC regarding updates, promotions, and other notifications. Message and data rates may apply. Users can opt-out at any time by replying "STOP" to any message or contacting RealNex at support@realnex.com.
For the purposes of this Privacy Statement, “Personal Information” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. The categories of Personal Information we collect depend on how you interact with us, our services, and the requirements of applicable law. Personal Information may be used to contact users for the purpose of research, product development, marketing, or customer service, if the user has opted to receive such communication. User search activity may be collected and analyzed and may be utilized by RealNex in the aggregate or in the abstract for a variety of business purposes. Financial information is used to bill users for products and services purchased. This information is not shared with anyone outside of RealNex. IP address and cookie log data may be analyzed to better understand traffic flows and user preferences. RealNex may retain the data it collects indefinitely. You may have your Personal Information deleted or deactivated by calling us at 281.299.3161or sending an email to Support@realnex.com.
Though RealNex makes every effort to preserve user privacy, we may need to disclose Personal Information when required by law wherein we have good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website.
RealNex shares member information in the following scenarios. When a member enters a sale or lease listing in the listing service or Deal Room, listing contact information is also entered. During this process, the listing submitter is able to view other members' contact information when he adds another contact beside himself to the listing. In addition, members searching RealNex can view contact information (name, email and phone number) when they view a property listing profile. RealNex allows users to share contact information with one another. This contact information is shared with the users who have property listings or deals that match the buying or leasing criteria. Unless required by law as detailed in this section or a user specifically takes action as discussed in this paragraph, RealNex does not share individual user search activity information and such activity information remains private to the individual user and to RealNex.
RealNex shares information with its alliance partners for the purpose of providing related services in which we deem our users have interest. Key billing information (such as credit card number, expiration date and dollar amount) gathered from users making online purchases of products or services may be shared with our credit card processing partner, in order to authorize charges to the credit card. RealNex may also use third party providers to perform email and postal mailings on behalf of RealNex, but this information (such as name, address and email) is confidential and is not used by the provider for any other purpose.
Please be aware that in the event RealNex merges with a third party, or in the event all or substantially all of RealNex' assets are acquired by a third party, customer information, including Personal Information, company and listing information, will be shared and/or transferred to such third party. The information may only be used or shared by such third parties for the primary purpose for which the information was originally collected. If such third parties, or if RealNex for its own business needs, desire to use the personal content for another purpose, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal content prior to the information being used for a new purpose, and you will have the opportunity to opt out of such new use of your personal content.
RealNex' clients and their Personal Information are considered to be RealNex' greatest asset and thus their privacy is treated with the utmost regard and respect. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Cookies are used on this website. A cookie is a small text file that is stored on a user's computer for record-keeping purposes. We use both session cookies and persistent cookies. We use session cookies to make it easier for you to use our website and to enable certain specialized functionality that requires maintaining information about your session. A session cookie is not stored on your hard disk and expires when you close your browser. A persistent cookie remains on your hard disk for an extended period of time. You can remove persistent cookies by following the directions in your Internet browser's "help" files.
If you select the "Remember Me" function on the website, we will store a persistent cookie on your hard drive which allows you to bypass the login requirement each time you access the website. Additionally, we use a persistent cookie to enable us to track and target the interests of our users to enhance the experience on our website.
Our website may offer publicly accessible blogs, testimonials or community forums. You should be aware that any information you provide in these areas may be read, collected and used by others who access them. To request removal of your personal content from our blog, testimonial or community forum, contact us. In some cases, we may not be able to remove your personal content, in which case we will let you know if we are unable to do so and why.
Our website includes links to other websites whose privacy practices may differ from those of RealNex. If you submit personal content to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
We offer subscribers the option of syncing their RealNex account with their personal Google account. This allows subscribers to sync contact and calendar data between their Google account and RealNex. Data received from Google is used to populate the contacts and calendar modules within a subscriber’s account. This data is solely accessible by the subscriber, and no data is ever shared with any outside parties. RealNex’ use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
RealNex utilizes email as a vital and primary communication channel with registered users and customers. As a registered user/customer, you hereby acknowledge and grant RealNex the permission to communicate with you via email (as well as other communication channel such as phone and fax) for any purposes RealNex determines to be relevant including, but not limited to, system messages, product updates, service announcements and other marketing messages. RealNex will use best efforts to honor customers request to opt out of marketing messages, but under no circumstances will RealNex have any liability for sending any email to its registered users/customers. You may correct or update your personal content by making the change on your member profile page. Users must affirmatively opt-in in order to receive SMS/text messages and must confirm that they agree to receive SMS/text messages from RealNex, LLC regarding updates, promotions, and other notifications. Message and data rates may apply. Users can opt-out at any time by replying "STOP" to any message or contacting RealNex at Support@realnex.com.
Unless indicated otherwise, subscriptions will automatically renew using the Customer's current credit card account number unless Customer cancels their subscription on the RealNex website five (5) business days prior to the renewal date to cancel such subscription. Once the cancellation is processed, a confirmation email will be sent via the customer's email account on record with RealNex. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
RealNex may provide notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email notice, written or hard copy notice (including via fax), or through posting of such notice on our website, as determined by RealNex in our sole discretion. RealNex reserves the right to determine the form and means of providing notifications to our users, provided that you may opt out of certain means of notification as described herein. RealNex is not responsible for any automatic filtering you or your network provider may apply to email notifications we send to the email address you provide us. We recommend that you add RealNex.com to your email address book to help ensure you receive email notifications from us. If you wish to contact us regarding any aspect of this Privacy Statement, you may call us at 281.299.3161 or email us at Support@realnex.com.
If RealNex decides to change its privacy statement, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. RealNex reserves the right to modify this privacy statement at any time, so please review it frequently. If RealNex makes material changes to this statement, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.
Our Services are not directed at children under the age of 16. We do not knowingly collect any information from children under the age of 16, and any such disclosure is strictly prohibited. If you are a parent or guardian and believe your child has uploaded Personal Information to our Services without your consent, you may contact us as described in Section VII below. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it.
You acknowledge and agree that regardless of your physical location or the location of any server on which your information may be accessed or used that this Privacy Statement and the laws of the United States of America shall govern and control the privacy issues related to the RealNex Services.
If you are a resident of California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) (Civil Code Section 1798.100, et seq.) (collectively, “California Law”) and “Shine the Light” laws provide you with additional rights regarding your Personal Information. This Supplemental Notice for California Residents supplements this Privacy Policy and applies solely to eligible residents of the State of California (“consumers” or “you”) as of January 1, 2023. Any terms used but not defined in this section have the same meaning as defined in California Law. In this section, Personal Information mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This notice takes precedence over the Privacy Statement with respect to your Personal Information for California residents if there is a conflict between the two.
A. Information We Collect
Depending on how you have interacted with us and our services, we may have collected certain information within the following categories of Personal Information from you in the last twelve (12) months. The categories below are those identified under California Law.
Please note that some of the categories of Personal Information described in California Law overlap with each other; for instance, your name is both an identifier and a type of data described in Cal. Civil Code 1798.80(e).
B. Disclosures of Your Personal Information
In the previous twelve (12) months, depending on how you have interacted with us and our services, we may have disclosed Personal Information for a business purpose to the categories of third parties indicated below.
Category of Personal Information Collected by RealNex | Categories of Sources of Collection | Business or Commercial Purpose for Use | Categories of Third Parties to Whom Personal Information Is Disclosed for a Business Purpose |
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Identifiers and categories of Personal Information in Cal. Civ. Code Section 1798.80(e) | Directly from you when engaging with our services |
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Internet or other electronic network activity information | Indirectly from you by your use of our website and services |
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Geolocation data | Indirectly from you by observing your interactions with our services through cookies and other automatic technologies |
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Inferences drawn from Personal Information | Indirectly from you by observing your interactions with our services |
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C. “Sales” or “Sharing” of Personal Information under California Law
RealNex does not sell your Personal Information for direct, monetary profit. However, we do engage in certain information disclosure activities as described in the Section above titled “Disclosure of Your Personal Information” that may be considered “sales” or “sharing” under California Law. For instance, our services may include social media plug-ins (such as the Facebook like button), widgets (such as the “Share” button), cookies or other tools made available by third parties, such as social media companies, that may result in information being collected or disclosed between us and the third parties for various purposes, including to select and serve personalized advertisements to you and others. These third parties may set and access their own cookies, web beacons, and embedded scripts on your device, and they may otherwise collect or have access to information about you, including unique personal identifiers such as an IP address, and they may disclose that information to us. Your interactions with these third parties are governed by the third parties’ privacy policies.
In the previous twelve (12) months, we have sold or shared the following Personal Information:
Category | Business or Commercial Purpose | Categories of Third Parties to Whom Personal Information was Disclosed That May be Considered a “Sale/Sharing” Under California Law |
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Identifiers |
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Internet or other electronic network activity information |
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Geolocation data |
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D. California Law Privacy Rights
Under California Law, California residents have the following rights, which can be exercised directly or in certain cases, through an authorized agent (as discussed below):
Please note that we may still use aggregated and de-identified Personal Information that does not identify you or any individual.
Please note that the deletion of your Personal Information or opting out of the sale or sharing of your Personal Information may impair some features and functionality of the RealNex services, including the possible deletion of your account and delisting of your listings.
E. How to Exercise Your Privacy Rights
To exercise privacy rights as described above, please submit a verifiable consumer request by emailing us at Support@realnex.com.
F. Verifiable Consumer Requests
To exercise your right to know, access, delete, or correct your Personal Information as described above, we may take reasonable steps to verify your identity or authority to make the request and confirm the Personal Information relates to you.
Only you, your parent, guardian (if you are under 13 years or age), conservator, a person to whom you have given power of attorney pursuant to California Probate Code sections 4000 to 4465, or an authorized agent may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your minor child if necessary. If an authorized agent makes the request on your behalf, then (i) we will need proof that you have provided the agent with power of attorney; (ii) you must provide the agent with signed permission to submit a request to access or delete; (iii) you must verify your identity directly with us; or (iv) you must confirm with us that you provided the authorized agent permission to submit the request.
We will ask you to provide certain information to verify your identity or authority to make the request: name, email address, and telephone number. Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request if we cannot verify your identity or authority to make the request. You may only make a verifiable consumer request for your right to access twice within a 12-month period.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
G. Response Timing and Format
We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period immediately preceding the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
H. Data Retention
We may retain all categories of your Personal Information described above for as long as needed to carry out the purposes described herein or as otherwise required by applicable law. Unless we are required or permitted by law to keep your Personal Information for a longer period of time, when your Personal Information is no longer necessary to carry out the purposes for which we process it, we will delete your Personal Information or keep it in a form that does not permit identifying you. When determining the retention period, we take into account various criteria, such as the nature of the use of the RealNex services, your general relationship with us, the impact on our ability to provide you the services if we delete your Personal Information, mandatory retention periods provided by law and the statute of limitations, and our use of your Personal Information for aggregated market research.
I. Do Not Track
Some internet browsers, like Internet Explorer, Firefox and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform signals have not been adopted, we do not currently process or respond to “Do Not Track” or “DNT” signals.
J. California’s Shine the Light Law
Under California Civil Code Section 1798,83, California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us.
Eligible residents of Colorado, Connecticut, Utah and Virginia also have rights with respect to the Personal Information that RealNex collects about you. This Colorado, Connecticut, Utah, and Virginia Privacy Rights section supplements this Privacy Statement and applies solely to eligible residents of Colorado, Connecticut, Utah and Virginia. Any terms not defined in this section have the same meaning as defined under applicable Colorado, Connecticut, Utah and Virginia privacy law, including the Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act and Virginia Consumer Data Protection Act. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:
To exercise the rights described above, please submit a consumer request to us by:
A. Data Controller
RealNex, LLC., with registered offices at 504 Murphy Road, Suite L, Stafford, TX 77477, United States, Support@realnex.com collects and processes your personal data as a data controller within the meaning of the EU General Data Protection Regulation (“GDPR”) when you use our services. Personal data means any information relating to an identified or identifiable natural person, such as a name, contact details, an online identifier such as an IP address, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
B. Processing of Personal Data, Legal bases and Purposes
We process your personal data for the following purposes:
Categories of personal data processed | Purpose(s) | Legal basis |
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Information you submit to us (e-mail address, phone number, professional postal address, name, role, user account information and business relationship information, including information related to preferences and property listings) |
Handle claims, dispute, litigation and any other proceedings Comply with legal obligations and performance of compliance checks Managing our transactions (including but not limited to merger, acquisition, divestiture or liquidation) Data anonymization to collect and analyze market trend information |
Our legitimate business interest to run and develop our commercial operations Our legitimate interest to defend our legal interests Compliance with applicable law or regulatory requirements Our legitimate interest to conduct business dealings Our legitimate interest to understand the market and to improve our business |
Job applicant data (e.g., employment information, personal certifications and affiliations, job application) |
To communicate with you about your job application and to determine your qualifications for job positions |
Our legitimate interest to hire staff |
Personal data collected via functional cookies (e.g., your preferences) |
Enabling you to visit and use our Services |
Our legitimate business interest to run and develop our commercial operations |
Personal data collected through the use of social media plugins (e.g., your preferences, demographic data) |
Benefiting from social media-related analytics |
Our legitimate interests to develop commercial activities and improve our products and services |
C. International Transfers of Personal Data
We store information about you within the United States. As a US-based company, to facilitate our operations, we may transfer your information to the United States, and to other countries where our trusted third-party vendors may reside. Such transfers may happen only provided that appropriate safeguards are put in place.
D. Retention of Personal Data
We will retain personal data as long as necessary for the purpose for which the data was initially collected or otherwise processed, subject to applicable local retention requirements. In the event the legal basis for the processing of the personal data is consent, we will erase your personal data when you withdraw your consent.
E. Your Rights Under GDPR
You have the right to request access to your personal data and the right to rectify your personal data which are incorrect and/or incomplete. In certain circumstances, you have the right to erasure, the right to data portability, the right to object to and the right to restrict the processing of your personal data. You also have the right to withdraw your consent at any time and free of charge, with effectiveness for the future. You have the right to lodge a complaint with the appropriate European Union supervisory authority. To exercise your rights or for further information concerning your rights, please contact Support@realnex.com
If you are located in Canada, the Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation (collectively, “Canadian Privacy Laws”) govern the collection, use and disclosure of personal information by organizations in the course of commercial activities. If you are located in Canada, this Canadian Privacy Rights section applies to you. Additionally, in certain Canadian provinces, provincial privacy legislation will apply to you, namely, for the Province of Alberta – the Personal Information Protection Act (Alberta), for the Province of British Columbia – the Personal Information Protection Act (British Columbia) and for the Province of Quebec – the Act respecting the protection of personal information in the private sector also applies to you and the expression “Canadian Privacy Laws” therefore also includes reference to these provincial laws. If you live in Canada and any part of our general Privacy Notice conflicts with this Canadian Privacy Rights section, this Canadian Privacy Rights section governs to the extent of the conflict.
Personal Information
Under Canadian Privacy Laws, personal information means any information about an identifiable individual, which may, in certain circumstances, include information gathered from your use of the Services.
Consent
In Canada, express or implied consent is the legal basis upon which organizations may collect, use and disclose personal Information. Accordingly, personal information will only be collected, used, and disclosed by us for the purposes described above in this Privacy Statement under the heading “How We Use Your Personal Information”, with your express or implied consent. We will collect your express consent for any sensitive personal information that we may collect, use, or disclose. Otherwise, your continued use of the RealNex services signifies your consent to our collection, use, and disclosure of your personal information as described in this Privacy Statement, as it may be amended from time to time after you have been informed of any such amendment. Your continued use of the services after having been informed of any amendment to this Privacy Statement will be deemed a consent by you to any such amendment; if you do not agree with this Privacy Statement or any amendment, do not access the services. If you provide personal information of a third-party to us, you represent that you have complied with the requirements of Canadian Privacy Laws with regards to its collection before providing it to us and for us its use and disclosure as set out in this Privacy Notice
Online Behavioral Advertising
With respect to the information that we collect using cookies or similar technologies that we have described above, you can opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Your Rights
Withdrawal of Consent
Under Canadian Privacy Laws, you have the opportunity to withdraw your consent at any time to our collection, use or disclosure of your personal information, subject to reasonable prior notice and applicable legal and contractual restrictions. Depending on the nature of the personal information for which you choose to withdraw your consent, if you do withdraw your consent, we may not be able to provide our products and services to you; we will explain the implications of withdrawing consent to you when we receive your notice of withdrawal. If you withdraw your consent in respect of any personal information that has been provided to third parties, we will advise such third parties of your withdrawal to the extent required by Canadian Privacy Laws.
Right to be informed
You have the right to be information about the personal information that we collect, use, process, disclose, retain and have deleted about you. You may request additional information to clarify the extent of your consent.
Right to an Accounting
You have the right to receive an accounting of the categories of third parties to whom we have disclosed your personal information.
Rights of Access, Correction
You have the right to access the personal information we maintain about you and you have the right to correct or supplement your personal information if it is inaccurate or misleading and to have it completed if it is incomplete. Where appropriate, to have personal information that you have corrected or supplemented transmitted to third parties who have had access to your personal information.
Right to be notified of a Data Breach
If you are in Quebec, you have the right to be informed of a confidentiality breach involving your personal information that may cause you a serious harm. If you are in the rest of Canada, you have the right to be informed of a breach of security safeguards affecting your personal information where there is a real risk of significant harm to you.
Right to Lodge Complaints
You have the right to lodge a complaint about our collection, use or disclosure of your personal information with the Office of the Privacy Commissioner of Canada and any applicable provincial privacy commissioner’s office having jurisdiction.
Additional Rights in Quebec
If you are in the province of Quebec, you have the following additional rights:
Right of Deletion
You may request under certain circumstances the deletion of your personal information.
Right to Data Portability
As of September 22, 2024 you will have the right to be provided, in a structured, commonly used and machine-readable format, with a copy of your personal information or to have it transferred directly to another entity or person. To exercise the above rights, please get in touch with us using the contact information provided under the heading “Contact Us”. We will consider and process your request within a reasonable period of time and in any event within thirty days of receipt of your request or such longer time as we may be permitted under Canadian Privacy Laws. Please be aware that under certain circumstances, Canadian Privacy Laws may limit your exercise of these rights. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. If we refuse to rectify your personal information, we will attach a statement to the record that sets out the reason why we have refused to make the rectification. We will also retain the personal information that has been the subject of an access request or a rectification request for as long as necessary to allow you to exhaust any recourse provided by law.
International Transfers
As noted above in this Privacy Notice, your personal information may be transferred to and stored at a location outside of your jurisdiction of residence. Please note that local data protection laws where your personal information is stored or processed may not provide as much protection as the data protection laws in force in your jurisdiction of residence, but we nevertheless ensure that we take reasonable steps to ensure that your personal information will not be used by such persons storing or processing the information for any purpose other than assisting us for the purposes described in this Privacy Statement. If you would like to receive more information about our policies and practices with respect to our use of service providers outside of Canada who handle your personal information or if you have any questions about our collection, use, disclosure or storage by any service providers outside of Canada on our behalf, please contact us at the address under the heading “Contact Us”.
If you provide personal information of a third party to us, you represent that you have complied all the obligations imposed by Canadian Privacy Laws regarding the transfer of personal information outside the jurisdiction of residence.
Business Transfers
Where we disclose your personal information in the event of a business transfer described in our Privacy Statement above, we will ensure that the information is treated confidentially by the parties to the transaction and that the information will be protected by security safeguards appropriate to its sensitivity. If the transfer is completed, we will require that the parties to the transaction continue to treat your personal information in accordance with Canadian Privacy Laws.
Service providers
Where we disclose personal information to services providers, we ensure that they are bound by contractual obligations to:
Electronic Marketing Messages
We send electronic marketing messages for the purposes described above in this Policy, however, notwithstanding Our Opt-in/Opt-out Policy described above, Canada’s anti-spam legislation contains special rules that regulate the way in which we may send these electronic messages to you. If you are located in Canada, we will only send electronic marketing messages to you if we have your prior opt-in consent, unless an exception or a specific form of implied consent applies. You may learn more and sign up for our electronic mailing list by contacting us.
Information security and governance
Our internal policies and practices provide for:
Each employee who uses personal information is bound by confidentiality obligations and has received appropriate training. In addition, each employee may only access personal information that is necessary for the performance of his or her duties. In the event of a breach, our governance policies and practices provide for sanctions.