- What is personal information?
- Sources of personal information
- Personal information you provide voluntarily
- Personal information automatically collected
- Purposes for which we collect personal information
- Disclosure of personal information
- Transfers of personal information outside of Canada
- Retention and security of personal information
- Right of access, rectification and deletion
- Refusal and withdrawal of consent
- Retention period of personal information
- Policy modification
- How to reach us
In effect as of October 2021
Respect for privacy and confidentiality is important for FairSquare Group Realty (hereinafter "FairSquare", "we", "our" or "ours"). For this reason, effective measures have been put in place by FairSquare to protect the confidentiality of the personal information we handle.
By accessing this Website or using our Services, you consent to our collection, use, disclosure, and storage of your personal information in accordance with this Policy. If you do not agree with this Policy, please refrain from using our Website or our Services. Of course, some Services can only be offered to you if you provide FairSquare with information of this nature; consequently, FairSquare may not be able to provide you with these Services if you decide not to provide us with the necessary personal information.
What is personal information?
This refers to any information which concerns a person and makes it possible, separately or in combination with other data, to identify them. This may include, for example, your name, email addresses, contact information and any similar information provided to FairSquare. Such information is not considered personal information when it is aggregated and cannot be associated with an identifiable individual.
Sources of personal information
We collect personal information about you from:
- when you provide this information to us directly, and
- when personal information about you is automatically collected as part of your use of our Services.
- our affiliates when they provide us with personal information about you.
third parties, when they provide us with personal information about you. Third parties who share your personal information with us include:
- Service providers. For example, we may use service providers to analyze how you interact and engage with our Website or our Services, or third parties may help us provide customer support to you.
- Advertising partners. We may receive information about you from some of our marketing or promotional service providers related to how you interact with our Website, applications, products, services, advertisements, or communications.
- Social Media. Certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile when you use your social media credentials (such as Facebook) to log into your FairSquare account.
Personal information you provide voluntarily
When you visit our Website, participate in a contest, promotion, survey or create an account on the Website or use our Services, you may be asked to voluntarily provide us with certain personal information (such as your name, email address, mailing address and phone number) so that we can communicate with you more efficiently and provide you with the Services you wish to obtain.
Personal information automatically collected
Cookies - When you access the Website, we use a browser feature called a "cookie" to automatically collect certain non-identifiable information about users, such as the Internet Protocol (IP) address that identifies the computer, the IP address of the Internet service provider, the name and version of the Web browser, the date and time the user accesses the Website, the Internet address from which the user directly accesses the Website, the operating system used, sections of the Website visited, Web pages read and images viewed and documents that displayed on the Website or downloaded from the Website. A cookie is a small text file containing a unique identification number that identifies a visitor’s browser (but does not necessarily identify the visitor) to our computers each time someone visits our Website.
FairSquare also works with advertising partners who collect and use information about your visits on our Website in order to present you with advertising that may be of interest to you. Our advertising partners and other third parties may also install cookies or Web beacons the moment you click on their advertising messages or links to their websites or services on our Website. This Policy does not apply to third party websites or the advertising providers of such third parties.
Purposes for which we collect personal information
FairSquare uses the personal information collected about you for the following purposes:
- respond to online service requests, questions, or comments that you send to us;
- create and manage your online account and provide you with the Services to which you have susbcribed to;
- personalize and improve your experience on our Website;
- email you with information about our products and services, as well as those offered by entities that are part of the same group of companies, promotional offers, important updates and real estate content;
- personalize and distribute online advertising content (or other media) and offer you products and services that may be of interest to you based on your preferences, interests or profile. To do this, we use information about your preferences, interests and profile, based on information you provide us as part of our Services, information generated when you interact with us or with entities that are part of the same group of companies, and statistical and demographic data available to the public. Rest assured that no sensitive information is used for advertising or marketing purposes and, to the extent possible, your information will be de-identified before it is used for these purposes;
- carry out analyzes and statistics on our audience, customers and on the use of our Services, in order to better understand the interests and preferences of our customers;
- manage, review and improve customer service and internal business processes;
- perform analyses of user data in an aggregate and anonymous manner;
- detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities;
- take any other action for which the personal information was collected;
- for other purposes described in this Policy or permitted by law.
If you prefer that your personal information not be used within our group of companies for advertising or marketing purposes or for other purposes that are not necessary for the provision of our Services or the good continuity of our operations, you can withdraw your consent at any time (subject to legal or contractual restrictions) by following the instructions set out in the “Refusal and withdrawal of consent” section below.
Tracking Information - FairSquare may use non-identifiable information about its users to create general tracking information reports about the demographics of users of the Website or our Services. This non-identifiable information is used for system and Website administration purposes, to better understand your interests and to improve the Website.
Electronic communications - If you provide your email address, FairSquare may occasionally send you commercial electronic messages in the form of email or SMS, namely, to inform you of our promotions, important updates, to offer you a new service or product, including those offered by entities that are part of the same group of companies or to send you real estate content. At any time, you can have your name removed from our mailing lists for these emails by unsubscribing from our emails or by modifying your preferences in your FairSquare account settings.
Targeted advertising - By using cookies and Web beacons, FairSquare can offer you advertising that better meets your needs, since it is targeted according to your interests. When you visit our Website, cookies and pixels tell us which pages you are interested in. Therefore, we may subsequently display advertising that meets your interests. These technologies do not contain any personal or financial information that could identify you. However, they can contain a unique identifier necessary for retargeting. When you click on one of these ads, FairSquare can also track the response rate of the campaign.
Disclosure of personal information
We cannot communicate to a third party the personal information contained in the file which we hold on you, except if you consent to it in writing or if the law provides for it (in the case of an investigation by judicial officers for example). In particular, we may disclose personal information contained in the file we hold about you to a third party if this communication is made for the same purposes.
The sending of personal information that concerns you outside FairSquare is then done in a way to ensure its confidentiality, even if you are the recipient.
Disclosure to corporate group entities - We may share your personal information with our affiliates (collectively the “Group”) to comply with applicable laws, regulations and requirements, ensure that your information is consistent, accurate and up to date and improve the quality and relevance of the Services you receive. Also, with your consent, we may share your personal information within the entities of the Group for statistical and analytical purposes or for any other purpose described in this Policy. Rest assured that each of the Group’s entities implements appropriate control measures to ensure the protection of your personal information, compliance with this Policy as well as compliance with applicable laws, regulations and requirements regarding the protection of personal information.
Disclosures to our service providers - We may also share your information with third party suppliers, consultants and other service providers that we employ for the purpose of performing tasks or rendering services on our behalf. These entities include, but are not limited to, our payment processing providers, Web analytics companies (e.g. Google Analytics), business intelligence service providers (e.g. Snowplow), email service providers (e.g. Mailchimp), and advertising partners.
Disclosure to government bodies - We may disclose personal information about you to government bodies that are authorized by law to obtain such information, or where FairSquare has reasonable grounds to believe that such information may be useful in connection with an investigation of unlawful activity, or to comply with a subpoena, arrest warrant or order of a court, competent person or body requiring the production of information, or to comply with court rules regarding the production of records or information, or to protect the rights and property of FairSquare.
Business transaction - If FairSquare is the subject of a merger or other restructuring, it may disclose your personal information to the organization resulting from that merger or other restructuring.
Transfers of personal information outside of Canada
FairSquare uses service providers located outside of Canada to accomplish certain specific mandates in the normal course of business. It is possible that certain personal information concerning you may be transferred to another country and be subject to the laws of that country.
FairSquare, however, makes sure to protect the personal information it has in its custody, including personal information entrusted to a supplier whether located in Canada or outside Canada.
Retention and security of personal information
Retention - The personal information that we hold about you is recorded in an electronic file whose objective is to allow you to benefit from FairSquare’s Services.
Security - We take and apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in our possession, to protect it against loss, destruction, theft, as well as against consultation, communication, reproduction, unauthorized use, and modification. Personal information contained in files is therefore only accessible to people who need to know it in the performance of their duties and who consult it only when necessary.
We have also implemented several security measures, including:
- Implementation of security systems in our business establishments to prevent unauthorized access to our premises.
- Measures to limit access to your information.
- Adoption of a policy on the protection of personal information applicable to all our employees concerning the obligation to preserve the confidentiality of personal information contained in files. Violation of these rules results in penalties up to and including dismissal.
- Implementation of appropriate protection and security measures relating to our computer systems and the information they contain to prevent any unauthorized access or disclosure of this information.
- Implementation of rigorous management of passwords and the use of firewalls.
- Establishment of a constant review of event logs to detect any abnormal activity or security incident.
However, due to the nature of the Internet and the technologies that result from it, the risks associated with security and confidentiality cannot be eliminated and FairSquare cannot guarantee that your personal information will not be disclosed in a manner contrary to the provisions of this Policy.
To the extent possible, we ensure that the personal information in the file we hold on you is up to date before we use it to make a decision that affects you.
Unless you consent or the law provides for it, the personal information in the file we hold on you is not used for purposes that are not relevant to the provision of our Services and for the purposes listed in this Policy.
- Physical measures:
Right of access, rectification and deletion
By contacting FairSquare at email@example.com, you can:
- request access to your personal information and obtain information relating to the collection, use and disclosure by FairSquare of such information;
- Request to modify or update your personal information; and
- Request to delete your personal information.
Subject to certain exceptions provided by law, you will be able to obtain reasonable access to the personal information we hold about you and you will have the right to question the relevance and accuracy of that information and to have it amended as necessary. You can help FairSquare maintain the accuracy of your information by notifying FairSquare of any necessary changes.
If you make a request to delete your personal information, it will be processed under the applicable laws. FairSquare may still retain some of your personal information to comply with its legal and regulatory obligations or if it is still necessary for the purposes for which the company collected it.
Refusal and withdrawal of consent
By contacting FairSquare at firstname.lastname@example.org, you can withdraw or modify your consent to our use and disclosure of your personal information or refuse to participate in certain uses and disclosures, subject to legal or contractual restrictions. If you refuse to provide us with your personal information or to give us the required consents with respect to it, it may be impossible for us to do business with you or provide you with the Services requested.
Electronic communications - At any time, you can have your name removed from our mailing lists for promotional or marketing electronic communications by unsubscribing from our emails or by modifying your preferences in your FairSquare account settings. In such event, and if you have an account for our real estate sales services, we will continue to send you non-promotional communications, such as service-related emails.
Targeted advertising - You may opt out of personalized advertising from third-party advertisers and advertising networks that are members of the Digital Advertising Alliance of Canada (DAAC) by visiting the DAAC Opt-Out Page.
Retention period of personal information
We keep your personal information for as long as we have a legitimate need to do so. Even if you have stopped doing business with us, we will need to keep certain information because, among other reasons, it is required by law. When this information is no longer needed, it is destroyed. As part of the process of destroying information, we follow strict rules and ensure that no unauthorized person gains access to it.
We may make changes or additions to this Policy at any time, so we encourage you to review it periodically. If we make any changes to this Policy, we will notify you by changing the effective date of this Policy at the top of the page.
How to reach us
For any questions or comments about this Policy, please write to us at email@example.com or at the following mailing address: FairSquare, 2-20 St Mary’s Rd, Winnipeg, Manitoba, R2H 1H1.