CARSON, DUNLOP & ASSOCIATES LTD.
Chief Privacy Officer
Carson, Dunlop & Associates Ltd.
120 Carlton Street, Suite 407
Toronto, Ontario, Canada
We are responsible for personal information in our possession or custody, including: (i) information that needs to be disclosed to third parties in the course of our business; and (ii) personal information of clients of home inspectors using our services. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their possession or control.
- Identifying Purposes We will clearly identify and document the purposes for which we may collect, use or disclose personal information at or before the time of collection. As part of our business operations, we may collect and use certain personal information for the following purposes:
- To provide you with Carson Dunlop products and services that you request
- To provide information regarding Carson Dunlop and our products and services that may be of interest to you (if you wish to stop receiving such information, simply provide written instructions to our Chief Privacy Officer or, for electronic communications, simply select the unsubscribe mechanism in such electronic communication)
- To respond to any correspondence or other communication we receive from you and, in some cases, to give effect to any request included in such communications; and,
- To identify trends and patterns related to the use of goods and services in the home inspection and construction industries and to provide information on those trends and patterns to our customers and others.
Access to certain areas of a Website and procurement and use of certain of our products may require that you create an account. This may entail the collection of the following personal information: (i) your name; (ii) telephone number(s); (iii) mailing address; (iv) e-mail address; (v) fax number; (vi) employer/principal name if you are creating an account in regard to your employment or engagement; and (vii) the type of credit card used and the last four digits of your credit card (your complete credit card information will be collected and retained on file for future transactions if and only if you have specifically requested that we do so). We may suggest and recommend our products to you based on your user profile generated by your registration information.
Our Websites use Google Analytics. This is a web analytics tool provided by Google Inc. to record your online activities on our Websites and what content is viewed, the time spent on any webpage, the frequency of such views and patterns relating to the foregoing. The evaluation is done anonymously. Google Analytics cookies, including the Google Analytics tool “anonymous IP address” and usage data, are usually transmitted to a Google server in the United States and stored there. For further information, please refer to https://support.google.com/analytics/answer/6004245?hl=en. Google Analytics offers the option to opt out of data collection through access to https://support.google.com/analytics/answer/6004245?hl=en.
In some instances, we may ask you to provide us with your feedback in terms of your user experience on a Website, with respect to any dealings with us or with respect to any of your purchases through a Website. If you choose to provide us with such feedback, you agree that we may use it internally to assess any changes or improvements to our Websites, our products, our operations, our pricing, our marketing materials and practices as well as our other business practices. If you provide us with contact information, we may contact you to obtain clarifications or obtain your further input. We may also post your feedback on our website or our social media pages (such as our Facebook page) but will only include your full name if you provide us with your consent.
In addition, in the unlikely event that Carson Dunlop sells all or substantially all of its assets, personal information, including your collected personal information and that of your clients will be one of the transferred assets. Certain personal information may also be disclosed to a prospective buyer in anticipation of such a sale for due diligence purposes. Any such prospective buyer must first agree to be bound by confidentiality obligations limiting its access, use and retention of such personal information to its due diligence in terms of such proposed transaction.
The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances.
If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose before such additional use. We will state the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.
- Limiting Collection We will limit the amount and type of personal information collected to that which is reasonably necessary for our identified purposes and we will only collect personal information by fair and lawful means. We may collect the following types of personal information from individuals visiting our Websites or purchasing Carson Dunlop products and services:
- Credit card details (credit card type and last four digits of credit card number if purchasing a Carson Dunlop product or service – full credit card details will be collected directly by our service provider providing payment processing services)
- Residential address (if purchasing a Carson Dunlop product or service)
- Residential telephone number (if purchasing a Carson Dunlop product or service)
- e-mail address
We monitor access to certain Website resources and features by end users and other browsing patterns and history. Any such data will be anonymized and aggregated and will not be associated with you specifically.
- Limiting Use, Disclosure and Retention Your personal information collected by Carson Dunlop will be used to deliver services, products or programs you have requested or enrolled in. In addition, you may receive invitations to participate in relevant surveys, and copies of Carson Dunlop’s e-newsletter.Carson Dunlop also uses your personal information to inform you of other products, services or benefits available from Carson Dunlop and its affiliates.For example:
Carson Dunlop may also contact you via surveys to conduct research about your opinion of current services, or on other research initiatives. Carson Dunlop will not, however, contact your clients or affiliated groups, including real estate agents, without your permission.Carson Dunlop will not use or disclose your personal information for purposes other than those for which it is collected, except with your express consent or as required by law. Carson Dunlop will not rent or sell your personal information or that of your clients or affiliated groups, including real estate agents, to any third party.Unless otherwise required by law, Carson Dunlop will retain your personal information and that of your clients or affiliated groups, including real estate agents, only for as long as is necessary for the fulfillment of those purposes. Notwithstanding the foregoing, personal information included in our inspection reports will be retained indefinitely.If you are a user of Horizon, please note that Horizon compiles inspection reports and maintains archive records, including inspection work orders and reports. These Horizon records and reports may include personal information. We will not access or use personal information in the archive records in any way for business purposes without your express permission. This includes contacting clients or real estate agents.Carson Dunlop retains the right to review the inspection reports created by Horizon, and or stored on our Horizon Website, for the purpose of compiling information related to the maintenance or updating of the Software, and or for the purpose of accumulating information which, in the aggregate, may be used by Carson Dunlop from time to time for the purpose of identifying trends and or products or services which may be of interest to you or other customers of Carson Dunlop or others. Carson Dunlop will not disclose any personal information about any identifiable individual which can be directly and specifically connected to any such identifiable individual.Your personal information is kept at secure facilities and on secure servers owned and operated by third party service providers retained by Carson Dunlop that are located in Canada although our website makes use of third party analytical and marketing services which makes use of servers and facilities outside of Canada (including, without limitation, cloud solutions and other distributed processing solutions). We may, however, in the future elect to relocate such servers to the United States. Moreover, we may transfer your personal information outside of Canada to our affiliates, business partners, and service providers located in other countries. By accessing a Website and/or using our online products, you consent to such transfer to, and processing in, Canada, the United States, and these other countries.
- Safeguards Carson Dunlop is committed to protecting the security of your personal information and we will protect your personal information and that of your clients or affiliated groups, including real estate agents, with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use security technologies and procedures to help protect your personal information and that of your clients or affiliated groups, including real estate agents, from unauthorized access, use or disclosure. For example, we store personal information you provide on computer systems with limited access in controlled facilities. When confidential information (such as credit card numbers) is transmitted over the Internet, it is protected through the use of SSL Encryption.We make our employees aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. Our service providers that process, store, receive or otherwise handle your personal information are contractually bound to adopt and maintain such practices and measures in regard to your personal information.Our methods of protection include physical measures (for example, restricted access to offices), organization measures (for example, limiting access on a “need to know” basis), and technological measures (for example, the use of passwords and encryption).While reasonable safeguards and security measures are in place to prevent against unauthorized use, access, alteration, disclosure or destruction of your personal information, Carson Dunlop cannot guarantee that such safeguards are impenetrable from breaches. You assume the risk of unauthorized use, access, alteration, disclosure or destruction of your personal information that may occur as a result of transmission over networks outside the control of Carson Dunlop or access of encrypted information by unauthorized persons.
- Access Upon written request addressed to our Chief Privacy Officer, except where applicable privacy laws otherwise allow or require, we will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information and may also require that such individual provide sufficient proof to validate his or her identity. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to recover our reasonable costs associated with such request. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.If you feel that your personal information or that of your clients or affiliated groups, including real estate agents, we hold is inaccurate or incomplete, you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the personal information or that of your clients or affiliated groups, including real estate agents. Any such request must be in writing.In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.
IP – An abbreviation for Internet Protocol, the basic network transmission protocol of the Internet.
SSL Encryption – SSL, or Security Socket Layer, encrypts your customers’ credit card numbers, as well as other confidential information. This allows for secure online business. When your Web page has SSL, your page will show a small gold lock or key in the lower right hand side of your browser.
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