PRIVACY POLICY (Last Updated: October 7, 2019)

  1. Introduction This privacy policy explains the privacy practices of Carson, Dunlop & Associates Ltd. (referred to as “Carson Dunlop”, “us”, “we” or “our”). This privacy policy applies to the collection, use and disclosure of personal information in connection with Carson Dunlop operated websites, including those located at,, or (collectively, the “Websites”) and in connection with the provision of Carson Dunlop’s products and services including, without limitation: (i) HORIZONTM(Carson Dunlop’s web based home inspection reporting and business management system); (ii), Home Reference Book®; (iii) Carson Dunlop’s home inspection and related training programs; and (iv) Carson Dunlop’s property inspection business. Our privacy policy may be amended from time to time, so we encourage you to periodically check our Websites for the current version. Notice of any such modification will be provided in the header of this Privacy Policy by way of an amended date of last update. A revision history with respect to changes made to this Privacy Policy is available upon written request.  Printed copies of our current privacy policy are also available by contacting our Chief Privacy Officer whose contact details are provided below.


  1. Minors. If you are less than the age of majority in the province or territory in which you reside, you must have one of your parents or legal guardians review this privacy policy and agree to all of its terms and conditions on your behalf. We do not knowingly retain any personal information about any individual under the age of 16 years of age and, to the extent permitted to do so by applicable laws, we will securely delete such information from our systems upon being requested to do so by a parent or legal guardian. We may, however, retain personal information about an individual that is less than 16 years of age where: (i) such individual has purchased a product through a Website; (ii) such personal information is relevant to litigation or potential litigation; (iii) such individual has undertaken any wrongful conduct or conduct that is otherwise actionable in regard to the exercise by Carson Dunlop or its affiliates of any remedy or recourse available to them; and/or (iv) such retention is reasonable and otherwise permitted under applicable laws.
  2. Our Commitment to Your Privacy The relationship between you and Carson Dunlop is based on trust. We value the trust you have placed in us and are taking all appropriate measures to safeguard your personal information and that of your clients, and to maintain your confidence. Carson Dunlop has established this privacy policy to ensure that your personal information and that of your clients is protected and that all our practices and procedures comply with relevant personal information protection and privacy legislation. Accordingly, we adhere to the privacy principles set out below, which are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada). As used in our privacy policy, the term “personal information” means information about an identifiable individual including their home or other real property, but does not include the name, title or business address or business telephone number of an employee of an organization.
  3. Accountability Carson Dunlop is responsible for all personal information under our control. If we provide you with services which require you to disclose personal information of your clients, we will co-operate with you to review and abide by the terms of your privacy commitment to your clients. Accountability for our compliance with this privacy policy rests with our Chief Privacy Officer. However, other individuals within Carson Dunlop may have responsibility for the day-to-day collection and processing of personal information.Contact information for our Chief Privacy Officer is set out below:

    John Kwasnik
    Chief Privacy Officer
    Carson, Dunlop & Associates Ltd.
    120 Carlton Street, Suite 407
    Toronto, Ontario, Canada
    Tel: 416-964-9415
    Fax: 416-964-0683

    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.

  1. 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 Google Analytics offers the option to opt out of data collection through access to

    Our websites also use a HubSpot tracking code. This is a web analytics tool provided by HubSpot, Inc. which uses cookies or similar technologies to record your online activities on our Websites and to gather demographic information about our online visitors. HubSpot keeps track of our websites and the webpages that you visit within HubSpot. This data is used to deliver customised content to users whose behaviour indicates that they are interested in a particular subject area. For further information, please refer to

    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.

  1. Obtaining Consent and Opting Out/Withdrawing Consent By using the services of Carson Dunlop, you consent to the collection, use and disclosure of certain of your personal information and that of your clients by Carson Dunlop as detailed in this privacy policy. We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. If you are retaining our services or transacting with us for one of your clients who is an individual, we may require that consent be provided by your client directly or require that you provide us with reasonable evidence that such consent has been provided. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent (or that of your client in terms of his or her personal information) after your personal information has been collected but before our use for that purpose.If you are a user of our Horizon report writing software application (“Horizon”), we expect and require that you have a privacy policy disclosed to your clients that permits the holding of their personal information in Horizon under the terms expressed herein. In choosing to provide us with such personal information, you are by that act affirming that providing such personal information to us for use in accordance with this policy (as it may be updated from time to time) is permitted by such privacy policy as you may have in place and under which you collected such information and other consents you may have obtained from your clients. You agree to indemnify and hold us harmless from any damages, costs, expenses, fines, liabilities and other losses that we may suffer in the event such privacy policy has not been communicated to your clients and/or required consents have not been obtained from your clients.We will not, as a condition of providing the Carson Dunlop service to you, require you to consent to the collection, use or disclosure of personal information beyond that which is reasonably necessary. You always have the choice of whether or not you wish to supply Carson Dunlop with personal information. Similarly, if you wish to withdraw your consent with respect to a particular use or disclosure of your personal information and that of your clients, you may do so at any time by sending written instructions to our Chief Privacy Officer at the address set out above.  Any such withdrawal of consent may, however, prevent or compromise the receipt of our services or the procurement and use of our products.In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstance include: (i) certain prescribed personal information which is publicly available; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.
  1. 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:
    • Name
    • 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

    Through the use of Cookies our Websites may automatically record some general information about your visit for website traffic analysis such as your IP address and type of browser and version number. This information is used to improve your visit to our Websites. For example, we may use your IP address to assist in the determination of your general location for the purposes of directing you to a version of our Website that is specific to the country or region associated with your IP address.  We may also combine or aggregate any of the personal information we collect through access to a Website and/or use of our Services ( online, offline, or elsewhere) for any of these purposes, including delivering targeted advertisements that are based on your previous online activity on a Website.

    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.

    Our Websites contains links to other sites and may track the path of these links as followed by the end user. Once you leave one of our Websites, you are subject to the privacy policies of the other sites you visit which may be different than this privacy policy.  You should therefore carefully review such privacy policies prior to providing such third parties with your personal information or otherwise allowing them to collect your personal information.

  1. 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.
  1. Accuracy We will use our best efforts to ensure that personal information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this privacy policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. In order to assist us in that regard, we urge you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold.
  2. 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.
  1. Openness We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.The information we will make available will include: (i) how to gain access to your personal information and that of your clients or affiliated groups, including real estate agents; (ii) the type of personal information held by us, including a general account of its use; (iii) general information concerning our privacy policy; (iv) what personal information is made available to third parties; and (v) how to contact our Chief Privacy Officer. Copies of the current version of our privacy policy are available by contacting our Chief Privacy Officer. Our privacy policy can also be viewed at each of our Websites at,, and
  1. 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.
  1. Challenging Compliance If you are not completely satisfied with our privacy policy and wish to submit comments or concerns regarding our privacy practices, we invite you to contact our Chief Privacy Officer. We will thoroughly investigate all written complaints addressed to our Chief Privacy Officer. If we find a written complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.


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