PART A – COLLECTION OF PERSONAL INFORMATION
1. Personal Information
- Fivewalls collects the personal information that you provide to us, such as your name and contact information, whenregister for our Services, either as a person or a business, as a _“Consumer”_ (each, a “Consumer”) or as“_Agent_” (each, an “Agent”). This information will be collected either through a website, application, orany other tool or channel associated with our Services. Some of this personal information is necessary in orderyou to gain access to and receive the full benefit of the use of all features of our Services. If you are anand you subscribe to our membership services, we may also collect certain information about your purchases andmethods including, without limitation, credit or debit card information.
We may collect any information that is submitted by you via our Services. This includes, without limitation, anycontained in profiles of Agents (each, a “Profile”), listings and the questions and answers used insuch listings (each, a “Matching Quiz”), messages transmitted through the Services’ two-way messaging system (each, a “Message”) and any feedback posted in relation to use of the Services (“Feedback”).
2. Automatic Information
- We may collect and store anonymous information (“Automatic Information”) about you as you navigate through our Services. This information may be collected using various technologies including, without limitation, cookies, Internet tags and navigational data. Some of this information is automatically transmitted to us through your browser, such as the URL that you just visited, the browser version that your computer uses, the date and time that you used the Services, the webpages that were visited and your IP address. “Cookies” are alphanumeric identifiers that are stored on your computer. These cookies allow us to adjust our Services to meet your personal browsing preferences. If your browser is not set to allow cookies, you may not have access to all areas or features of the Website.
PART B – USE OF YOUR INFORMATION
To accomplish any of the purposes listed below, Fivewalls may combine personal information, Automatic Information, and non-personal information collected through your use of our services.
1. Personal Information
- Personal information will be used by Fivewalls to provide you with full access to our Services and to supply you with any information or services requested.
First name and last initial of a Consumer will be shared with the Agent whose Profile the Consumer selects to communicate with through a Message regarding such Agent or a posted Listing. It is at a Consumer’s discretion to disclose any other information that they so choose to Agents they find using our Services. Any information posted by an Agent through a Profile or Listing will be published and otherwise made available through our Services. We therefore advise that Consumers and Agents avoid including any personal contact details in Profiles or Listings other than as they may freely choose to post. Any Feedback posted by a Consumer may be published and otherwise made available through our Services.
Contact information submitted to Fivewalls as an Agent may be published or otherwise made available through our Services. Personal Information will be used by Fivewalls to inform you about Listings as they are posted through our Services, as well as to inform you of any activity relating to such Listings. Any information included in Listings submitted through our Services will be shared with the Agent who posted the corresponding Listing. Information submitted by an Agent through a Listing will be published and otherwise made available through our Services.
Except as set forth above, Personal Information will not be provided to any other user of our Services.
Information submitted by registered Agents may also be used for marketing purposes. If you do not wish for your information to be used this way, please contact us fusing the contact information in Part H.
Payment and banking information submitted upon any subscription will not be published or made public through our Services. Payment information will be used by Fivewalls to charge for fees associated with our Services. In circumstances where a subscriber’s account is past due, or where the primary payment method fails, we may use additional payment methods listed on file to satisfy these accounts.
2. Automatic Information
We also reserve the right to use personal information and Automatic Information as set forth in Section 13 of Part E of our Terms and Conditions of Use.
PART C – DISCLOSURE OF YOUR INFORMATION
1. To Help with Business Operations
- We may disclose your information to our representatives, affiliates, suppliers or other third parties with which we do business (our “Business Partners”) when it is deemed necessary for our business operations. For example, from time to time, we may engage companies or individuals for certain services on our behalf including, without limitation, conducting audits, performing legal services, processing credit card payments, collecting feedback, and providing customer service. Our Business Partners and any other third-party service providers will only have incidental access to personal information to the extent required to perform their services. They are prohibited from the use of your personal information for any purpose other than assisting with our business operations.
2. Safety and Security
- We may disclose your information as necessary to protect the safety or security of users of our Services, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law.
3. Transfer or Sale
4. Legal Requirement
- As otherwise required by law or in response to a subpoena, court order, or other legally valid inquiry or order, Fivewalls may disclose your personal information.
- Fivewalls may provide, disclose or transfer your personal information with your consent.
PART D – PROTECTION OF YOUR INFORMATION
In order to help prevent unauthorized access to, maintain data accuracy and ensure the correct use of your information, Fivewalls has put in place commercially reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect through our Services. That said, we cannot guarantee that information provided to us through our Services will remain private, or that the information you transmit to us over the Internet will not be intercepted.
To help prevent unauthorized access to your personal information you are responsible for keeping the username and password (collectively, “ID”) that you receive upon registration with our Services private and confidential. You are solely responsible for preventing the unauthorized use of your ID.
PART E – ELECTRONIC COMMUNICATIONS
Should you submit an inquiry through our Services, or otherwise communicate with us electronically, you consent to Fivewalls responding to such inquiries electronically. Fivewalls cannot guarantee that information that we send to or receive from you over the Internet will not be intercepted.
PART F – INFORMATION SHARED BETWEEN USERS
Should you choose to share information with any Agent or Consumer that you find using our Services, we hereby state and you hereby confirm that we are not responsible for the handling, privacy, or processing of such information.
PART H - HOW TO CONTACT US
PART I - YOUR RIGHTS REGARDING YOUR PERSONAL DATA
You have a number of rights under data protection law, which have been strengthened under the General Data Protection Regulation (GDPR):
- Access: You have the right to access the personal data we may hold about you and the purposes for which we are using it. We may ask for proff of your identity. On receipt of such request we will endeavour to respond to you as soon as possible, at most within one calendar month.
- Rectification: You have the right to request that we amend any personal data which is incorrect or requires updating.
- Erasure: You have the right to request that we delete any personal information pertaining to you. We will assess any deletion request on a case by case basis and will endeavour to respond to you as soon as possible, at most within one calendar month. If you have authored any content on the DPN and would like this to be deleted, please let us know.
If you would like to exercise any of these rights, please use the following contact details:
Fivewalls Realty Brokerage
500 Hanlon Creek Blvd. Guelph, Ontario, Canada. N1C0 A1
Effective: September 23, 2015