Privacy Policy

Welcome to Fivewalls Inc. ("Fivewalls"). At Fivewalls we are committed to preserving the privacy of all visitors to and users of our sites, services, applications and tools (collectively, the "Services"). Accordingly, this Privacy Policy is designed to help you understand how personal information is collected, used and disclosed when using our Services. Before registering, submitting any content or personal information, or otherwise using our Services, please make sure that you read this entire Privacy Policy as well as our Terms and Conditions of Use.

By accessing or otherwise using our Services, you consent to the terms of this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with the provisions of this Privacy Policy, do not use or access our Services or otherwise provide us with any of your personal information.

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, when

you register for our Services, either as a person or a business, as a _"Consumer"_ (each, a "Consumer") or as

an "_Agent_" (each, an "Agent"). This information will be collected either through a website, application, or

by any other tool or channel associated with our Services. Some of this personal information is necessary in order

for you to gain access to and receive the full benefit of the use of all features of our Services. If you are an

Agent and you subscribe to our membership services, we may also collect certain information about your purchases and

payment methods 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, any

information contained in profiles of Agents (each, a "Profile"), listings and the questions and answers used in

developing such 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 may aggregate, evaluate and use Automatic Information in order to help improve our Services. We may use cookies, IP addresses or other Automatic Information to analyze trends, administer the Services, track customer website navigation and gather broad demographic information. Automatic Information will not be published or made public through our Services.

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

Except as provided in this Privacy Policy, Fivewalls does not sell, trade, or otherwise transfer your personal information to third parties. We may, however, disclose your personal information in the following limited circumstances:

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

In the event that Fivewalls sells, transfers or otherwise disposes of its business to an affiliate, successor, assign or other third party entity, we may disclose personal information. Our business may wish to sell or buy subsidiaries or business units, in which case such a transaction may require that customer information, including personal information, be transferred as a business asset. However in the event that such a transaction occurs, any customer information will remain subject to the terms of any pre-existing Privacy Policy.

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.

5. Consent

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 G – CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy, and any other policies and procedures concerning our practices for managing personal information, at any time without prior notice to you. The latest version of this policy will always be available at fivewalls.com/privacy.

If the revision, in our sole discretion, is material we will notify you through the application or via e-email. Any changes that are made to this Privacy Policy will apply to both personal information that we hold prior to the effective date of the amended Privacy Policy and to any personal information collected on or after the posted effective date. Our successors and assigns may collect and use your personal information for substantially similar purposes as described in this Privacy Policy.

PART H - HOW TO CONTACT US

Any questions, comments or concerns relating to this Privacy Policy, and any requests to correct or access personal information collected during your use of our Services, should be directed to:

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

Email: info@fivewalls.com

2967 Dundas St. W. #468 Toronto, Ontario, Canada. M6P 1Z2

Effective: September 23, 2015