This Privacy Policy is provided by Right at Home Realty, Brokerage (referred to as “Right at Home” or “RAHR”) to provide Users (referred to as “You”or “User”) with information on real estate brokerage services in the Province of Ontario, market updates, news and resources.

‍Definitions

‍“Collection” refers to the act of gathering, acquiring, recording, or obtaining personal information.
“Consent” is a voluntary agreement between RAHR and the User for the collection, use, and disclosure of personal information for defined purposes. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative.
“Disclosure” means making personal information available to a third party.“Personal information” is information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual. Personal information also excludes certain information as excluded pursuant to applicable legislation or other regulations, such as publicly available information or business contact information, as and when applicable.
“PIPEDA” is Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5“Third party” refers to an individual or organization outside of Right at Home.
“Use” is the treatment, handling, and management of personal information by and within an organization.

We are committed to providing you with an internet experience that respects and protects your personal privacy choices and concerns. We respect our customers' privacy and are dedicated to maintaining the accuracy, confidentiality, security, and protection of your personal information. To uphold this commitment, Right at Home implemented the following Privacy Policy, which ensures our respect for your privacy and the safeguarding of your personal information. Privacy laws in Canada is governed by PIPEDA set out by the Office of the Privacy Commissioner of Canada PIPEDAgenerally defines "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy describes:

• How we collect, use, disclose and protect the personal information of the consumer and website users:
• when accessing our Website by desktop computer or mobile device.
• in email, text, and other electronic messages between you and our Website.
• when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy or our Website.
• Describes the types of information we may collect from you or that you may provide when you visit  https://www.rightathomerealty.com (our "Website").
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit. In addition, in certain instances, the advertisers on our Website may ask you for personal information, we do not accept any responsibility or liability for the privacy practices of the advertisers. This policy DOES NOT apply to information that:

• We collect offline or through any other means, including on any other Company or third-party website, including our affiliates and subsidiaries.
• You provide or is collected by any third party, including our affiliates and subsidiaries, through any application or content (including advertising) that may link to or be accessible from or on our Website.

For clarity, the Policy does not apply to information about Right at Home's corporate customers or Right at home’s employees; however, such information is protected by other Right at Home policies and practices and through contractual arrangements.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services. The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or openedan email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on our Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content. You can opt-out of third party ad servers' and networks' cookies simultaneously by using contacting them directly. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. We do not control these third parties tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. This policy includes Right at home’s designated affiliates that do business with us, as they may exist from time to time. The policy is subject to change and may be supplemented or amended by additional terms specific to the relationship between Right at Home and the User. Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information. To uphold the highest possible standards, Right at Home will adhere to the ten privacy principles outlined in Schedule 1 of PIPEDA.  Accordingly, the following ten principles will guide our actions regarding the collection, use, and disclosure of personal information as well as providing access to personal information.

Principle 1 - Accountability

Right at Home shall designate one or more individuals to be responsible for ensuring compliance with the Policy, and upon request, will provide the names of those designated individuals. Right at Home is accountable for any personal information in its possession or under its control, and will take appropriate measures to protect this information when it is being processed by third parties on its behalf, as outlined in Principle 7. Additionally, Right at Home will implement policies and procedures to effectively enforce and adhere to the Policy.

Principle 2 - Identifying Purposes for Collection of Personal Information

Right at Home collects personal information for several purposes, including establishing and maintaining a responsible commercial relationship with customers, fulfilling purposes that are identified to individuals or are apparent in the context of specific collections of personal information, and complying with legal and regulatory requirements. Additionally, the information is used to understand individual needs and preferences, develop, enhance, market, or provide products and services, and manage and develop Right at Home's business and operations, including data transfers among affiliated entities. Right at Home will, when appropriate, inform individuals of the identified purposes for collecting personal information, either orally, electronically, or in writing, at or before the time of collection. If requested, those collecting the personal information will provide an explanation of these purposes or direct the individual to a designated representative within Right at Home who can further explain the purposes.

Principle 3 – Consent

Right at Home will obtain meaningful consent from Users before collecting, using, or disclosing personal information. We understand the importance of obtaining either express or implied consent for a clearly defined and legitimate purpose, such as providing a product or service. Express consent may be given verbally, electronically, or in writing, while implied consent can be reasonably inferred from an individual’s actions or inactions. Typically, Right at Home seeks consent at the time personal information is collected; however, in certain cases, consent may be obtained after the information has been collected but before it is used or disclosed for a new purpose. In accordance with Canadian law, Right at Home will make reasonable efforts to inform Users of the specific purposes for which their personal information will be used or disclosed when seeking consent, ensuring the information is communicated in a clear and understandable manner. When determining the appropriate form of consent, Right at Home will take into account the sensitivity of the personal information and the reasonable expectations of the User. Users have the right to withdraw their consent at any time, subject to legal or contractual obligations and with reasonable notice by contacting Right at Home, more specifically the Privacy Compliance Officer, for further details on the implications of withdrawing consent. It is important for Users to be aware that withdrawing their consent may result in them no longer receiving the product or service associated with that consent.

Principle 4 - Limiting Collection of Personal Information

Right at Home will restrict the collection of personal information to what is necessary for the purposes it has identified and as permitted by law. Right at Home primarily collects personal information directly from the User to whom the information pertains. However, it may also obtain personal information from other sources, including third parties who claim to have the authority to disclose the information, or as otherwise permitted by law.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

Right at Home will not use or disclose personal information for purposes other than those for which it was collected, unless the User consents or it is required by law. Personal information will be retained only as long as necessary to fulfill the identified purposes or as required or permitted by law. Right at Home may disclose personal information to employees, agents, or third parties who need access to perform their duties, such as research or data processing, and to affiliate companies for product and service development, enhancement, marketing, or provision. Personal information may also be shared during mergers, sales of assets, or other corporate reorganizations.  Additionally, RAHR will also retain usage data for internal analysis purposes. This data is typically kept for a short period, unless it is used to enhance the security or improve the functionality of our Service. Additionally, we may share your name and email address with agents specifically for the purpose of providing you with real estate services. This disclosure enables agents to contact you directly, offer personalized assistance, respond to your inquiries, and deliver the real estate services you have requested or may be interested in. Your information is shared strictly to enhance your experience and ensure you receive the appropriate support from our agents. Right at Home shall implement reasonable and systematic controls, schedules, and practices for the retention and destruction of records, ensuring that personal information no longer needed for the identified purposes, or as required by law, is securely destroyed, erased, or anonymized.

Principle 6 - Accuracy

Right at Home awill take steps to ensure that personal information is accurate, complete, and up-to-date as appropriate for its intended purposes. The personal information used by Right at Home must be sufficiently accurate and current to minimize the risk of using incorrect information in decision-making about a User. Right at Home will update personal information as needed to fulfill the identified purposes or upon the reasonable request of the User.

Principle 7 - Security Safeguards

To protect the sensitivity of the information collected, Right at Home will implement reasonable measures to guard personal information against risks like loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. When sharing personal information with third parties, Right at Home will also take appropriate steps, such as entering into contractual agreements, to maintain the confidentiality of the information and to clearly define the purposes for which it can be used. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology.

Principle 8 - Openness

Right at Home will make specific information about its policies and practices regarding the management of personal information readily available to Users. This includes providing details on how Users can access their personal information held by Right at Home, as well as a description of the types of personal information Right at Home holds and a general overview of its usage.

Principle 9 - Individual Access

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email to legal@rightathomerealty.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Compliance Officer.

Principle 10 - Handling Inquiries and Challenging Compliance

Users have the right to raise concerns about an Right at Home’s adherence to the privacy principles. Right at Home has established procedures for handling complaints and inquiries related to this Privacy Policy and the management of personal information. Upon request, Right at Home will provide information about the existence, use, and disclosure of personal information at minimal or no cost, and Users can challenge and request amendments to their data. Access may be restricted in cases where revealing information could disclose third-party details, compromise safety, or expose confidential information protected by the privilege. Requests for access should be directed to a designated representative. Right at Home encourages you to contact us with any questions or concerns you might have about your privacy or our Privacy Policy and we will aim to respond within 30 days or as required by law.. Any questions, requests for access to information, or complaints, must be made in writing and addressed to the Privacy Officer:

Privacy Compliance Officer
‍Right at Home Realty, Brokerage
‍895 Don Mills Road, Unit 401
Toronto, Ontario M3C 1W3
Phone: (416) 391-8891
Email: legal@rightathomerealty.com

The Privacy Compliance Officer will promptly investigate and respond to any concerns you have about how your information is handled. A written report detailing the investigation’s findings and any measures taken to update Right at Home’s Privacy Policy and procedures will be provided in all cases.

If you are not satisfied with the findings or actions taken by Right at Home’s Privacy Compliance Officer, you may file a complaint with the Federal Privacy Commissioner at the address provided below:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll Free 1-800-282-1376
TTY:  (819) 994-6591
Email notification@priv.gc.ca
Website: https://www.priv.gc.ca