Of
Personal Information
Pawlowski Realty
Inc. is
committed to respecting your privacy and has
prepared this Policy to inform you of our policy and practices concerning the
collection, use and disclosure of Personal Information.
This Policy governs Personal Information collected from and about (i) individuals who are or may become Clients of Pawlowski Realty Inc. and (ii) individuals or organizations with whom Pawlowski Realty Inc. works with.
Using contractual or other
arrangements, Pawlowski Realty Inc. shall ensure that agents, contractors
or third party service providers, who may receive Personal Information in the
course of providing services to Pawlowski Realty Inc. as part of our
delivery of real estate services, protect that Personal Information in a manner
consistent with the principles articulated in this Policy.
This Policy does not cover aggregated data from which
the identity of an individual cannot be determined. Pawlowski Realty Inc. retains the right to use
aggregated data in any way that it determines appropriate.
In the event of questions about: (i) access to your Personal Information; (ii) Pawlowski Realty’s collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact:
Lynn Pawlowski, Broker
178 St. Bees Close, London, Ontario N6G 4B9
Phone: 519-679-5431 Fax: 519-439-2714
email: pawlowski@odyssey.on.ca
For the purposes of this Policy:
“Client” means an individual who may or has purchased Pawlowski Realty Inc. real
estate or services to buy or purchase real estate;
"Personal
Information" means any information, recorded in any form, about an
identified individual, or an individual whose identity may be inferred or
determined from such information.
Your provision of Personal
Information to Pawlowski
Realty Inc.
means that you agree and consent that we may collect, use
and disclose your Personal Information in accordance with this Privacy Policy.
If you do not agree with these terms, you are requested not to provide
any Personal Information to Pawlowski Realty Inc. or a Broker or Sales Representative
working with Pawlowski Realty Inc.
Unfortunately, certain services can only be offered if
you provide Personal Information and consequently, if you choose not provide us
with any required Personal Information, Pawlowski
Realty Inc. may not be able to
offer you those services.
This
office only collects personal information necessary to effectively market and
sell the property of sellers; to locate, assess and qualify properties for
buyers and to otherwise provide professional and competent real estate services
to clients.
Pawlowski Realty Inc., Brokers or sales representatives may use personal
information for commission management purposes (e.g. commission financing,
commission dispute resolution).
Pawlowski Realty
Inc.’s use of Personal
Information is limited to these purposes. Pawlowski Realty Inc. does not sell, trade, barter or exchange for consideration any Personal
Information it has obtained. Unless
permitted by law, no personal information is
collected about an individual without first obtaining the consent of the
individual to the collection, use and dissemination of that information.
Personal information will be
collected, to the extent possible, directly from the individual concerned.
Pawlowski Realty Inc.
does not knowingly collect Personal Information from anyone under the age of 18,
especially children under 13, and does not use such information if Pawlowski Realty Inc.
discovers that it is has been provided by a minor.
Personal Information may also be transferred to another
company in the event of a change of ownership of all or part of Pawlowski Realty Inc.
Pawlowski Realty
Inc. may disclose Personal
Information of Clients to organizations that perform services on its behalf.
This will only be done if such organizations agree to use such
information solely for the purposes of providing services to Pawlowski
Realty Inc. and, with respect to that
information, to act in a manner consistent with this Policy.
Please note that there are
circumstances where the use and/or disclosure of Personal Information may be
justified or permitted or where Pawlowski Realty Inc. is obliged
to disclose information without consent. Such circumstances may include:
Where required by law or by order or requirement of a court,
administrative agency or other governmental tribunal;
Where Pawlowski Realty Inc. believes, upon reasonable grounds, that it is necessary to protect the
rights, privacy, safety or property of an identifiable person or group;
Where it is necessary to establish or collect monies owning to Pawlowski Realty
Inc.;
Where it is necessary to permit Pawlowski Realty Inc. to pursue available remedies or limit any damages that
Pawlowski Realty
Inc. may sustain; or
Where the information is public.
Where obliged or permitted to
disclose information without consent, Pawlowski Realty Inc. will not disclose more information than is required.
Pawlowski Realty Inc.
endeavours to ensure that any Personal Information provided by Clients and in
its possession is as accurate, current and complete as necessary for the
purposes for which Pawlowski Realty Inc.
uses that data. Information
contained in files that have been closed is not actively updated or maintained.
Pawlowski Realty
Inc. retains Personal Information
as long as Pawlowski Realty
Inc. believes it is necessary to
fulfil the purpose for which it was collected and Firm legal or business
requirements.
Pawlowski Realty
Inc. endeavours to maintain
adequate physical, procedural and technical security with respect to its offices
and information storage facilities so as to prevent any loss, misuse,
unauthorized access, disclosure, or modification of Personal Information.
Pawlowski Realty
Inc. further protects Personal
Information by restricting access to it to those Employees and Contractors that
the management of Pawlowski
Realty Inc. has determined need to know
that information in order that Pawlowski Realty Inc. may
provide services to Clients.
Pawlowski Realty
Inc. permits access to and review
of Personal Information held by Pawlowski Realty Inc. about an
individual by the individual concerned.
If an individual believes any
Personal Information concerning that individual is not correct, that person may
request an amendment of that information by sending a request to the person
indicated in Section 1 of this Policy.
Pawlowski Realty Inc. reserves
the right not to change any Personal Information but will append any alternative
text the individual concerned believes appropriate.
Where not required to be retained by the Firm, an individual may also
request that Pawlowski Realty Inc. delete an individual’s Personal Information from Pawlowski Realty Inc.’s system and records. However, due to constraints of computer technology and the
fact that Pawlowski Realty
Inc. backs up its systems,
Personal Information may continue to reside in Pawlowski Realty Inc.’s systems after deletion. Individuals,
therefore, should not expect that their Personal Information would be completely
removed from Pawlowski Realty Inc.’s systems in response to an accepted request for deletion.
Pawlowski Realty
Inc. reserves the right to decline
access to Personal Information where the information requested:
a)
Would disclose the Personal Information of another individual
or of a deceased individual;
b)
Would disclose business confidential information that may
harm Pawlowski Realty
Inc. or the competitive position of a third party;
c)
Is subject to solicitor-client or litigation privilege;
d)
Could reasonably result in: (i) serious harm to the treatment
or recovery of the individual concerned; (ii) serious emotional harm to the
individual or another individual; or (iii) serious bodily harm to another
individual;
e)
May harm, or interfere with, law enforcement activities and
other investigative or regulatory functions of a body authorized by statute to
perform such functions;
f)
Is not readily retrievable and the burden or cost of
providing would be disproportionate to the nature or value of the information;
or
g)
Does not exist, is not held, or cannot be found by Pawlowski Realty Inc.
Where information will not or cannot be disclosed, the
individual making the request will be provided with the reasons for
non-disclosure.
Where information will be disclosed, Pawlowski Realty Inc.
will endeavor to provide the information in question within a reasonable time
and no later than 30 days following the request.
Pawlowski Realty
Inc. will not respond to repetitious or vexatious requests for
access. In determining whether a request is repetitious or vexatious, it will
consider such factors as the frequency with which information is amended, the
purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, Pawlowski Realty Inc.
will require sufficient information to allow it to confirm the identity of the
person making the request before granting access or making corrections.
This statement is in effect as
of January 1, 2004. Pawlowski Realty Inc. will from time to time review and revise its privacy
practices and this Policy. In the
event of any amendment, an appropriate notice will be communicated to Clients and others in an appropriate
manner.