Royal LePage Real Estate Services Ltd. Privacy Policy
Royal LePage Real Estate Services Ltd., Brokerage, we respect the privacy of our clients and we are
committed to keeping your personal information accurate, confidential, secure and private. We have
adopted the following Privacy Policy to ensure that Royal LePage Real Estate Services Ltd. continues to
meet its commitment to your privacy.

The following sections, read as a whole, comprise the Royal LePage Real Estate Services Ltd. Privacy
Policy:
1. Introduction
2. The Ten Principles of Privacy
3. Application of the Ten Principles – How We Treat Your Personal Information
i) The Kind of Information We Collect
ii) How We Use Your Information
iii) When We are Permitted to Disclose Your Information
iv) With Whom We May Share Your Information
v) How We Safeguard Your Information
vi) Web Site Security
vii) Accessing and Amending Your Information
viii) Opting Out
ix) Web Site Usage Information and Cookies
4. Updates
5. Questions, Concerns and Complaints

1. Introduction
Royal LePage Real Estate Services Ltd. provides a variety of products and services to the public,
including but not limited to: real estate brokerage services, real estate agency services, advising with
respect to real estate purchase and sale, property leasing, property management, and other real estate
advisory services.
In the course of providing these products and services, Royal LePage Real Estate Services Ltd. may
collect, with consent, certain personal information about its clients, employees and Royal LePage Real
Estate Services Ltd. brokers and agents.
“Personal Information” means information about an identifiable individual. This may include, without
limitation, the individual‘s name, home address, age, income, credit history or other financial information,
credit card information, personal preferences and other information about his, her or their family.
Business contact information is also personal information, but consent is not required to collect, use or
disclose this information for the purpose of communicating or facilitation communication with an individual
in their business capacity.


The Royal LePage Real Estate Services Ltd. Privacy Policy is based on Canada’s Personal Information
Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined
in the National Standard of Canada entitled Model Code for the Protection of Personal Information. For
more information about this legislation, please visit the official web site of the Office of the Privacy
Commissioner of Canada at http://www.priv.gc.ca.

This web site is governed by Canadian law. If you are located in a jurisdiction outside of Canada and
have questions on the application of the laws of your country to our collection, use or disclosure of your
personal information, then please contact your local privacy commissioner or data supervisory authority.
This Privacy Policy describes the ten principles that Royal LePage Real Estate Services Ltd. follows to
protect your Personal Information when we collect, use or disclose it in the course of carrying on
commercial activities in Canada. All of our employees and contractors who have access to Personal
Information must adhere to the Royal LePage Real Estate Services Ltd. Privacy Policy and related
procedures. To this end, Royal LePage Real Estate Services Ltd. has appointed a Chief Privacy Officer to
ensure compliance by all Royal LePage Real Estate Services Ltd. employees and to address your privacy
concerns.

2. The Ten Principles of Privacy

The following ten principles govern our actions as they relate to the collection, use and disclosure of
Personal Information:

Principle 1 - Accountability
Royal LePage Real Estate Services Ltd. is accountable for all Personal Information in its
possession or control, including Personal Information transferred to third parties for processing.

Principle 2 - Identifying Purposes
Royal LePage Real Estate Services Ltd. will inform you of the purposes for which it is collecting
any Personal Information, before or at the time the information is collected.

Principle 3 - Consent
As required under Canadian law, Royal LePage Real Estate Services Ltd. will obtain your
consent before or when it collects, uses or discloses your Personal Information.
Consent can be express or implied. In certain cases consent may be given through an
authorized representative. You may withdraw your consent at any time on reasonable prior notice
(subject to any legal or contractual restrictions of which you will be informed). In certain
exceptional circumstances Royal LePage Real Estate Services Ltd. may collect, use or disclose
Personal Information without your knowledge or consent where such collection, use or disclosure
is permitted or required by law.

Principle 4 - Limiting Collection
The information collected by Royal LePage Real Estate Services Ltd. will be limited to those
details necessary for the purposes we have identified to you or to perform the services you have
requested. Information will be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention
Personal Information will only be used or disclosed for the purpose for which it was collected
unless you have consented to use or disclosure for other purposes. Personal Information will be
handled in accordance with our document retention policies and will generally only be retained for
the amount of time needed to fulfil the purpose for which it was collected, unless a longer period
is required or permitted under applicable law.
In certain exceptional circumstances, Royal LePage Real Estate Services Ltd. may have a legal
duty or right to collect, use or disclose Personal Information without your knowledge or consent
with respect to matters that concern the company’s or the public’s interest.

Principle 6 - Accuracy
Royal LePage Real Estate Services Ltd. will keep Personal Information as accurate, complete
and current as necessary to fulfil the identified purposes for which it was collected. You may have
this information amended or supplemented where it is found to be inaccurate or incomplete.

Principle 7 - Safeguarding Personal Information
Personal Information is safeguarded using measures appropriate to the sensitivity of the
information.

Principle 8 - Openness
Royal LePage Real Estate Services Ltd. will make information available to its clients, employees
and Royal LePage Real Estate Services Ltd. brokers and agents about the policies and
procedures Royal LePage Real Estate Services Ltd. uses to manage personal information. You
have access to this information through our Web site, or through alternate means if requested.

Principle 9 - Access
Upon written request, you will be informed of the existence, use and disclosure of your Personal
Information, and will be given access to it, except where prohibited by law. Royal LePage Real
Estate Services Ltd. will respond to such requests as efficiently as possible. If Royal LePage
Real Estate Services Ltd. is prohibited from providing such access we will explain the reasons for
the lack of access, except where prohibited by law.

Principle 10 – Challenging Compliance
Individuals have the right to express their concerns with an organization’s compliance with these
privacy principles. Royal LePage Real Estate Services Ltd. has policies and procedures to
receive, investigate and respond to complaints and questions regarding this Privacy Policy and
our collection, use and disclosure of Personal Information. You may contact Royal LePage Real
Estate Services Ltd. Chief Privacy Officer to express any concerns with Royal LePage Real
Estate Services Ltd.’s adherence with this Privacy Policy or to request access to your Personal
Information. The contact information for our Chief Privacy Officer is provided at the end of this
document.

3. Application of the Ten Privacy Principles - How we treat your personal information
The Kind of Information We Collect
Royal LePage Real Estate Services Ltd. gathers and uses Personal Information in order to
provide you with the products and services you have requested and to comply with applicable
legislative requirements. The following is a representative list of the types of information that we
collect:
• Information required in accordance with FINTRAC rules to verify your identity or when
necessary to qualify you as a seller, buyer, mortgagor, lessor or tenant:
o name, address and contact information;
o date of verification;
o occupation/principal business;
o date of birth;
o document used to verify identity, including source information, ID number, issuing
jurisdiction, and expiry date;
o credit file information including credit bureau name, date we consulted the
applicable credit bureau and your credit file reference number;
o financial account number information and the documentation from two reliable
sources to verify your identity;

• when collecting an e-signature, we save the geographic location of the signee;
• identity verification information as above to verify the directors and officers of
corporations;
• your Social Insurance Number if we are obligated to collect it pursuant to the Income Tax
Act, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act or other
applicable legislation;
• information about real property that you own as required to effectively market, sell or rent
properties on your behalf;
• information such as resume and prior employment and reference information to evaluate
real estate agent applicants and potential employees; and
• information required to otherwise provide professional and competent real estate services
to clients and to ensure that you are satisfied with the products and services we have
provided.

We do not collect personal information about you when you visit this web site (except for IP
address, described below under “Web Site Usage Information and Cookies”) unless you provide
it. All information that you do provide us with is securely maintained and kept strictly confidential.
This Privacy Policy does not apply to aggregated data from which it is not possible to determine
the identity of a specific individual. Royal LePage Real Estate Services Ltd. reserves the right to
use anonymous, aggregated data in any way that it determines appropriate.

How We Use Your Information
At Royal LePage Real Estate Services Ltd. we use Personal Information for the following
purposes:
• to verify your identity;
• to market your real property for sale or lease;
• to assist you in finding real property for sale or lease;
• to communicate with you in order to provide you with our products and services, which
includes providing you with updates about our services and offering you additional
products or services that you may be interested in;
• for inclusion in documentation relating to your particular real estate transaction;
• to monitor our level of service and report back to you to ensure your satisfaction with the
provision of our services; and
• to consider your application for employment or engagement as a Royal LePage Real
Estate Services Ltd. agent.
We will only use Personal Information for the purpose that we have disclosed to you and for
which you have provided your express or implied consent, unless use for another purpose without
your consent is permitted or required under applicable law. If we want to use your information for
a different purpose, we will notify you and ask for your consent first.

When We are Permitted to Disclose Your Information
Royal LePage Real Estate Services Ltd. is obliged to keep your Personal Information confidential
except under the following circumstances:

• When Authorized by You
Many of the services offered by Royal LePage Real Estate Services Ltd. require us to
obtain Personal Information about you in order to perform the services you have engaged
us to provide. For example, in the course of the real estate listing process, we will share
your property and ownership information with our local real estate board and the
Canadian Real Estate Association for the purposes of listing the property on the MLS
system and we will share your property information with those persons and companies
involved in the real estate transaction such as other real estate brokerages and agents,
property appraisers, home inspectors, financial institutions, and lawyers.
We will always obtain consent from you first, and we will never use the information for
purposes other than those we have told you about unless use for another purpose
without your consent is permitted or required under applicable law.
You may withdraw your consent at any time on reasonable prior notice, subject to any
legal implications (which we will inform you about). In some cases, if you do not consent
to our use or disclosure of certain Personal Information, we may be unable to continue to
provide all or part of the services you have requested.

• When Required by Law
The type of information we are legally required to disclose usually relates to government
tax and financial transaction reporting requirements. However in some cases, such as
under a court order, we may be required to disclose certain information to persons
specified in the court order. We will only provide the specific information requested and
only upon being satisfied that the authorities have legitimate grounds to request the
information.

• When Permitted by Law
Canada’s privacy legislation has provided for certain situations where Royal LePage
Real Estate Services Ltd. is legally permitted to disclose Personal Information without
your consent. Examples include situations involving the collection of debt in arrears,
medical emergencies, or suspicion of illegal activities.

With Whom We May Share Your Information

• Real Estate Brokers, Agents and Employees
In the course of daily operations, we may disclose Personal Information to real estate
brokers and agents, both at our brokerage and other firms. Our employees will also have
access to Personal Information. Access to Personal Information is limited to those brokers, 
agents and employees with a legitimate reason to use it. As a condition of their
engagement, all Royal LePage Real Estate Services Ltd. brokers, agents and
employees are required to follow all applicable laws and regulations, including this
Privacy Policy. Unauthorized use or disclosure of confidential client information by any
Royal LePage Real Estate Services Ltd. broker, agent or employee is prohibited and may
result in disciplinary measures.

• Real Estate Boards
As described above, in order to list a property on the MLS system we will disclose to our
local real estate board and the Canadian Real Estate Association the property and
ownership information for the listed property. This information is made available through
the MLS system to other Realtors, both in Canada and internationally.

• Royal LePage Real Estate Services Ltd. Third Party Suppliers and Service Providers
As you may know, we may engage and coordinate third party suppliers to provide you
with certain services offered through Royal LePage Real Estate Services Ltd. Such
suppliers are only given the information that is needed for them to provide the specific
services that we have contracted them to provide and they are restricted from using this
information for any other purpose. Suppliers and service providers are obliged to protect
the confidentiality of your Personal Information and they are required to treat your
Personal Information in accordance with this Privacy Policy.
In some cases our service providers may be located outside of Canada in countries
where the law provides for a different level of protection for Personal Information than
that which is available under Canadian law. If you would like to obtain more information
about our policies and procedures regarding the use of service providers located outside
of Canada, please contact our Chief Privacy Officer at the address listed in Section 5
below.

• Sale of Business
We may disclose your personal information to a third party and their professional
advisors in connection with a sale, merger or other disposition (whether of assets, stock
or otherwise) of our business. In this event we will require that the information be
maintained as confidential and only used for the purposes of evaluating and completing
the transaction.

How We Safeguard Information
Royal LePage Real Estate Services Ltd. has organizational, technical and physical controls in
place that are designed to maintain the security of its information and information systems. Files
containing Personal Information are stored according to the sensitivity of the information
contained therein. Appropriate controls (such as restricted access) are placed on our computer
systems and data processing procedures. Physical access to areas where Personal Information
is gathered, processed or stored is limited to authorized employees and contractors.
When you telephone a Royal LePage Real Estate Services Ltd. agent or employee to speak
about your file, you may be asked for some Personal Information to identify you. This type of
safeguard is designed to ensure that only you, or someone authorized by you, has access to your
file.
As a further means of safeguarding your Personal Information, we follow commercially
reasonable document retention practices and securely destroy your Personal Information once
the purposes for which we collected it have been fulfilled, unless a longer period is permitted or
required by law.

Third Party Web Sites
In order to serve you better, Royal LePage Real Estate Services Ltd. offers clients access to
certain information about third party products and services through links on this web site to other
third party web sites, including social media web sites. Royal LePage Real Estate Services Ltd.
is in no way responsible and cannot guarantee the content or privacy of other web sites linked to
www.rlpgta.ca.

Accessing and Amending Your Information
You have the right to access the Personal Information we keep about you and have the right to
verify or amend the information if it is shown to be inaccurate or incomplete. If you would like to
view the Personal Information held in your file, please make a written request to the Chief Privacy
Officer at the address listed below, under “Questions, Concerns and Complaints”. We will
respond to your request as efficiently as possible. Please note that we will request Personal
Information from you to verify your identity before providing you with access. Please also note
that your right of access is not absolute; there are circumstances under which we may refuse
access as provided under applicable law.

Opting Out
Should you wish to withdraw you consent to our collection, use or disclosure of your Personal
Information, please contact the Chief Privacy Officer at the address, phone number or email
address provided at the end of this document. While we can accommodate your request in
respect of the promotional materials you receive from us, if you wish to withdraw your consent for
the other business purposes for which we collect, use and disclose your Personal Information, we
may not be able to provide our services to you that are based on the use and disclosure of this
information.

Web Site Usage Information and Cookies
Royal LePage Real Estate Services Ltd. may collect information about your usage of this web
site. For example, our web servers may record certain information automatically when you visit
the web site. Some of this information collected cannot be traced back to a specific person, while
other information is anonymous. This web site information is collected using “cookies” (discussed
below) and might include the pages you visited, your IP (Internet Protocol) address and other site
usage statistics. This information is used for research and analytical purposes only (like
evaluating how many visitors our web sites receive or which pages they visit most often). This
aggregate data may be disclosed to third parties, but never with personally identifying
information.
Cookies are small text files that contain a unique identification number that allows our computers
to identify your web browser (but not you) each time you visit our web sites. The information helps
Royal LePage Real Estate Services Ltd. improve the functionality of the site and enhance the
navigation and security of your session. Most major web sites use this technology and most
browsers are set up to accept them.
You may configure your browser to notify you when you receive a cookie, and you may refuse to
accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that
we can provide to you when you visit our site.

4. Updates

We may update this Privacy Policy from time to time, so please check back often to review the
latest version. Following each update we will assume that you have familiarized yourself with the
current version of our Privacy Policy and we will assume that we may collect, use and disclose
your Personal Information in accordance with the updated Privacy Policy unless you advise us
otherwise in writing.
This Privacy Policy was last updated on May 22, 2020.

5. Questions, Concerns and Complaints
If you have any questions, concerns or complaints about your Personal Information, or about the
Royal LePage Real Estate Services Ltd. Privacy Policy, please contact our Chief Privacy Officer
using the contact information provide below:

Chief Privacy Officer
Royal LePage Real Estate Services Ltd., Brokerage
39 Wynford Drive, Suite 200
Toronto, Ontario M3C 3K5
T 416.306.4336
privacyofficer@royallepage.ca