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Canada Privacy Policy

To view the Canada Privacy Policy in French – click here

Canada Privacy Policy

At CapRelo ULC (“CapRelo”}, we respect the privacy of our customers, and we are cornmitted to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that CapRelo continues to meet its cornrnitrnent to your privacy.

The following sections, read as a whole, cornprise the CapRelo Privacy Policy:

  1. lntroduction
  2. The Ten Principles of Privacy
    1. Application of the Ten Principles
    2. The kind of information we collect
    3. How we use your personal information
    4. When we disclose your personal inforrnation
    5. With whom we share your personal inforrnation
    6. How we safeguard your personal inforrnation
    7. Website security
    8. Accessing and arnending your personal information
    9. Opting-out
    10. Cookies
  3. Questions, Concerns and Cornplaints About the CapRelo Privacy Policy

Introduction

CapRelo provides a variety of relocation services to the public, including, but not limited to: property valuation and appraisal review, home sale or harne sale assistance, financial assistance, equity advances and expense coordination, property management, lease cancellation, interim living arrangernents, furniture rnoving and storage coordination, orientation, home finding, harne purchase or rental assistance, guidance regarding mortgages and taxation, harne and neighborhood inforrnation, education and elder care connections.

In the course of providing these products and services, CapRelo may collect, with their consent, certain personal inforrnation about its custorners.

“Personal Information” means information about an identifiable individual customer. This may include without limitation, the individual’s name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.

The CapRelo Privacy Policy is based an, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at http://www.privcom.gc.ca.

This Privacy Policy describes the ten principles that CapRelo follows to ensure that we protect our customers’ personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada. All of our employees who have access to personal information must adhere to the CapRelo Privacy Policy and related procedures. To this end, CapRelo has appointed a Privacy Officer to ensure compliance by all CapRelo employees.

The following ten principles govern our actions as they relate to the use of customer information:

PRINCIPLE 1 – ACCOUNTABILITY
CapRelo is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for processing.

PRINCIPLE 2 – IDENTIFYING PURPOSES
CapRelo will inform its customers of the purposes for which it is collecting any personal information before or at the time the information is collected.

PRINCIPLE 3 – CONSENT
CapRelo will obtain consent from its customers before or when it collects or uses the personal information.

A customer’s consent can be express or implied. A customer can withdraw consent at any time (with certain exceptions). CapRelo, however, may collect, use or disclose personal information without the customer’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

PRINCIPLE 4 – LIMITING COLLECTION
The information collected from the customer will be limited to those details necessary for the purposes it has identified to the customer. 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 the customer has otherwise consented or when it is required or permitted by law.
Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected.

In certain exceptional circumstances, CapRelo may have a legal duty or right to disclose personal information without customer knowledge or consent with respect to matters that concern the company’s or the public’s interest.

PRINCIPLE 6 – ACCURACY
CapRelo will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Customers may have this information amended 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
CapRelo will make information available to its customers about the policies and procedures CapRelo uses to manage personal information. Customers have access to this information through our web site or through alternate means if requested.

PRINCIPLE 9 – CUSTOMER ACCESS
Upon written request, a customer will be informed of the existence, use and disclosure of their personal information and will be given access to it. CapRelo will respond to such requests as efficiently as possible.

PRINCIPLE 10 – ADDRESSING CUSTOMER COMPLAINTS AND SUGGESTIONS Customers may challenge the CapRelo compliance with its Privacy Policy. CapRelo has procedures to receive, investigate and respond to customers’ complaints and questions. Customers may contact the CapRelo Privacy Officer to express any concerns or to request access to their personal information. The contact information for this individual is provided below.

The Kind of Information We Collect

CapRelo gathers and uses personal information in order to provide you with the relocation services you have requested (through your employer) or to offer additional products or services you may be interested in. Providing us with your personal information is your choice, however, we may not be able to provide you with certain products or services if you do not provide us with certain information. For example, we cannot provide you with relocation services if we do not know where you live.

The nature of your relocation requirements will determine the kind of personal information we might ask for.

Information that is typically required to provide you with relocation services:

  • Name
  • Current address
  • Future address (as soon as it’s known) and phone number(s)
  • Mortgage information
  • Information relating to the condition of your property Family information
  • Special requirements relating to your needs at your point of destination Bank account and other financial information
  • lf there are tax implications related to your financial activities, the federal government requires that we ask for your Social lnsurance Number for tax reporting purposes pursuant to the lncome Tax Act

CapRelo may keep a file with your contact history tobe used for customer inquiry purposes so that we may ensure that you are satisfied with the relocation services which we have provided to you.

lf you visit a CapRelo website, we da not collect personally identifiable information about you unless you provide it. All intormation that you da provide us with is securely maintained and kept strictly confidential.

How We Use Your Personal Information

At CapRelo we use personal information for two general purposes:

  1. To communicate with you during the course of your relocation and to provide you with our products and services. Same services may be provided by other service providers (such as movers or consultants) in order to serve your relocation needs.
  2. Transactional information to monitor our level of service and report back to you to ensure your satisfaction with the provision of such services.

We will only use personal information for the purpose that we have disclosed to you. lf we want to use your information for a different purpose, we will notify you and ask for your consent first.

When We Disclose Your Personal Information

CapRelo is obliged to keep your personal information confidential except under the following circumstances:

When authorized by you
Many of the services offered by CapRelo require us to obtain personal information about you in order to perform the services we have been engaged to provide. We will use this information to tailor programs to meet your needs and objectives. 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.

For example, if we are providing you with orientation services in your new community, we will need to know information about your family that will help us tailor an orientation program. This might include information about your children’s educational requirements or information about your health care needs. Or we may reimburse you for mileage or other incidentals that would require you to provide us with your receipts. We will always obtain your consent before we collect, use or disclose this information. You may also withdraw your consent at any time, subject to any legal implications (which we will inform you about). For example, you cannot withdraw your consent with respect to a promissory note you have signed.

When required by law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain information to authorities. 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
The legislation has provided certain situations where CapRelo is legally permitted to disclose personal information without your consent. Examples include, but are not limited to, situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.

With Whom We Share Your Personal Information

CapRelo Employees
In the course of daily operations, access to sensitive personal information is limited to those employees and professional advisors (such as CapRelo lawyers, auditors, etc.) with a legitimate reason for accessing it. As a condition of their employment, all CapRelo employees are required to follow all applicable laws and regulations, including the Privacy Policy we have established.

CapRelo Affiliates
To ensure that all your relocation needs are met, and where we have your permission, we may share some of your personal information with our affiliates. We will only do this with your express consent.

CapRelo Service Providers
As you may know, we often engage and coordinate other service providers to deliver to you the vast array of relocation services offered through CapRelo. For example, we maintain a network of lawyers, movers and consultants who assist families in purchasing, moving and settling in to their new homes.

Such service providers are only given the information that is needed to provide the specific service for which they are engaged to provide. Our network of Service Providers is also bound by strict contractual means to protect the confidentiality of your information, and they are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with the CapRelo Privacy Policy.

How We Safeguard Your Personal Information

CapRelo has extensive controls in place to maintain the security of their information and information systems. Client files are stored according to their sensitivity. Appropriate controls (such as restricted access) are placed over our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

When you telephone or meet with a CapRelo employee to speak about your file, you may be asked for some personal identifying information. This kind of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

Website Security

In order to serve you better, CapRelo may offer customers access to certain information through its secure websites. CapRelo is committed to your privacy and will ensure that any information you access or provide through this site remains secure. To safeguard against unauthorized access to your account, you may be required to “sign-on” using an encrypted password to gain access. If you are unable to provide the correct password, you will not be able to access your account.

Accessing and Amending Your Personal Information

As a customer, you have the right to access the personal information we keep in your file, and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to our Privacy Officer at the address listed below under “Questions, Concerns and Complaints.” We will respond to your request as efficiently as possible.

To make a change, please make a similar request in writing to the Privacy Officer.

Opting-Out

In order to provide you with relocation services and products, CapRelo will, with your consent, share your personal information with other CapRelo affiliates. Should you not want to receive promotional materials from, or have your personal information shared with, these companies, please contact us at privacy@caprelo.com.

Anonymous Information and “Cookies”

CapRelo may collect non-personal information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers record certain information automatically when you visit CapRelo websites. This information is collected using “cookies” – a small text file that contains a unique identification number identifying your web browser (but not you) to our computers every time you visit one of our websites that uses cookies. They may indicate pages you visited, your IP (Internet Protocol) address and other site usage statistics. They help CapRelo to improve the functionality of the site and to enhance the navigation and security of your session. It does not reveal any personal information about you, the user. Aggregate data may be disclosed to third parties but never with personally identifying information.

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.

If you have any questions, concerns or complaints about your personal information or about the CapRelo Privacy Policy, please contact our Privacy Officer at privacy@caprelo.com

Last updated: December 30, 2024