CARSON
DUNLOP, & ASSOCIATES LTD.
PRIVACY POLICY (Updated as of October 27, 2005)
1.
Introduction
This privacy policy explains the privacy practices of Carson, Dunlop & Associates
Ltd. (referred to as "Carson Dunlop", "us", "we" or "our").
This privacy policy applies to the collection, use and disclosure of personal
information in connection with Carson Dunlop operated websites and in connection
with the provision of Carson Dunlop’s products and services. Our privacy
policy may be amended from time to time, so we encourage you to periodically
check our web site at http://www.carsondunlop.com for the current version.
Printed copies of our current privacy policy are also available by contacting
our Chief Privacy Officer.
2.
Our Commitment to Your Privacy
The relationship between you and Carson Dunlop is based on trust. We value
the trust you have placed in us and are taking all appropriate measures to
safeguard your personal information and maintain your confidence. Carson Dunlop
has established this privacy policy to ensure that your personal information
is protected and that all our practices and procedures comply with relevant
personal information protection and privacy legislation. Accordingly, we adhere
to the privacy principles set out below, which are based on the principles
set out in Schedule 1 of the Personal Information Protection and Electronic
Documents Act (Canada). As used in our privacy policy, the term "personal
information" means information about an identifiable individual, but does
not include the name, title or business address or telephone number of an employee
of an organization.
3.
Accountability
Carson Dunlop is responsible for all personal information under our control.
Accountability for our compliance with this privacy policy rests with our Chief
Privacy Officer. However, other individuals within Carson Dunlop may have responsibility
for the day-to-day collection and processing of personal information.
Contact
information for our Chief Privacy Officer is set out below:
John Kwasnik Chief Privacy Officer Carson, Dunlop & Associates Ltd. 120
Carlton Street Suite 407 Toronto, Ontario Canada
Carson
Dunlop is responsible for personal information in our possession
or custody, including information that needs to be disclosed
to third parties in the course of our business. We use contractual
and other means to ensure that third parties to whom we disclose
personal information for processing provide a comparable
level of protection with respect to personal information
in their possession or control.
4.
Identifying Purposes
We will clearly identify and document the purposes for which we may collect,
use or disclose personal information at or before the time of collection. As
part of our business operations, we may collect and use certain personal information
strictly for the following purposes:
To provide
you with Carson Dunlop products and services that you request
To provide
you with Carson Dunlop’s newsletter
To provide
information regarding Carson Dunlop and our products and
services that may be of interest to you (If you wish to
stop receiving such information, simply visit the Carson
Dunlop website at www.carsondunlop.com and
follow the instructions to unsubscribe or provide written
instructions to our Chief Privacy Officer).
In addition,
in the unlikely event that Carson Dunlop sells all or substantially
all of its assets, subscriber information, including your
collected personal information will be one of the transferred
assets.
The specific uses of personal information in connection with the foregoing
purposes will be limited to what a reasonable person would consider appropriate
in the circumstances.
If we
plan to use personal information we have collected for a
purpose not previously identified, we will identify and document
the purpose before such additional use. We will state the
identified purposes in such a manner that you can reasonably
understand how your personal information will be used or
disclosed.
5.
Obtaining Consent and Opting Out/Withdrawing Consent
By using the services of Carson Dunlop, you consent to the collection, use
and disclosure of certain of your personal information by Carson Dunlop as
detailed in this privacy policy.
We will
use reasonable efforts to seek your express consent for the
collection, use or disclosure of your personal information
at the time of collection. In some circumstances, such as
where we want to use personal information for a purpose that
was not previously identified, we may have to seek your consent
after your personal information has been collected but before
our use for that purpose.
We will
not, as a condition of providing the Carson Dunlop service
to you, require you to consent to the collection, use or
disclosure of personal information beyond that which is absolutely
necessary.
You always have the choice of whether or not you wish to supply Carson Dunlop
with personal information. If you wish to "opt-out" of receiving
certain informational and promotional materials from us, simply visit the Carson
Dunlop website at www.carsondunlop.com and follow the instructions to unsubscribe
or provide written instructions to our Chief Privacy Officer at the address
set out above. Similarly, if you wish to withdraw your consent with respect
to a particular use or disclosure of your personal information, you may do
so at any time by sending written instructions to our Chief Privacy Officer
at the address set out above.
In certain
limited circumstances, as permitted or required by law, we
may collect, use or disclose personal information without
the knowledge or consent of the individual. Although the
following list is not exhaustive, these circumstance include:
(i) personal information which is publicly available as defined
by regulation; (ii) circumstances where collection or use
is clearly in the interests of the individual and consent
cannot be obtained in a timely fashion; (iii) to investigate
a breach of an agreement or a contravention of a law; (iv)
to act in respect of an emergency that threatens the life,
health or security of an individual; (v) for debt collection;
or (vi) to comply with a subpoena, warrant or court order.
6.
Limiting Collection
We will limit the amount and type of personal information collected to that
which is necessary for our identified purposes and we will only collect personal
information by fair and lawful means.
We may collect the following types of personal information from individuals
visiting our website or purchasing Carson Dunlop products and services:
Name
Credit
card number (if purchasing a Carson Dunlop product or service)
Residential
address (if purchasing a Carson Dunlop product or service)
Residential
telephone number (if purchasing a Carson Dunlop product
or service)
e-mail
address
Through
the use of Cookies our websites may automatically record
some general information about your visit for website traffic
analysis such as your IP address and type of browser. This
information is used to improve your visit to our website.
Our website
contains links to other sites. Once you leave our website,
you are subject to the privacy policies of the other sites
you visit.
7.
Limiting Use, Disclosure and Retention
Your personal information collected by Carson Dunlop will be used to deliver
services, products or programs you have requested or enrolled in. In addition,
you may receive invitations to participate in relevant surveys, and copies
of Carson Dunlop’s e-newsletter.
Carson
Dunlop’s home inspection clients receive a membership
in the Carson Dunlop Homeowners Association, a not-for-profit
organization that provides member benefits including, by
way of example, preferred pricing on home insurance and home
security. Some of these benefits are provided directly from
Carson Dunlop and other benefits are through third-party
relationships with other companies. You may choose to withdraw
from: I) the Carson Dunlop Homeowners Association or II)
the use and disclosure of your personal information in accordance
with this policy at any time by sending written instructions
to our Chief Privacy Officer at the address set out above.
Carson
Dunlop also uses your personal information to inform you
of other products, services or benefits available from Carson
Dunlop and its affiliates. For example:
Contact
information for Home Inspection clients may be given to
TD Insurance to offer our group home insurance program
Contact
information for Home Inspection clients may be given to
Sears Home Security to provide a home security report and
to offer upgrades or monitoring as appropriate
In addition,
contact information for Real Estate Continuing Education
clients is required for RECO (Real Estate Council of Ontario)
to verify successful completion of Mandatory Continuing Education
(MCE) courses.
Contact
information for Home Inspection Training clients may be given
to Seneca or other Community Colleges as appropriate in order
to record progress through courses, including test and exam
results, case study and field exercise results.
Carson
Dunlop may also contact you via surveys to conduct research
about your opinion of current services, or on other research
initiatives.
Carson
Dunlop will not use or disclose your personal information
for purposes other than those for which it is collected,
except with your express consent or as required by law. Carson
Dunlop will not rent or sell your personal information to
any third party.
Carson
Dunlop will retain your personal information only for as
long as is necessary for the fulfillment of those purposes,
subject to legal requirements. Currently, our policy is to
maintain personal information for as long as the individual
is a subscriber of a Carson Dunlop service and for a period
of one year thereafter. For Carson Dunlop’s home inspection
clients we keep reports for seven years. After the relevant
time period has expired, our records are amended so that
names are removed and the information can no longer be identified
with an individual.
8.
Accuracy
We will use our best efforts to ensure that personal information under our
control that is used on an ongoing basis, including information that we disclose
to third parties in accordance with this privacy policy, is as accurate, complete,
and up-to-date as is necessary for the purposes for which it is to be used.
In order to assist us in that regard, we urge you to provide us with updates
regarding such information and to inform us of any errors affecting your personal
information that we hold.
9.
Safeguards
Carson Dunlop is committed to protecting the security of your personal information
and we will protect your personal information with safeguards appropriate to
the sensitivity of the information. We employ appropriate safeguards to protect
personal information against loss or theft, as well as unauthorized access,
disclosure, copying, use or modification, regardless of the format in which
the information is held. We use security technologies and procedures to help
protect your personal information from unauthorized access, use or disclosure.
For example, we store personal information you provide on computer systems
with limited access in controlled facilities. When confidential information
(such as credit card numbers) is transmitted over the Internet, it is protected
through the use of SSL Encryption.
We make our employees and business partners aware of the importance of maintaining
the confidentiality of personal information, and we will exercise appropriate
care in the disposal or destruction of personal information to prevent unauthorized
parties from gaining access to the information.
Our methods of protection include physical measures (for example, restricted
access to offices), organization measures (for example, limiting access on
a "need to know" basis), and technological measures (for example,
the use of passwords and encryption).
10.
Openness
We will make specific information about our policies readily available, except
to the extent that it is confidential commercial information.
The information
we will make available will include: (i) how to gain access
to your personal information; (ii) the type of personal information
held by us, including a general account of its use; (iii)
general information concerning our privacy policy; (iv) what
personal information is made available to third parties;
and (v) how to contact our Chief Privacy Officer.
Copies
of the current version of our privacy policy are available
by contacting our Chief Privacy Officer. Our privacy policy
can also be viewed at our website at http://www.discoverhorizon.com
11.
Access
Upon written request addressed to our Chief Privacy Officer, we will inform
an individual of the existence, use and disclosure of his or her personal information
and we will give the individual access to that personal information. An individual
can challenge the accuracy and completeness of his or her personal information
under our control and have it amended as appropriate.
We will
respond to an individual’s written request within a
reasonable time (generally within 30 days) and we will assist
any individual who informs us that he or she needs assistance
in preparing a request. We may require an individual to provide
sufficient information to permit us to provide an account
of the existence, use and disclosure of personal information.
While our response will typically be provided at no cost
to the individual, depending on the nature of the request
and the amount of information involved, we reserve the right
to impose a reasonable cost. In these circumstances, we will
inform the individual of the approximate cost to provide
the response and proceed upon payment by the individual of
the cost. Requested information will be provided or made
available in a form that is understandable. Where possible,
we will indicate the source of the information.
If you
feel that your personal information we hold is inaccurate
or incomplete you are invited to advise our Chief Privacy
Officer of such inaccuracies and ask that we amend the personal
information. Any such request must be in writing.
In providing
an account of third parties to which we may have disclosed
personal information about an individual, we will attempt
to be as specific as possible. When it is not possible to
provide a list of the organizations to which we have actually
disclosed personal information, we will provide a list of
organizations to which we may have disclosed the personal
information.
If an
individual successfully demonstrates an inaccuracy or incompleteness
of his or her personal information under our control, we
will amend the personal information as appropriate. If a
challenge is not resolved to the satisfaction of the individual,
we will record the substance of the unresolved challenge.
Where appropriate, the amended information or the existence
of the unresolved challenge, as the case may be, will be
transmitted to third parties having access to the information
in question.
In certain
situations, we may refuse a request or not be able to provide
access to all the personal information we hold about an individual.
Exceptions to the access requirement will be limited and
specific, as permitted or required by law. Where permitted,
the reasons for denying access will be provided to the individual
upon request. Although the following list is not exhaustive,
exceptions may include: (i) information that contains references
to other individuals or contains confidential commercial
information, where such information cannot be severed from
the record; (ii) information collected in the course of investigating
a breach of an agreement or in the course of a formal dispute
resolution process; and (iii) information that is subject
to solicitor-client privilege.
12.
Challenging Compliance
If you are not completely satisfied with our privacy policy and wish to submit
comments or concerns regarding our privacy practices, we invite you to contact
our Chief Privacy Officer. We will thoroughly investigate all written complaints
addressed to our Chief Privacy Officer. If we find a written complaint to be
justified, we will take all appropriate measures, including, if necessary,
amending our policies and practices.
If for
any reason you are not satisfied with the results of our
investigation of and responses to your complaint, you may
file a complaint with the Office of the Federal Privacy Commissioner,
112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.
Glossary
Cookies - Cookies are small text files that Web sites place in your computer
to help your browsers remember specific information. For example, they
might store your passwords and user IDs. They are also used to store your
preferences for content or personalized pages. Most shopping carts use
cookies. These allow you to choose items and leave the virtual store, then
return later and find that all the items are still in your shopping cart.
Some sites use temporary cookies (called session cookies) that are deleted
when you exit your browser. Others place persistent cookies, which stay
on your hard drive for long periods.
IP - An
abbreviation for Internet Protocol, the basic network transmission
protocol of the Internet.
SSL Encryption
- SSL, or Security Socket Layer, encrypts your customers'
credit card numbers, as well as other confidential information.
This allows for secure online business. When your Web page
has SSL, your page will show a small gold lock or key in
the lower right hand side of your browser.
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