Privacy Policy

 

Version 3.0 - Updated May 23, 2018

           

Thanks for using HIA® Services or visiting one of our websites. This policy explains the what, how and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell any personal information. At HIA®, keeping your personal information in confidence is a foundation of our business and a critical part of our dedication to customer service excellence. If you have any questions at all concerning this privacy policy please contact us at support@hiacanada.com.


The Basics

1. Definitions

When we say “we,” “us,” “our,” and “HIA,®” we are referring to Home Investment Advisors Ltd. We provide online platforms that you may use to build your business as a real estate agent, including the ability to create accounts for your homeowner Clients or you may use our platform to manage your digital real estate life (the “Services”). When we say “Member,” we are referring to the person (Agent or Client) that is registered to us to use the Services. When we say “you,” we are referring either to a Member or to some other person who visits any of our Websites. A “Client” is someone who a Member that has created an account on our Services. “Personal Information” means information that can be used to identify you or a Client, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. This information can be in any form including paper, electronic, video or voice recording. When we say “Program Partners,” we means companies that we have carefully selected to provide benefits, products or services under, or to participate in, a HIA® Partner Program. These partners are subject to change at the sole discretion of HIA®.

We offer the Services on at our websites: www.hia.ca, www.realoffice360.com and www.homehub360.com. This Privacy Policy applies to these specific websites, as well as any other sites or mobile applications owned or operated by us.

The “Websites” include the Websites themselves, and any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs” or other online, mobile, or wireless offerings that post a link to this Privacy Policy, whether access via computer, mobile device, or other technology, manner or means. While providing the Services, and as described in more detail below, we may collect Personal Information about a Website visitor, Member, person or Client.

2. Changes

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to be bound by this Privacy Policy. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in effect on each respective date you visited the Website.

3. Scope

This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you, according to our Agent Terms of Use and Client Terms of Use.

4. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:

 

Home Investment Advisors Ltd.
Attn. Privacy Officer
support@hiacanada.com
#140, 3553 31 Street NW

Calgary, AB, Canada

T2L 2K7


Your Information

5. What We Collect

(a) Information you voluntarily provide to us: When you sign up for and use the Services, consult with our customer service team, send us an email, post on our blog, integrate the Services with another website or service, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include either your or your Clients name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, occupation, location, purchase history, real estate information, financial information, insurance information, tax information and other demographic information. By giving us this information, you consent to this information being collected, used, disclosed, transferred to Canada and stored by us, as described in our Agent Terms of Use and Client Terms of Use and in this Privacy Policy.

(b) Information we collect automatically: When you use the Services or browse one of our Websites, we may collect information about your visit to our Websites, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Websites or other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

(c) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.

(d) Cookies and tracking: We and our partners may use cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the website, track users’ movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. We may partner with third parties to display advertising on our website or to manage and serve our advertising on other sites. Our third party partners may use cookies or similar tracking technologies in order to provide you advertising or other content based upon your browsing activities and interests.

(e) Web beacons: We use web beacons on our Websites and in our emails. When we send emails to Members, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Members. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Subscribers took. Reports are also available to us when we send email to you, so we may collect and review that information.

(f) Information from other sources: We may receive more information about you or your Clients, such as name, email address, demographic information, IP addresses, location, and use of social media websites, by searching the Internet or querying third parties (we refer to that information as “Supplemental Information”).

(g) Legal Basis for Processing: We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services and our Website; and for our marketing activities.

(h) Other Data Protection Rights: 

You may have the following data protection rights:

·      To access, correct, update or request deletion of your Personal Information. Home Investment Advisors Ltd. takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at personaldatarequests@hiacanada.com. We will consider your request in accordance with applicable laws.

·      In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at personaldatarequests@hiacanada.com.

·      You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Home Investment Advisors Ltd. as a processor on behalf of our individual Members, you should contact the relevant Member that is using the Home Investment Advisors Ltd. Services, and refer to their separate privacy policies.

If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

 

 

6. How We Use and Share Information       

We may use and share personal information only for the following purposes, to:

(a) To promote use of our services to you and others. For example, if you leave your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to advertise our Services to potential or other users like you.

(b) To send you informational and promotional content that you may choose (or “opt in”) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.

(c) To bill and collect money owed to us by our Members. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.

(d) To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

(e) To communicate with our Members about their account and provide customer support.

(f) To enforce compliance with our Agent Terms of Use, Client Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.

(g) To protect the rights and safety of our Members and third parties, as well as our own.

(h) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

(i) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

(j) To prosecute and defend a court, arbitration, or similar legal proceeding.

(k) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

(l) To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Clients. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Clients with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.

(m) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

       

7. Data Collected for and by our Members & Clients

As you use our Services, you may import into our system Personal Information you have collected from your Clients or other individuals. We have no direct relationship with your Clients or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Clients to companies that help us promote, provide, or support our Services or the services of our Members (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about your Clients. We may share this information, including Client email addresses, with third parties in line with the approved uses in Section 6.

Other Data Protection Rights: 

You may have the following data protection rights:

·      To access, correct, update or request deletion of your Personal Information. Home Investment Advisors Ltd. takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at personaldatarequests@hiacanada.com. We will consider your request in accordance with applicable laws.

·      In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at personaldatarequests@hiacanada.com.

·      You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Home Investment Advisors Ltd. as a processor on behalf of our individual Members, you should contact the relevant Member that is using the Home Investment Advisors Ltd. Services, and refer to their separate privacy policies.

If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

 

8. Public Information and Third Party Websites

(a) Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.

(b) Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

(c) Links to third-party websites. Our Websites include links to other websites, whose privacy practices may be different from HIA®’s. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

 

9. Third Parties

You consent to permitting us to disclose Personal Information to the following types of third parties for the purposes described in this policy:

(a) Program Partners.  We may share information with our program partners. If you participate in a HIA® partner program, we also share information in order to administer, develop, manage and promote the HIA® partner program including accrual of points or rewards, reporting on and analyzing the programs performance, developing new benefits, products or services, and conducting market research. If you withdraw your consent to this sharing we may not be able to provide you with the product or service.

(b) Service providers. Sometimes, we need to use third party Service Providers in order to provide and support the features of our Services. For example, if it is necessary to provide you something you have requested (like send you a T-shirt or enable a feature such as Social Profiles), then we may share your Personal Information with a Service Provider for that purpose. We will tell you we are working with a Service Provider whenever reasonably possible, and you may request at any time the names of our Service Providers. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information in a manner that is consistent with this policy.

(c) Advertising partners. We may partner (non-personally identifiable information) with third parties to display advertising on our Websites or to manage and serve our advertising on other sites and may share non-personally identifiable information with them for this purpose. All third parties with which we share this information are required to use your non-personally identifiable information in a manner that is consistent with this policy. We and our third party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests.

 

10. Contests and Rewards

We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.

 

11. Content of Electronic Messages

When you send an email from RealOffice360™, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use RealOffice360™ to send confidential information.


YOUR BUSINESS

12. Your Business Database on RealOffice360™

A Business Database can be built in a number of ways using RealOffice360™, including by import of clients, such as through csv or added directly by Member input. Your Business details are stored on a secure Amazon Web Services Server in Canada. We do not, under any circumstances, sell your Business details, including your Client Lists. If someone on your Client List complains or contacts us, we might then contact that person. Only authorized employees have access to view Client Lists. You may export your Client Lists from RealOffice360™ at any time by contacting support@hiacanada.com

We will use and disclose the information in your Client Lists only for the reasons discussed in Sections 6-9. We will not use and disclose the information in your Contact Lists to:

·      Bill or collect money owed to us;

·      Send you system alert messages;

·      Communication with you about your account; or

·      Send you informational and promotional content


SECURITY

13. Notice of Breach of Security

We are committed to protecting our users’ information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and log out after having used the Services. While we take data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information.  If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your Client List, then HIA® will notify you as soon as possible and later report the action we took in response.

14. Protecting Your Personal Information

At HIA® we take the protection of your personal information very seriously. We make reasonable efforts to prevent unauthorized use, sharing, loss or theft of information, or security breach.        

Where we use service providers who might have access to information, we select them carefully and require them to have privacy and security standards that meet HIA®'s requirements. We use contracts, confidentiality provisions, and other measures with our service providers to maintain the confidentiality and security of your information and to prevent it from being used for any other purpose.            

HIA®, service providers and other parties with whom we share information under this privacy policy, may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.         

We agree to protect your personal information, hold it strictly in confidence and only disclose it in circumstances that are required by law, or as outlined in this Privacy Policy, or otherwise with your express written consent. We also acknowledge and agree that we will use reasonable and appropriate online security measures and safeguards to protect your personal information. By using our website, or any of our services, you are expressly agreeing to these privacy terms.


PRIVACY CHOICE & COMPLIANCE

15. We Operate in Canada

Our servers and offices are located in Canada, so your information may be transferred to, stored, or processed in Canada. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in Canada and those third parties with whom we share it as described in this policy.

16. Choice

Subject to legal, business or contractual requirements, you can withdraw your consent to our collection, use or sharing of information at any time upon giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products or Services. For example, if you choose not to provide us with your email, we will not be able to provide you with any product where your email is required (e.g. Access to RealOffice360™, Access to HomeHub360™).    

17. Keeping Your Information Updated

We take care to keep the information in our records as accurate, complete and up to date as necessary for the purposes for which it is used. However, we also rely on you to tell us when your information changes. Keeping your information accurate and up-to-date allows us to continue to offer you the highest quality service.    

18. Accessing Your Information

You have the right to access personal information we hold about you. Much of your information is available to you through your account, by accessing it online. If you require other information please see the How To Contact Us section below. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Subscriber, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.

19. Legal Basis for Processing Personal Information (EEA Persons Only)

If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. 

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.

If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using at personaldatarequests@hiacanada.com.

20. How to Contact Us

If you want to reach out, please contact us:

·      ONLINE at: hiacanada.com

·      OR BY EMAIL at: support@hiacanada.com

·      OR BY MAIL at: Home Investment Advisors Ltd. C/O The Inc. #140, 3553 31 Street NW Calgary, AB T2L 2K7