Privacy Policy

PRIVACY POLICY

[INSERT BROKERAGE / AGENT LEGAL NAME]
Last Updated: [Insert Date]

1. Introduction

This Privacy Policy describes how [Insert Brokerage / Agent Legal Name] (“we”, “us”, “our”) collects, uses, discloses, stores, and safeguards personal information obtained through our website, MLS®/IDX display systems, artificial intelligence tools, digital intake platforms, phone assistants, portals, and related services (collectively, the “Services”).

We are committed to protecting personal information in accordance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA)
• Applicable provincial privacy legislation
• Provincial real estate regulatory requirements
• REALTOR® association and MLS® data use rules (where applicable)
• Anti-Money Laundering and FINTRAC obligations

By using our Services, you consent to the practices described in this Policy.

2. Professional Identification

Legal Name: [Insert Brokerage / Agent Legal Name]
Trade Name (if applicable): [Insert Trade Name]
Province(s) of Registration: [Insert Province(s)]
Regulatory Authority: [Insert Regulator – e.g., RECO, BCFSA, OACIQ, etc.]
Brokerage Address: [Insert Address]
Privacy Contact: [Insert Email]

You are encouraged to verify licensing status through the applicable regulator.

3. Categories of Personal Information Collected

We may collect personal information including:

A. Identification Information

• Name
• Address
• Phone number
• Email address
• Government-issued identification (where required)

B. Transaction & Representation Information

• Property preferences
• Listing inquiries
• Showing requests
• Offer documentation
• Financing details
• Deposit information
• Transaction documents
• Communications regarding purchase or sale

C. Seller & Listing Information

• Property details
• Marketing materials
• Photos
• Listing agreements
• Comparative market analysis data

D. Regulatory & Compliance Information

To comply with regulatory obligations, we may collect:

• Names of buyers, sellers, and beneficial owners
• Corporate affiliations
• Identification documentation
• Information required under FINTRAC and anti-money laundering legislation

4. Artificial Intelligence, Automated Systems & Data Containment

We may utilize artificial intelligence systems, automated chat assistants, automated phone assistants, transcription systems, and digital intake technologies (collectively, “AI Systems”) to assist with:

• Property inquiries
• Appointment scheduling
• Buyer or seller intake
• General real estate information
• Administrative assistance
• Document collection

4.1 One-Way Intake Architecture

AI Systems are designed solely to:

• Receive information from users
• Provide automated informational responses
• Support internal administrative workflows

Information submitted through AI Systems:

• Is not published publicly
• Is not displayed to other users
• Is not posted to public forums
• Is not redistributed as public content
• Is not made available through open AI systems

User-submitted information remains private within our internal systems and authorized service providers.

4.2 No Public Dissemination or AI Training Use

We do not:

• Publish confidential buyer or seller submissions
• Share intake data with unrelated users
• Use identifiable client data to generate responses for other visitors
• Train public-facing systems using identifiable client data

AI Systems are designed for communication and intake purposes only.

4.3 AI Limitations

AI Systems:

• Operate based on programmed logic and user inputs
• May contain generalized information
• May contain inaccuracies or omissions
• Do not replace licensed real estate advice
• Do not create a representation agreement

All professional advice must be confirmed directly with a licensed representative.

4.4 User Responsibility

You acknowledge that:

• You are responsible for ensuring the accuracy of information submitted.
• You should not rely solely on automated responses when making buying or selling decisions.
• A formal client relationship is established only through a written representation agreement.

5. No Representation Relationship Through Website Use

Submission of information through:

• Contact forms
• AI chat
• AI phone systems
• Email
• Document uploads

Does not create a buyer representation agreement or seller representation agreement.

A client relationship is formed only after a written agreement is executed.

6. MLS®, IDX & Listing Data

Property listings displayed on this website may be sourced from MLS® or IDX systems.

MLS®/IDX data:

• Is deemed reliable but not guaranteed accurate
• May not reflect real-time availability
• Is subject to licensing restrictions
• Is provided for personal, non-commercial use only

We do not guarantee completeness, accuracy, or current status of listing information.

7. Purpose of Collection

We collect personal information to:

• Respond to property inquiries
• Facilitate real estate transactions
• Schedule showings
• Conduct client intake
• Comply with regulatory and FINTRAC obligations
• Maintain required brokerage records
• Improve our Services

8. Cookies & Analytics

Our website may use cookies, tracking pixels, and analytics technologies (“Tracking Technologies”) to:

• Ensure website functionality
• Improve performance
• Analyze traffic and usage patterns
• Monitor system security
• Enhance user experience

8.1 Information Collected by Cookies

Tracking Technologies may collect:

• IP address
• Browser type
• Device information
• Pages viewed
• Time spent on pages
• Interaction behavior
• Referral sources

This data is used for operational, analytical, and security purposes only.

8.2 No Public Disclosure of Cookie Data

Information collected through cookies:

• Is not published publicly
• Is not shared with other website users
• Is not posted to public forums

8.3 Third-Party Analytics Providers

We may use third-party service providers to assist with analytics and website performance.

These providers process data subject to contractual safeguards and applicable privacy laws.

8.4 Managing Cookies

You may disable cookies through your browser settings.

Disabling cookies may impact website functionality.

9. Electronic Communications & Document Uploads

Our Services may allow submission of:

• Identification documents
• Purchase agreements
• Deposit confirmations
• Financing documentation
• Listing documents

Electronic transmission carries inherent risks.

We implement reasonable safeguards but cannot guarantee absolute security.

10. Third-Party Service Providers

We may use third-party providers for:

• Hosting
• Cloud storage
• Email systems
• AI processing
• CRM systems
• MLS® integrations

These providers are contractually obligated to protect personal information.

11. Cross-Border Data Storage

Some service providers may store or process data outside Canada.

Where this occurs:

• Data may be subject to foreign legal requirements
• Reasonable contractual safeguards are implemented

12. Data Retention

We retain personal information:

• As long as necessary to fulfill transaction purposes
• As required by real estate regulatory laws
• As required under FINTRAC and anti-money laundering legislation

13. Safeguards

We implement reasonable administrative, technical, and physical safeguards including:

• Encrypted communications
• Secure portals
• Access controls
• Authentication procedures

No electronic system is completely secure.

14. Your Rights

You may:

• Request access to personal information
• Request corrections
• Withdraw consent (subject to legal limitations)

Requests must be submitted in writing to the Privacy Contact listed above.

15. Updates to This Policy

We may update this Privacy Policy from time to time.

The revised version will be posted with an updated “Last Updated” date.

Continued use of the Services constitutes acceptance of updates.