Privacy Policy

Revised:  May 25, 2018

Your information privacy is extremely important to us.  We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Savills website located at http://www.savills-studley.ca and http://www.savills.ca (“Site”) and any Savills mobile application, application programming interfaces, and other services offered by Savills Studley, Inc., Brokerage o/a Savills, Brokerage (“Services”).  This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below).  This Privacy Policy applies to all users of the Site and Services.  The Site and Services are provided by Savills Studley, Inc., Brokerage o/a Savills, Brokerage  (“Companywe” “our” “us”).

BY USING THE SITE OR SERVICES, YOU ARE CONSENTING THAT WE MAY COLLECT, USE, AND DISCLOSE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.  PLEASE READ IT CAREFULLY.

  1. 1. Managing Your Information Preferences

You can review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by changing the relevant settings in your account or by e-mailing us at dataprivacy@savills-studley.com.  If you have questions or concerns regarding this Privacy Policy, please e-mail us at the same address.

  1. 2. Information We Collect

Personal Information

Personal Information” means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address).  This Privacy Policy does not cover business contact information or aggregated data from which the identity of an individual cannot be determined.  We retain the right to use business contact information and aggregated data in any way that we determine appropriate.  You may be asked to provide us with Personal Information when you register with the Site or use any of our Services, and at other times.

Usage Data and Site Activity

We automatically collect information regarding the actions you take on the Site (“Usage Data”).  For example, each time you use the Site we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site.  We use this information to help us understand how people use the Site and Services, and to enhance the services we offer. 

Cookies and Anonymous Identifiers

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie).  We use cookies and other anonymous identifiers to analyze use of and improve the Site and Services.  Most web browsers are initially set up to accept cookies.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies.  Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.

We use Google Analytics on the Site and Services to collect Usage Data, to analyze how users use the Site and Services, and to provide advertisements to you on other websites.  For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

  1. 3. How We Use Information and When We May Share and Disclose Information Generally

We use Personal Information for internal purposes only, such as to provide you with the Site and Services, to improve the Site and Services, to notify you of new research reports and other products or services, and to otherwise communicate with you about our Company.  We may also use your Personal Information to provide more relevant search results from the search functions of the Site and the Services.  We will not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Privacy Policy.  We may disclose to third parties, certain Usage Data regarding the Site and Services.  However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually.

  1. 4. Service Providers

From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”).  For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions.  We only provide our Service Providers with the information necessary for them to perform these services on our behalf.  Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure.  Service Providers are prohibited from using Personal Information other than as specified by us.

  1. 5. Where Information Can Be Shared Or Disclosed Without Consent

There may be exceptional circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose information without your consent.  Such circumstances may include:

 

  • Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
  • Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
  • Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;
  • Where the information is public as permitted by law;
  • Where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or
  • Where it is necessary for the purpose of a prospective business transaction if the information is necessary to determine whether to proceed with the transaction or to complete the transaction, or a completed business transaction where the information is necessary to carry on the activity that was the object of the transaction. In this case, the party with whom we enter into the business transaction will be contractually bound to only use and disclose personal information for purposes related to the proposed transaction; protect the information with appropriate security safeguards; and return or destroy the information if the transaction does not proceed.

Where obliged or permitted to disclose information without consent, we will not disclose more information than is required.

  1. 6. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.  We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

  1. 7. Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others.  In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others.  This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

  1. 8. Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us.  Within the Company, access to your Personal Information is granted only to authorized employees and agents of the Company who require access to fulfill their job requirements or on a “need to know” basis.  All our personnel are expected to sign a Confidentiality/Privacy Agreement that specifies that Personal Information is confidential and cannot be disclosed to anyone outside the Company.  However, no data transmission over the Internet or other network can be guaranteed to be 100% secure.  As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk. 

  1. 9. Links

Our Site and Services may contain links to other websites or allow others to send you such links.  A link to a third party’s website does not mean that we endorse it or that we are affiliated with it.  We do not exercise control over third-party websites.  You access such third-party websites or content at your own risk.  You should always read the privacy policy of a third-party website before providing any information to the website.

  1. 10. Children’s Privacy

The Site and Services are intended for users who are 13 years old or older.  We do not knowingly collect Personal Information from children under the age of 13.  If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.  Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.

  1. 11. Processing in the United States 

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country.  If you are located outside of the United States, please be advised that we process and store all information in the United States.  The laws in the United States may not be as protective of your privacy as those in your location.  By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.  Your personal information may also be subject to access by and disclosure to law enforcement agencies under the applicable laws in the United States.

  1. 12. Special Note for EU Users—Your Rights and Choices

The data controller for the Site and Services is:

Savills Studley, Inc., Brokerage o/a Savills, Brokerage 

181 Bay St #2810

Toronto, ON M5J 2T3

Canada

Under EU data protection legislation we are only permitted to use your Personal Information if we have a legal basis for doing so.  In addition to your consent, we rely on the following legal bases to use your information:

  • For employment-related purposes
  • Where we need information to perform the contract we have entered into with you
  • Where we need to comply with a legal obligation
  • Where the processing is necessary for us to carry out activities for which it is in our legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
    • Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns—this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
    • Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
    • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively—this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer;  processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialized in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorized access or to comply with a request from you in connection with the exercise of any of your rights outlined below.

In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your interests (or someone else's interests)
  • Where it is needed in the public interest or for official purposes

We may process special categories of Personal Information and criminal conviction information in the following limited circumstances:

  • With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

You have a number of rights under EU data protection legislation in relation to your Personal Information, these include the right to:

  • Be informed about how we use your Personal Information
  • Obtain access to your Personal Information that we hold
  • Request that your Personal Information is corrected if you believe it is incorrect, incomplete or inaccurate
  • Request that we erase your Personal Information in the following circumstances:
    • If we are continuing to process Personal Information beyond the period when it is necessary to do so for the purpose for which it was originally collected
    • If we are relying on consent as the legal basis for processing and you withdraw consent
    • If we are relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing
    • If the Personal Information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
    • If it is necessary to delete the Personal Information to comply with a legal obligation
  • Ask us to restrict our data processing activities where you consider that:
    • Personal Information is inaccurate
    • our processing of your Personal Information is unlawful
    • where we no longer need the Personal Information but you require us to keep it to enable you to establish, exercise or defend a legal claim
    • where you have raised an objection to our use of your Personal Information
  • Request a copy of certain Personal Information that you have provided to us in a commonly used electronic format. This right relates to Personal Information that you have provided to us that we need in order to perform our agreement with you and Personal Information where we are relying on consent to process your Personal Information
  • Object to our processing of your Personal Information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your Personal Information
  • Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you wish to exercise any of your above rights, please reach out to us by any of the ways mentioned in the “Managing Your Information Preferences” section of this Privacy Policy.

Regarding the transfer of Personal Information to countries outside the EU, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer of Personal Information to controllers or processors established in third counties as the case may be.

The period for which we will keep your Personal Information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain Personal Information for a longer period, or where we may need to retain the information in case of a legal claim.

  1. 13. Resolving your Privacy Concerns

In the event of questions about: (i) access to your Personal Information;  (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Privacy Policy; please contact our Privacy Officer by sending an e-mail to dataprivacy@savills-studley.com or writing to:

Savills Studley, Inc., Brokerage o/a Savills, Brokerage 

181 Bay St #2810

 

Toronto, ON M5J 2T3

Canada

We will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.  If we are unable to resolve your concerns to your satisfaction you may contact the Privacy Commissioner of Canada by writing to:

Office of the Privacy Commissioner of Canada

Place de Ville

Tower B, 3rd Floor

112 Kent Street

Ottawa, Ontario  K1A 1H3

  1. 14. Privacy Policy Changes

We may change this Privacy Policy from time to time.  If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site.  Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy.  By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.

 

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