Revised: March 25, 2019
1. Managing Your Information Preferences
2. Information We Collect
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
3. How We Use Information and When We May Share and Disclose Information Generally
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.
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.
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.
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.
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.
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.
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.
12. Special Note for EU Users—Your Rights and Choices
The data controller for the Site and Services is:
Savills Inc., Brokerage 181 Bay Street, Suite #2810Toronto, 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.
13. Resolving your Privacy Concerns