”) describes how Max Wright Real Estate Corporation dba Sotheby’s International Realty Canada and Gestram Real Estate Services Inc. dba Sotheby’s International Realty Québec (collectively, the "Company
”, or “us
”) collects personal information, the type of information collected, how that personal information is used, to whom personal information may be disclosed, the safeguards in place to protect personal information, and your rights with regard to your personal information. This Policy applies to any personal information we receive from or about individuals who are not employed by the Company, for as long as we hold your information, including after the end of any business relationships.
2.Collection of Personal Information
The Company may collect information directly from you when you communicate or interact with us or when you update your account preferences and settings. We may also collect your information indirectly and from other sources listed below. Where required, the Company will obtain your consent for collection.Sources of Collection
The Company collects certain information when you submit or provide it to us directly. When you interact with our websites, apps, and contact forms (together with offline interactions, the “Services”) online, we also automatically collect information about you and your use of the Services with log processes, cookies, location-identifying technologies, and other tracking technologies. Certain information is collected about you from third parties, including when you connect through a third-party service or business partner site or when information is shared by merchants and business partners with whom you’ve also interacted.Type of Information Collected
The types of information we collect about you may include personal information of the following types:
- Identifiers that you provide us directly, such as your first and last name, date of birth, postal address, email address, information from identification documents, tax/financial information, job, account numbers, phone number, and language/communication preferences
- Information about other individuals besides yourself (beneficiaries, your spouse or common-law partner, incapacitated persons for whom you are acting as a power of attorney, etc.)*
- *If you provide us with information about another individual, we will assume that you are authorized to do so and that you have obtained that individual’s consent for the collection, use, or disclosure of that information for the purposes set out in this Policy
- Identifiers collected through your use of the Services, such as unique online or device identifiers, IP address, device or session IDs and information regarding your system configuration (operating system and version), network, and connected hardware (e.g. computer or mobile device and carrier) and software applications (e.g. other applications installed on your mobile device)
- Client Record Information, such as account names and numbers, financial/professional background, income amounts and sources, and reasons for doing business with us
- Classification Characteristics, such as your gender, age, household income, marital status, or your inclusion in any other classification, only to the extent you provide this information to us as demographic information in a survey response that is identifiable to you
- Internet and other network activity, such as your browsing and search history and your interactions with Company sites and Services, including:
- URLs of the pages you visit;
- Date and time stamps associated with browsing, searches, and clicks;
- Click stream data, meaning the page-by-page clicks that you make as you navigate through our Services, including the web pages visited before arriving at Company websites;
- Member account credentials, including username and password; and
- Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you, except “sensitive” information.
3.Use and Disclosure of Personal Information
The Company only collects personal information that is directly related to our business activities. By entering personal information onto our website, you are thereby consenting to the processing of your personal information for our business purposes with respect to your current home sale and/or prospective home purchase, market research, or for the reasons more particularly described in your real estate transaction. The amount and the type of information collected will be limited to that which is needed to fulfill the identified purpose(s).Use of Personal Information
The Company uses personal information for the following purposes:
Disclosure of Personal Information
- To respond to requests for information or legal proceedings
- To provide you with client service
- To conduct, process, and complete transactions with you
- To make available, promote, and offer properties, services, products, and/or special offers
- To administer a contest, promotion, survey, or other website feature
- To send periodic emails regarding your interest in property listings and services
- To manage risk, including credit and business risks, and comply with applicable laws and regulations
- To prevent, detect, and control fraud, spam, and other malicious behaviour, as well as any unauthorized or illegal activities (money laundering, cyber threats, etc.)
- Enable due diligence of our operations in preparation for a business transaction
- To communicate with you using the contact information you provided (by mail, email, text messages, phone calls, social media)
- To improve and customize the content and/or layout of our website for individual visitors
- To identify usage trends and statistics
- To provide you marketing information, subject to your consent where required, including personalized offers, special offers, and/or more relevant offers, and through digital advertising
- To advertise to you online, including targeting advertising to you on other websites
- To comply with applicable laws, rules, regulations, and judicial authorities
- To enable us to better serve you
To accomplish the purposes for which your personal information was collected, Company employees may have access to your personal information, but only to the extent required by their respective functions.
The Company may share your personal information with third parties, for example to its co-contractors, agents, sub-contractors, or service providers (including website hosting and providers, etc.) to conduct business activities. These third parties have access to your personal information only to the extent required by their functions and are bound by the same obligation of confidentiality as the Company. In certain cases provided for by law, the Company may communicate your personal information to third parties without your consent.
With respect to our business activities, your personal information may be provided to the following third parties:
- Legal advisors, accountants, and/or auditors
- The real estate agent and/or broker who introduced you to the Company
- Other Sotheby’s International Realty or Peerage Capital companies, subsidiaries, or affiliates
- Data processing companies that contract with us and/or process our marketing campaigns on our behalf
- To collect a debt owed to the Company by the individual or client
- Insurance companies providing coverage to us or to you
- Governmental or regulatory authorities, bodies, or agencies
- Any other parties disclosed in agreements of purchase and sale that are signed by you
- To comply with a subpoena, a warrant, or an order made by a court or other body with appropriate jurisdiction
- As required by applicable law
- At your request, a party acting for you, a financial institution, or a credit reporting agency
- A person who is otherwise involved in your business relationship with us
Québec consumers only:
In cases where the Company must communicate your personal information outside Québec, it considers the sensitivity of the information, the purpose for which it will be used, and the measures that will be taken to protect it outside Québec. Except in cases provided for by law, the Company will communicate your personal information outside Québec only if it determines, after analysis, that the personal information will be adequately protected in the location where it is to be communicated or kept.
4.Your Privacy Rights
You have certain rights in relation to your personal information under applicable laws, subject to certain exceptions. To assert your privacy rights, please contact the Company as indicated at the end of this Policy.Right to Know and Access
You have the right to request to know the personal information specific to you that the Company collected, used, disclosed for a business purpose, and shared for the purposes of cross-context or targeted advertising, including the purposes of use, categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information. You also have the right to request to receive a copy of the specific pieces of personal information we have collected about you (note that we will not provide any sensitive personal information we may hold in response to this type of request).Right to Correct
You have the right to request that the Company correct any inaccurate or incomplete personal information we have collected from you or maintain about you, subject to certain exceptions.
5.Communication PreferencesEmail Marketing
The Company may send you periodic electronic communications and direct mailings when you sign up for an account. If you consented to receiving promotional email communications, you can withdraw your consent at any time by following the instructions provided in those communications to unsubscribe or stop them, modifying the settings of your account, or contacting us at email@example.com. Data Collection and Sharing Preferences
You may in some cases have the option to decline to provide the Company with certain information; however, your choice may impact your use of certain features or services for which that information is a necessary component.
This site and any related services are intended for adults 18 years of age or over as applicable by provincial law.Retention of Data
We may retain information about you for as long as it is necessary to fulfill the purposes indicated. Some of your information may be retained in our systems to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, undertake any investigations necessitated by the foregoing, or otherwise use internally in a lawful manner that is reasonably aligned with your reasonable expectations or compatible with the context in which the information was provided.Information Security
In accordance with regulatory requirements, the Company has implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that it processes. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security. Information, including email and any communication via the Internet, network, telephone, or any other technological means, may be illicitly intercepted by unauthorized third parties.
However, the Company cannot guarantee the effectiveness or absolute security of these measures. It is always possible that a hacker may succeed in penetrating the Company’s servers, or that any other type of breach of confidentiality of your personal information may occur. In the event of a confidentiality incident involving your personal information, the Company will notify you as required by law.Scope
This policy no longer applies as soon as you leave the Company’s sites and platforms to access a third-party site, including sites accessible via hyperlinks posted on Company sites and platforms.
By providing the Company with your personal information, you agree to it being processed in accordance with this Policy, including disclosure to third parties.
The Company is responsible for all personal information under our control. The Company’s General Counsel & National Director, Administration is accountable within Sotheby’s International Realty Canada. The Regional Director, Québec is accountable within Sotheby’s International Realty Québec. If you have any questions, concerns, or complaints regarding the privacy practices of our organization or would like information on our use of service providers located outside of Canada please write to us at:Email: firstname.lastname@example.orgQuébec:
Sotheby’s International Realty Québec
ATTN: Georges Gaucher, Regional Director, Québec
1430 rue Sherbrooke Ouest
H3G 1K4All other provinces:
Sotheby’s International Realty Canada
Attn: Madeleine Tyber, General Counsel & National Director, Administration
1867 Yonge Street, Suite 100
8.Changes to this Policy
This Policy is current as of the effective date set forth below. We reserve the right to change this Policy from time to time, consistent with applicable privacy laws and principles and our practices in relation to personal information. If we make changes to this Policy, we will notify you by revising the date below.Last Updated: January 4, 2024