Personal Information  Protection

At MLS, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.

We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.

 

Scope of this Policy

This Personal Information Protection Policy applies to MLS.

Personal Information –means information about an identifiable individual including name, age, home address and phone number, marital status, medical information, education, employment information, passport and/or identifying identification including Drivers’ License. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.

 

Privacy Officer – means the individual designated responsibility for ensuring that MLS complies with this policy and PIPEDA. 

1.1 Unless the purposes for collecting personal information are obvious and the client purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. 

1.2 We will only collect client information that is necessary to fulfill the following purposes: 

· To verify identity;

· To open and manage a file;

· To deliver requested services

· To ensure a high standard of service to our clients; 

· To meet regulatory requirements.

1.3 Personal Data

We may use Personal Data for the following purposes: 

1.3.1 To provide and maintain our Service, including to monitor the usage of our Service. 

1.3.2 To manage your Account: to manage your registration as a user of the Service. The Personal Data you  provide can give you access to different functionalities of the Service that are available to you as a  registered user. 

1.3.3 For the performance of a contract: the development, compliance and undertaking of the purchase  contract for the products, items or services you have purchased or of any other contract with us through  the Service. 

1.3.4 To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic  communication, such as a mobile application's push notifications regarding updates or informative  communications related to the functionalities, products or services, including the security updates, when  necessary or reasonable for their implementation. 

1.3.5 To provide you with news, special offers and general information about other goods, services and events  which we offer that are similar to those that you have already purchased or enquired about unless you  have opted not to receive such information. 

1.3.6 To manage your requests: To attend and manage your requests to us. 

1.3.7 For other purposes: We may use your information for other purposes, such as data analysis, identifying  usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve  our Service, products, services, marketing and your experience.

1.4 Usage Data is collected automatically when using our Website.

1.4.1 Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address),  browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the  time spent on those pages, unique device identifiers and other diagnostic data. When you access the  Service by or through a mobile device, we may collect certain information automatically, including, but  not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your  mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device  identifiers and other diagnostic data. We may also collect information that your browser sends whenever  you visit our Service or when you access the Service by or through a mobile device. Tracking  Technologies and Cookies we use Cookies and similar tracking technologies to track the activity on our  Service and store certain information. Tracking technologies used are beacons, tags, and scripts to  collect and track information and to improve and analyze our Service. 

1.4.2  The technologies we use may  include: 

Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your  browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept  Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser  setting so that it will refuse Cookies, our Service may use Cookies. 

Web Beacons. Certain sections of our Service and our emails may contain small electronic files known  as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company,  for example, to count users who have visited those pages or opened an email and for other related  website statistics (for example, recording the popularity of a certain section and verifying system and  server integrity). Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your  personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as  you close your web browser. We use both Session and Persistent Cookies for the purposes set out  below: 

Necessary/Essential Cookies Type: Session Cookies Administered by us: Purpose: These Cookies are  essential to provide you with services available through the Website and to enable you to use some of its  features. They help to authenticate users and prevent fraudulent use of user accounts. Without these  Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to  provide you with those services.

1.4.3 Cookies Policy/Notice Acceptance 

Cookies Type: Persistent Cookies Administered by us: Purpose:  These Cookies identify if users have accepted the use of cookies on the Website. 

Functionality Cookies Type: Persistent Cookies Administered by us Purpose: These Cookies allow us to  remember choices you make when you use the Website, such as remembering your login details or  language preference. The purpose of these Cookies is to provide you with a more personal experience  and to avoid you having to re-enter your preferences every time you use the Website. 

Tracking and Performance Cookies Type: Persistent Cookies Administered by 

Third-Parties Purpose:  These Cookies are used to track information about traffic to the Website and how users use the Website.  The information gathered via these Cookies may directly or indirectly identify you as an individual visitor.  This is because the information collected is typically linked to a pseudonymous identifier associated with  the device you use to access the Website. We may also use these Cookies to test new pages, features  or new functionality of the Website to see how our users react to them. 

1.5 Security of Your Personal Data

1.5.1 The security of your Personal Data is important to us, but remember that no method of transmission over  the Internet, or method of electronic storage is 100% secure. While we strive to use commercially  acceptable means to protect your Personal Data,  we cannot guarantee its absolute security. 

The Service Providers we use may have access to your Personal Data. These third-party vendors  collect, store, use, process and transfer information about your activity on Our Service in accordance  with their Privacy Policies. 

1.5.2 Analytics: We may use third-party Service providers to monitor and analyze the use of our Service. 

1.5.3 Children's Privacy: Our Service does not address anyone under the age of 13. We do not knowingly  collect personally identifiable information from anyone under the age of 13. If you are a parent or  guardian and you are aware that your child has provided us with Personal Data, please contact us. If we  become aware that we have collected Personal Data from anyone under the age of 13 without  verification of parental consent, we take steps to remove that information from our servers. If we need to  rely on consent as a legal basis for processing your information and your country requires consent from  a parent, we may require your parent's consent before we collect and use that information. 

1.5.3 Links to Other Websites: Our Service may contain links to other websites that are not operated by us. If  you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

Policy 2 – Consent

2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted  below, we are authorized to do so without consent). 

2.2 Consent can be provided in writing, or it can be implied where the purpose for collecting using or  disclosing the personal information would be considered obvious and the client voluntarily provides  personal information for that purpose. 

2.3 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or  product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, can  withhold or withdraw their consent for MLS to use their personal information in certain ways. A client’s  decision to withhold or withdraw their consent to certain uses of personal information may restrict our  ability to provide a particular service or product. If so, we will explain the situation to assist the client in  making the decision. 

2.4 We may collect, use or disclose personal information without the client’s, knowledge or consent in the  following limited circumstances: 

· When the collection, use or disclosure of personal information is permitted or required by law;

· In an emergency that threatens an individual's life, health, or personal security;

· When the personal information is available from a public source (e.g., a telephone directory);

· For the purposes of collecting a debt;

· To protect ourselves from fraud;

· To investigate an anticipated breach of an agreement or a contravention of law 

Policy 3 – Using and Disclosing Personal Information

3.1 We will not use or disclose client personal information for any additional purpose unless we obtain  consent to do so. 

3.2 We will not sell client lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client, has a reasonable opportunity to request access to it. 

4.2 Subject to policy 4.1, we will retain client purpose. 

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete  where it may be used to make a decision about the client or disclosed to another organization. 

5.2 Clients may request correction to their personal information in order to ensure its accuracy and  completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. 

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the  information as required and send the corrected information to any organization to which we disclosed  the personal information in the previous year. If the correction is not made, we will note the clients’  correction request in the file. 

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 

6.2 The following security measures will be followed to ensure that client personal information is  appropriately protected: 

· Use of locked filing cabinets

· Physically securing offices where personal information is held

· The use of user IDs and passwords, encryption and firewalls where available

6.3 We will use appropriate security measures when destroying client’s personal information such as  shredding client files. 

6.4 We will continually review and update our security policies and controls as technology changes to  ensure ongoing personal information security. 

Policy 7 – Providing Clients Access to Personal Information

7.1 Clients have a right to access their personal information, subject to limited exceptions. Paralegal-client privilege

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify  the personal information being sought. 

7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been  disclosed if applicable. 

7.4 We will make the requested information available within 30 business days, or provide written notice of  an extension where additional time is required to fulfill the request. 

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we  will inform the client of the cost and request further direction from the client on whether or not we should  proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal  and the recourse available to the client. 

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Owner of MLS is responsible for ensuring MLS’s compliance with this policy 

8.2 Clients should direct any complaints, concerns or questions regarding compliance in writing to the  Laurel Marshall is unable to resolve the concern, the client may also write to the Information and Privacy  Commissioner of Ontario. 

Contact information for Laurel Marshall: 905-449-7386