FHRE Privacy Code
The Forest Hill Real Estate Inc. Muskoka commitment to privacy
Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business within Forest Hill Real Estate Inc. Muskoka(FHRE)1.
We strive to provide you with the best customer service. To us, that includes treating you fairly and with respect.
The FHRE Privacy Code informs you of the ways we help protect your privacy and the confidentiality of your information.
We may amend this Code from time to time. We will post the revised Privacy Code on our website (website address)
Our Privacy Code
Our Privacy Code informs you of the practices we have in place relating to the management of personal information at FHRE in Canada. The word “information” means personal, financial and other details about you that you or your authorized representative provide to us and we obtain from others within or outside FHRE, including through the products and services you use.
This Code applies to any person who has requested from us, or offered to provide a guarantee for, any product or service offered by us in Canada. This includes individuals carrying on business alone or in partnership with other individuals and signing officers of our business customers. It consists of five key principles:
1. Collecting and using your information
Either before or when we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties such as credit bureaus.
Your information is used to help us manage services you have with us, contact you about services you may be interested in having with us and manage operations and risk within FHRE. Your information is also used in order to satisfy valid information requests from regulators and other organizations or individuals who are legally entitled to make such requests.
2. Releasing your information
We may provide your information to other persons in situations where:
· our suppliers, agents and other organizations who assist us in serving you, need the information
· we are required or permitted to do so by law or applicable regulators and self-regulatory organizations
· we want to prevent, detect or suppress financial abuse, fraud, criminal activity, protect our assets and interests or manage or settle any actual or potential loss
· you have provided your consent
3. Protecting your information
We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time it is required and for the purposes we explained to you.
4. Providing your information access and keeping your information accurate
Upon request, we will give you access to the information we retain about you and we will make reasonable efforts to keep your information accurate and up to date.
5. Respecting and responding to your privacy concerns
We will explain your options for withdrawing consent to the collection, use and disclosure of your information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your information.
In this Code, we explain how we fulfill each of these important principles.
Why we ask for your information
We ask you for information to enable us to complete your request and to establish and serve you as our customer.
We collect the information we need and only use it for the purposes explained to you.
When you apply for a new service we will indicate in the application or agreement how we intend to use your information. We will indicate clearly which information would help us serve you but is optional for you to provide.
We obtain most of our information about you directly from you.
At the time you request to begin a relationship with us and during the course of our relationship, we may collect information about you. The information we ask for depends on which product or service you want. For every product or service we need your name, address, birthdate, occupation and some identification. Here is why we need some of the information we may ask you to provide.
This helps us identify and authenticate you.
• Social Insurance Number (SIN)
Your SIN is required for when interest is earned, in order to comply with the Canada Revenue Agency’s income reporting requirements. Providing your SIN for credit products, or when applying for products online that do not earn investment income, is optional. If you provide us with your SIN, we also use it to keep your information separate from that of other customers with a similar name, including information we obtain with your consent through the credit approval process.
• Employer name and address
This is required when a new account is opened in order to comply with anti-money laundering or other regulations.
We also collect information during our interactions with you.
• Over the phone
We may monitor and/or record your telephone discussions with our representatives for our mutual protection, to enhance customer service and confirm our discussions with you.
• In person
We may use video or photographic surveillance to monitor and/or record the activity that occurs in and around FHRE premises, such as at our retail branch offices. We use this information for security and investigation purposes, relating to, among other things, theft, vandalism, damage to property and fraud.
• Through email
When you send us an email or when you ask us to respond to you by email, we learn your exact email address and any information you have included in the email.
We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further.
How we obtain your consent
It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your information.
Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain information, inquire about or apply for products, or services from us.
We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.
Why we share your information
We may share information within FHRE to manage your total relationship with us including servicing your account and maintaining information about you, to manage and assess our risks and operations, to comply with legal or regulatory requirements.
Your information may be shared, stored or accessed in Canada or other jurisdictions or countries. Your information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.
In order to understand when you can withdraw your consent, refer to the “Respecting your preference” section.
When we release your information
We do not sell or rent customer lists or personal information to others. However, we may release your information to parties outside FHRE in certain circumstances, which include –
• For servicing purposes
We give a limited amount of information, only as necessary, to our vendors, suppliers and agents. These suppliers and agents may be located in Canada or other jurisdictions or countries and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.
• When required or permitted to do so by law or applicable regulators and self-regulatory organizations
We may release information in response to a search warrant, court order or other demand or inquiry which we believe to be valid. This may include requests from regulators, including self-regulators, who are responsible for ensuring FHRE is in compliance with applicable regulations.
• To protect our interests
We may also disclose information to any person or organization, including an investigative body, in order to prevent, detect or suppress, financial abuse, fraud, criminal activity, protect our assets and interests, or manage or settle any actual or potential loss or in the case of a breach of agreement or contravention of law.
How we protect your information
We will protect your information with appropriate safeguards and security measures.
We have security standards to protect our systems and your information against unauthorized access and use.
All our vendors, suppliers and agents, as part of their contracts with TD, are bound to maintain your confidentiality and may not use your information for any unauthorized purpose.
When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required. All employees of FHRE are familiar with the procedures that must be taken to safeguard customer information. And to us, protecting the confidentiality of your information is more than a procedure – it’s part of our job. It is specified in our employment agreements and regularly confirmed in writing.
The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date or for legal or regulatory purposes. When your information is no longer needed for these purposes, we have procedures to destroy, delete, erase or convert it to an anonymous form.
Your right to access your information
Upon request, we will give you access to the information we have about you. If requested, we will assist you in making your request.
Most of this information is in the form of your transaction records.
If you require other information, simply contact or forward a written request to the branch or office where your account is held. We will ask you for specific details.
We will advise you in advance if a minimal charge will be required for conducting the search and we will respond to your request within 30 days.
Please note that we may not be able to provide information, from our records, about you which contains references to other persons, is subject to legal privilege, contains confidential information proprietary to FHRE, relates to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons.
If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. If we relied on information from a third party, such as a credit bureau, to make the decision, we will provide you with the name and address of the third party.
Keeping your information accurate
We will make reasonable efforts to keep your information accurate and up to date.
Having accurate information about you enables us to provide you with better service and minimize the possibility that out-of-date information may be used to make a decision that impacts you. We have procedures and practices in place to help us maintain the accuracy of your information. For most updates, we rely on you for information. You can help by keeping us informed of any changes, such as if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections immediately, and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.
Respecting your preference
We will explain your options of withdrawing consent to the collection, use or release of your information, and, given reasonable notice, we will record and respect your choices.
In most cases you are free to refuse or withdraw your consent at any time. You may do so by contacting the branch where your account is held or reply/click unsubscribe to an email received.
There are several privacy preferences available to you, subject to legal, business or contractual requirements. If you prefer, you may choose not to have us –
· Contact you by telephone, fax, text messaging, or other electronic means at the numbers you have provided us, internet, mail, email and other methods with marketing offers that may be of interest to you.
This does not include messages or other information about promotional offers we provide on, or enclose with, your written or electronic account statements, or that we may discuss while talking with you. Any marketing campaigns that are already underway may not immediately take your preferences into account.
· Share your financial information within FHRE in certain circumstances.
We can restrict access to your profile such that only certain groups within FHRE have access to your account details.
Do you have a complaint?
Resolving your complaint
At FHRE, we take your complaints seriously and are committed to helping resolve your complaint about FHRE or the service you’ve received.
Usually, the best way to address the complaint is to raise the issue as soon as it comes up with the person you are dealing with. Even if you don’t notice the issue right away, you can always get in touch with us at any time to voice your complaint. Please use any one of the contact options provided below.
Before you begin:
· Have any supporting documents available.
· Consider what solution you think is appropriate.
To help us serve you better, please follow these three steps:
Step 1: Voice your complaint
To tell us about your complaint, please use the contact information provided below.
For your own security and safety, never send out your account details or any other confidential information by e-mail.
If you are not satisfied with the resolution provided in Step 1, please proceed to Step 2.
Step 2: Escalate your complaint
You can escalate your complaint in the following ways:
1. Ask the individual you are dealing with in Step 1 to escalate on your behalf to your local Branch Manager.
2. Escalate the complaint directly with Chief Compliance Officer, using the following contact information.
Chief Compliance Officer
441 Spadina Road
Step 3: Additional Escalation Options
At Step 3, there are several escalation options that may provide further review of your concern or additional information.
Industry Regulators and Additional Resources
The following independent services may provide you with information and a further review of your complaint. These agencies may contact TD to facilitate their investigation and work toward a resolution.
Office of the Privacy Commissioner of Canada (OPCC)
Phone: 1-800-282-1376 Fax: 1-819-994-5424
Mail: 30 Victoria Street, Gatineau, QC K1A 1H3