PRIVACY POLICY
Rennie & Associates Realty Ltd., rennie group dba, Rennie and Associates LLC and Rennie Group of California, and our corporate affiliates (the “Company”, “we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services. This privacy policy (the “Policy”) explains our practices for processing your personal information. It does not apply to our employees’ personal information, de-identified information, or other information that is exempt from applicable privacy laws. This Policy also does not apply to the business contact information that we collect from residents of Canada.
This Policy describes how we may collect, use, disclose, retain, dispose of and otherwise process (collectively, “process”) your personal information that you provide or that we collect through our website found at https://rennie.com and other locations from time to time (the “Website”), and the products, services, software and tools we provide through the Website (collectively, the “Services”). This Policy references our general Terms of Use located at https://rennie.com/terms, and forms an integral part of them. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Use.
If you are a resident of Canada, see Annex 1, Section B. for additional information about your rights under Canadian law.
If you are a resident of California, please see Annex 1, Section A, California Notice at Collection and Privacy Policy, which includes additional information about the categories of personal information that we may collect about you and your rights under California privacy laws.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using our Website or Services, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to us processing your personal information in accordance with this Policy and as may be further identified when the personal information is collected. If you do not consent to the processing of your personal information, please do not access or continue to use the Website or any of our Services, or otherwise provide any personal information to us.
Table of Contents
For the purposes of this Policy, “personal information” means any information about an identifiable individual or any information that can be used, either alone or in combination with other information, to identify an individual (for example, an individual’s name, mailing address, telephone number and email address), but excludes any information that is exempted by applicable privacy laws.
The types of information we receive and collect depends on how you use our Website. Our Website has option features which, if used, require us to collect additional information to provide such features. You will be notified of such collection, as appropriate. If you choose not to provide the information needed to use a feature, you will be unable to use the feature. For example, a user must provide a valid email address or phone number to create an account to access our “Virtual Office Website”.
Directly Collected Personal Information
When you use our Website or Services, we may collect the following personal information from you:
Your personal information may be collected when:
We only collect personal information that we need. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.
Automatically Collected Personal Information
We, and our third-party partners, may also automatically collect information about you and any computer or device you use to access our Website, read our emails or otherwise engage with us. Some of the information we may collect, and ways we may collect it include:
Collection from Third Parties
We do not knowingly collect your personal information from a third party, unless you consent or we are otherwise exempt, authorized or required by applicable laws to do so. For example, we may collect your personal information from the following third parties:
If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.
We may process your personal information for the following purposes:
We collect, use, disclose and otherwise process your personal information in accordance with this Policy and applicable privacy laws. Where required by applicable laws, we will obtain your consent to engage in certain processing activities. Users in Canada, please see Annex 1, Section B. for additional information about the legal bases for which we process your personal information.
We will not share your personal information with any third party, except as indicated in this Policy or as authorized or required by law.
We may disclose your personal information for the Purposes as described in this Policy in the following ways:
We have implemented reasonable safeguards that are intended to protect the personal information in our custody or under our control from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information.
Your personal information may be communicated, transferred, stored and processed outside of your province or territory of residence, in any other province, territory, or country where we have operations or in which we engage Service Providers. By using our Services you understand that your information will be transferred to provinces, territories, or countries outside of your place of residence, including the United States. You acknowledge that your personal information may be transferred, processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the Canada, the United States and elsewhere may be able to access or obtain disclosure of your personal information under a lawful order or otherwise through the laws of the such jurisdiction, irrespective of the safeguards we have put in place for the protection of your personal information. In these cases, we will comply with applicable local law requirements relating to the conditions for disclosure or release of personal information.
You have certain choices regarding our processing of your personal information. For example:
Marketing Communications. We may send periodic promotional and operational emails or other similar communications to you if permissible under applicable law, and with your consent if required by that law. You may change your preferences by following the instructions provided to you in the communication. If you opt out of receiving promotional emails from us, we may still send you communications about your account or any Services you have requested or received from us.
Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Website and Services and those of third parties, in order to display more relevant targeted advertising to you. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance).
Cookie Preferences. You can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. You can also manage your cookie preferences through the “Cookie Settings” link at the bottom of the webpage. Visitors to our Website who disable cookies will be able to browse the Website, but some features may not function. If you visit our Website from a different device or from a different browser on the same device, you will need to apply your cookie settings for that browser and/or device as well.
Reviewing, Updating and Correcting. You can request to review and update the personal information you have provided us by contacting us as set out in Section 11 below.
If you are a resident of Canada or of California (USA), please review Annex 1 for additional information about your rights and how to exercise them, as applicable.
We will delete, destroy, erase, aggregate or de-identify documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer required for a legal or business purpose.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.
We may use and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (e.g. data that is no longer reasonably linked or linkable to an identified or identifiable individual, household, or personal or household device) we will maintain and use the information in de-identified form and not attempt to re-identify the information, except in order to determine whether our de-identification processes are reasonable and adequate pursuant to applicable privacy laws.
Our Website may contain links to other websites, applications or Internet resources (“Third-Party Services”) which are provided or made available solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services. We do not endorse and have no responsibility or liability for, nor do we have any control over, those Third-Party Services, their content or their processing of your personal information. We encourage you to read the privacy policies of those Third-Party Services to learn how they process your personal information.
Our Website and Services are intended solely for users who are not minors (e.g. those who are 18 years of age or older). We do not knowingly collect personal information about any minor, and no minor, nor any parent or guardian as it relates to such minor, should submit such minor’s personal information to us through the Website, the Services or otherwise for any reason and under any circumstances. By using our Website or Services, you are representing that you are at least 18 years old.
If you believe that a minor has provided us with personal information without parental consent, please contact us at the address indicated in Section 11 below and we will work to delete that data from our systems.
This Policy was last updated as of the “Last updated” date set out at the beginning of this Policy.
We may update this Policy from time to time to ensure ongoing compliance with applicable laws and for any other purpose that we deem reasonably necessary. We therefore encourage you to periodically review this Policy to ensure you are aware of any changes.
If we make any material changes, we will either (a) notify you by email (sent to the email address listed in our records), or (b) provide a notice on the Website before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected after the date that this Policy is posted or on the date as specified in the notification. Your continued use of the Website or Services following the effective date of any changes to this Policy signifies your acceptance of such changes.
If you have any questions or concerns regarding our compliance with this Policy and our processing of your personal information, you may contact our Privacy Officer at privacy.officer@rennie.com.
If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested.
Annex 1
Jurisdiction-Specific Privacy Notices
The following supplemental Privacy Notices supplement the information in our Privacy Policy. Unless otherwise expressly stated, all terms used but not defined in these supplemental Privacy Notices have the meanings given to them in our Privacy Policy.
The following only applies to residents in the State of California.
California Consumer Privacy Act
In this section, we provide additional information to California residents about how we handle their personal information, as required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA, such as publicly available information or deidentified or aggregated information.
Categories of Personal Information Collected and Disclosed.
The table below identifies, generally, the categories of personal information we have collected about California residents, as well as the categories of third parties to whom we may disclose this personal information for a business or commercial purpose.
Categories of Personal Information |
Third-Party Disclosures for Business or Commercial Purposes |
Identifiers. Includes direct identifiers such as name, alias, email, phone number, address, unique personal identifier, online identifier, IP address, or other similar identifiers. |
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Customer Records. Includes your account and profile information and customer records that contain personal information, such as name, demographics and other characteristics or descriptions, contact information, and financial or payment information. |
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Commercial Information. Includes records of property and/or Services purchased, obtained, or considered, or other purchasing or use histories or tendencies. |
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Internet or Other Electronic Network Activity Information. Includes browsing history, clickstream data, search history, and information regarding interactions with our Website and Services, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services. |
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Location Data. Such as general location information about a particular individual or device. |
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Audio, Electronic, Visual, or Similar Information. Includes information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, and photographs. |
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Professional or Employment-related Information. Includes professional and employment-related information such as current and former employer(s), position(s), job title(s) and job role(s), business contact information, and professional memberships, qualifications, and licensing. |
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Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting consumer preferences, characteristics, behaviors, attitudes, abilities, and aptitudes. |
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Protected Classifications. We may collect some information that is considered a protected classification under California or federal law, which may include your gender, age, date of birth, citizenship, marital status, disability status, gender identity or expression, and medical condition. |
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Sources of Personal Information
We generally collect personal information from the following categories of sources: directly or indirectly from you; affiliates and subsidiaries; vendors and service providers; our advisors, third-party websites and services; public databases; Internet service providers; operating systems and platforms; and marketing and data analytics providers.
Sales and Sharing of Personal Information.
The CCPA defines “sale” as disclosing or making available personal information to a third party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, Internet and network activity information, and commercial information. We may disclose these categories to third-party advertising networks and analytics providers for purposes of marketing and advertising and to improve and measure our ad campaigns.
We do not sell or share any personal information or sensitive personal information about California residents who we know are under sixteen (16) years old.
Sensitive Personal Information.
Notwithstanding the above, we do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary and proportionate (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you.
Retention of Personal Information
We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection and as otherwise necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. Rather than delete your data, we may deidentify the data so that the data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device. Where we use and/or disclose deidentified data, we will maintain and use the information in deidentified form and not attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.
California Residents’ Privacy Rights.
Under the CCPA, California residents have the following rights (subject to certain limitations) with respect to their personal information collected by us:
Submitting CCPA Requests.
Request to Delete, Correct or Know/Access.
If you are a California resident and would like to make a verifiable request to delete, correct or know/access the personal information we have collected about you, please submit your request in writing to privacy.officer@rennie.com.
We will take steps to verify your request, which may include (i) sending you an email confirmation link to your registered email address, which you must click to confirm your request; and (ii) matching the information provided by you with the information we have in our records. In your request, please provide us with your name, email address and contact information and other information relevant to your request. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
Authorized agents may initiate a request on behalf of another individual by emailing privacy.officer@rennie.com. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Please note that if you wish to remove photos or a listing for a property that you own from our database of listings, you must contact the selling agent of the property directly.
Requests to Opt Out of “Sales” / “Sharing”
If you are a California resident and would like to opt out of the “sales” and/or “sharing” of your personal information, you may opt out of all but essential cookies using our cookie preference manager here. You may also click on the “do not share or sell my personal information” link at the bottom of our website.
In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Website or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well. More information about GPC is available at: https://globalprivacycontrol.org/.
California “Shine the Light” Law
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. You may request and obtain from us once a year, free of charge, certain information about the personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to privacy.officer@rennie.com.
The following only applies to residents of Canada.
Your Consent
We will process your personal information only with your knowledge and consent, except where exempted, authorized or required by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express, with clear options to say “yes” or “no” (such as by being asked to check a box to indicate your consent), or implied ( such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request). Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.
You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal, contractual or other restrictions and reasonable notice, by opting out of the use of your personal information by contacting our Privacy Officer (see Section 11 below). However, if you withdraw or change your consent, we may not be able to provide you with the Services.
Aside from consent, we may also process your personal information under other legal bases, as permitted by applicable laws.
Your Privacy Rights
Accessing Your Personal Information
You have a right to access your personal information that we hold.
Upon your written request, we will provide you your personal information in our possession or under our control. We will also provide your information about the ways in which that information is being used and a description of the individuals or organization to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
We may need to request specific information from you to help us confirm you identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who does not have a right to receive it.
Access may be declined where authorized or required by applicable law. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
Correcting Your Personal Information
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.
If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
If a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information in our possession or under our control with a note that the correction was requested but not made.
CASL Policy
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe mechanism, you may contact using the contact information provided in Section 11 of this Policy.