Milborne Real Estate Inc. (collectively, “Milborne”, “we” and “us”) respect an individual’s privacy and takes great care in protecting our customer’s personal information. As a leading Toronto pre-construction real estate broker, our clients rely on us to safeguard this information and ensure its responsible collection and use.

1. Policy Objectives

This policy relates to the customer personal information collected by Milborne as well as its website, mobile applications and banners.

In this policy, we describe what personal information we collect; how we use, share and manage it. Please also refer to any privacy statements available at our locations, websites or mobile applications available to you at the time your personal information is collected.

2. What personal information is collected and how?

Milborne limits the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. The personal information we collect falls into the following categories:

a. Information we collect directly from you

You may provide personal information to us in our sales centers, by mail, by email, over the telephone, through our websites or mobile applications or in any other direct manner. When you voluntarily share information about yourself with us, we will collect that information in order to provide you with our programs, products or services, respond to your inquiry, or for any other purpose disclosed to you at that time.

The information you give us may include, but not be limited to;

• Basic identifying information including your full name (first and last), alias, postal address, e-mail address, phone number, date of birth, account name, signature, or other similar identifiers.
• Demographic data including age, gender, marital status, parental status, and household information.
• Job Applicant Information

b. Information we collect from use of our services

When you visit our websites, use our mobile applications, open or click on emails we send you, we may collect certain information using online tracking technologies such as analytics software and third-party cookies.

c. Information we collect from other sources

We may receive personal information from other sources with your consent or if the law requires or permits us to do so.

The information we obtain from other sources may include, but not be limited to;

• Documentation required to meet FINTRAC compliance.
• Information required by other legal and regulatory obligations.

“Personal information” is any information that identifies you or could be reasonably associated with you. The personal information we collect may include contact information such as your name, email address, home address, and phone numbers, as well as information required to be collected as per government regulations, such as FINTRAC legislation; date of birth, social insurance number and personal identification number.

Failure or refusal to provide personal information required in order to provide our services may make you ineligible for our services, particularly in instances where we are required by law to collect such personal information (e.g. as required for FINTRAC compliance).

3. How do we use personal information?

We use your personal information to provide you with our programs, products and services, to manage our business operations, to communicate offers and information we think might interest you, to generally enhance your customer experience with us, and as permitted or required by law.

We use your personal information for the following purposes:

a. Providing Products and Services

We use your personal information in order to provide you with our products and services, which include:

• Providing you with a quote for a product or service;
• Determining your eligibility for product or service.

b. Communicating With You

We use your personal information to communicate with you in a variety of ways, including:

• Providing you with information and updates about our products and services
• Responding to your inquiries;
• Taking or verifying instructions from you;
• If we have your consent, informing you in a variety of ways (e.g., email, telephone, SMS, direct mail) about products, services or events that may be of interest to you;
• If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message.

c. Conducting Market Research

We may use your personal information in order to conduct market research by tracking and analyzing current or previously collected information to improve or to develop new products, services and to better understand our customer base. When doing so, we will generally use your information in an aggregated format or with direct personal identifiers removed.

d. Conducting Data Analytics

We may use your personal information in order to conduct data analytics for business purposes, such as:

• Managing and developing our business and operations (e.g. analyzing and improving our sales center operations);
• Understanding customer needs and preferences and customizing how we tailor and market products and services to our customers based on their interests and sentiments; and
• Measuring the effectiveness of our marketing.

4. How do we share personal information?

Milborne does not share personal information with third parties other than for reasons stated below.

a. As required to provide services

Information may be shared with relevant parties in regards to negotiating or completing any and all real estate transactions. Relevant parties include developer clients and their solicitors, and co-operating brokerages.

b. As required by law

Canadian law permits or requires the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect our group of companies, our employees, our customers, or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.

c. With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of Milborne, in accordance with applicable law.

5. How do we manage consent?

By subscribing to our products and services and/or submitting information to us in connection with using our products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” (e.g. your permission is assumed), based on your action or inaction at the point of collection, use or sharing of your personal information.

6. How do I change my privacy choices?

There are several options available for you to manage your privacy preferences, including, for example, contacting us directly, and/or where available using “unsubscribe” functionality.

If you wish to receive email or SMS marketing communications, you must opt-into receiving then, either at the time that you register for our products or services, or at a later date.

You may opt-out of receiving email or SMS marketing communications from the sender, by clicking “unsubscribe” within any marketing email you receive, texting “STOP” within any SMS marketing you receive. We are obliged by law to action your request within 10 days.

7. How do we protect and store personal information?

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. These measures include multi-factor authentication, masking, encryption, logging and monitoring, described below. We store your personal information for as long as it is necessary to provide you with our products, and services and for up to 7 years thereafter, or as permitted or required by law.

a. How We Protect Personal Information

To protect your personal information, we maintain administrative, technical, and physical safeguards in sales centers and information storage facilities. By having these safeguards, we aim to avoid the loss, misuse, unauthorized access, disclosure, or modification of your personal information that we hold. These safeguards also apply when we dispose of or destroy your personal information.

For example, where appropriate, we use the following safeguards:

• Anonymization, which is the process of altering your data so that it can no longer be used to identify you personally;
• Encryption, which is the process of obscuring your information in order to make it unreadable without the use of a code or a key; and
• Logging and monitoring, which is the process of tracking, recording and monitoring activity related to the access and/or use of your accounts or personal information.

b. Where We Keep Personal Information

We use all reasonable safeguards, including contractual requirements with our service providers, to protect your personal information wherever it is used or stored. In general, we store, access and use personal information in Canada. Some of our service providers store your personal information outside of Canada in the course of providing their services to us. When we engage a service provider that operates outside of Canada, personal information may be stored in another country. In that case, the personal information is subject to the law of the jurisdiction in which it is used or stored, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. The countries where our service providers may be located include the United States.   

c. How Long We Keep Personal Information

We will store your personal information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law (e.g., real estate brokerages are required to keep all documents and records related to a trade for at least six years after a transaction has been completed). Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

8. How do I request access to my personal information?

Under Canadian privacy law, you have the right to access the personal information we hold about you, subject to any legal restrictions. Upon request, we will provide you with access to your personal information within 30 days, and at a maximum, 60 days if allowed by law.

It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your personal information or need to update it, please let us know through the steps outlined below.

For personal information you can request access by contacting Director of Operations, at ha.chu@milborne.com or 385 Madison Ave., Toronto ON M4V 2W7.

9. How do I know if there are changes to the privacy policy?

This Privacy Policy was last updated on the date noted at the top of this form and may be updated from time to time in the future. If we make material changes, we will post the updated Privacy Policy on this page and change the date at the top of this webpage. You may also request an updated copy of the Privacy Policy at any time by contacting the Director of Operations, at ha.chu@milborne.com.

10. Who do I contact with privacy questions or complaints?

We welcome your questions, comments and concerns about privacy and how we handle your personal information. You can contact our Director of Operations through email at ha.chu@milborne.com

In the event we are unable to satisfy your concerns you may also contact the Office of the Privacy Commissioner of Canada:

Toll-free: 1-800-282-1376
Office of the Privacy Commissioner of Canada
30 Victoria St., Gatineau QC K1A 1H3