All Points Relocation Privacy Policy

Introduction

All Points Relocation Services Inc. (All Points, we, us, our) provides a variety of products and services, including but not limited to: Relocation Management Services including Move Management, Home Marketing Assistance, Relocation Expense Management, Destination Services, and other relocation-related services (collectively, the “Services”). We understand and respect the importance of our customers’ privacy and are committed to processing personal information in ways that meet privacy principles and requirements with respect to personal information under applicable privacy legislation. This Privacy Policy (the Policy) applies to Services provided by All Points through our website https://www.allpointsrelocation.com, through our websites optimized for mobile services, and for any platform we may use to provide our services, including the Connect and APro platforms (collectively, the Sites).

This Privacy Policy should be read in conjunction with our Terms of Use. All capitalized terms not defined in the Policy are defined in our Terms of Use. Please read the Privacy Policy carefully to understand our policies and practices for collecting, processing and storing your personal information. By using the Sites, you agree to be bound by the terms and conditions of this Privacy Policy and consent to the practices described herein.

For the purposes of the Policy, “personal information” refers to information which relates, directly or indirectly, to an identifiable individual. Personal Information does not include the name, title, business address, or telephone number of an employee of an organization. Any personal information collected by All Points on the Sites is subject to this Policy.

The following sections comprise All Points’ Privacy Policy:

1. Object of the Policy
2. Personal Information All Points Collects
3. How All Points Uses Personal Information
4. Disclosure of your Personal Information
5. Protection of Personal Information
6. Cookies and other Tracking Technologies
7. Maintenance, Transfer, Storage, Retention of Personal Information
8. Changes to our Privacy Policy
9. Contact Us

Object of this Policy

Our main objective when we collect personal information about you is to offer you a secure, effective and personalized experience, provide you with services and functions that meet your needs and to personalize our service to make your experience more secure and friendlier. The information we collect about you is solely information we deem necessary to achieve this objective.

This Policy describes the information that we collect from you as part of our services and what may happen to that information. You may be required to provide certain personal information to access various sections of the Sites. You can still opt not to provide the requested information by simply not accessing the functions or services offered on our Sites.

This Policy applies to both corporate clients of All Points using the Sites for their employee relocation needs (a Client), as well as to individual employees using the Sites to manage and update their relocation efforts and actions (an Employee), and to any Services we may provide to you.

Personal Information All Points Collects

As part of providing products and services, All Points may request that you provide certain personal information. Unless permitted or required by law or regulation or with your consent , we only collect personal information that is necessary to provide you with our different services. Where possible, we indicate which fields are required and which fields are optional.

Option 1: general use of the Site

• When you subscribe to our newsletter, we will collect your name and email address.
• When you visit our Sites, we may collect information about your visit through cookies and similar
  technologies (see our section on Cookies and other tracking technologies for more information).
• When you register on the Sites as a Client, you will be required to provide a valid email address.

By completing the “Contact Us” form on the Sites, you allow us to contact you using the information provided only for the purpose of responding to your comment or question. The information you provide when filling out the contact form will be stored to allow us to analyze and respond to your request.

We may collect other information about you, including information you communicated to us during dispute settlements or in correspondence you sent us and in which you exchange information through our Sites.

Option 2: Connect/APro platforms

• When you register on the Sites as an Employee, you must provide us with certain information to enable All Points to assist you with your relocation efforts:
  • Your full name, marital status, email address, phone number, language preference (between Canadian official languages), current employer (our Client) and other employment information which may include employee number, grade, position title, salary, type of assignment and job start date;
  • In addition, depending on the services the Client has authorized us to provide to you, we will also need additional information to assist you, which may include the following:
    • Relocation Management Services: home address at origin, home address at destination, number of family members and their age, any special needs, financial information including banking, current mortgage information and/or line of credit number(s), mortgage/line of credit balance(s) and current home lease details, lease agreement or sale price and/or appraised values and building inspection results where applicable.
    • Destination Services: nationality, origin country and city, number of family members and their age, gender and date of birth, any special needs, immigration status (regarding yourself and your family members), driver’s license information, children’s and/or spouse’s education records, medical information if it relates to special needs, lease or purchase details regarding destination residence.
    • Immigration Services: place of birth, permanent residence(s), number of family members and their age, gender, date of birth citizenship(s) and permanent residence(s), previous relationship history (as applicable, special needs and information about your employment relationship with the Client, employment history, curriculum vitae, , education certificates, passport number, work permit information, immigration status (regarding yourself and your family members), language test results, copies of your passport, COVID-19 vaccination proof, police certificates, medical examination results and medical history, digital photographs, criminal records and any records of previous military service.
  • This information will be used by All Points for various purposes aimed at facilitating your relocation, for example to effectively market and sell the property of sellers or lessors; to locate, assess, and qualify properties for buyers and renters; to assist with registration for social insurance, health programs, driver’s licensing, education, as well as other programs; and to otherwise provide professional and competent relocation assistance and to ensure that you are satisfied with the products and services we have provided. Note that the information required from you may also vary depending on the extent of Services your employer, our Client, is providing you with;
• When you visit our Sites, we may collect information about your visit through cookies and similar technologies (see our section on Cookies and other tracking technologies for more information).
• When you register on the Sites as a Client, you will be required to provide a valid email address.

By completing the “Contact Us” form on the Sites, you allow us to contact you using the information provided only for the purpose of responding to your comment or question. The information you provide when filling out the contact form will be stored to allow us to analyze and respond to your request.

We may collect other information about you, including information you communicated to us during dispute settlements or in correspondence you sent us and in which you exchange information through our Sites.

How All Points Uses Your Personal Information

At All Points, we generally use personal information for the following purposes:

1. Provide you with products or services that have been authorized by your employer, or which you
   may request from us or selected third parties on a retail basis;
2. Provide you with information or updates regarding the services;
3. Enable us to carry out the services by including it in documentation relating to your relocation
   needs;
4. Instruct third parties (sub –contractors for example) to assist us in the provision of the services;
5. Check and verify your identity when you use our services;
6. To provide the Client with updates on our relocation efforts, at their request and/or according to the terms of any agreement entered into between us and the Client.

We will only use personal information for the purposes that we have discussed with you or as provided for in the law. If we want to use your personal information for a different purpose, we will notify you and ask for your consent, unless otherwise authorized by applicable law.

Disclosure of your Personal Information

All Points will only disclose your personal information with your consent or if it has legal authority to do so, such as in the following contexts:

1. When authorized by you: Many of the services offered by All Points require us to obtain personal information about you to perform the services we have been engaged to provide. We will always obtain consent first, and we will never use personal information for purposes other than those we have told you about.
2. When required to provide our services to you. We engage and coordinate third party suppliers to provide you with certain services offered through All Points, such as temporary accommodation providers, real estate agents, home movers, and immigration consultants, etc. Such suppliers are only given the information that is needed to provide the specific service which we ask them to provide. Suppliers are obliged to protect the confidentiality of your personal information and are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with this Policy. We will only do this with your express consent and you may withdraw this consent at any time, although it may impact the quality of the Services we provide you.
3. We may share our data, including personal information about you, with our affiliated companies, potential partners and third-party service providers that perform services on our behalf such as data hosting, tech development, payment processing, marketing, and processing, to the extent it is necessary for them to complete their function. To the extent that these entities may have access to your information, they are contractually bound to keep personal information confidential and use it only for the purposes for which we disclose it to them. Our affiliated companies, potential partners and third-party service providers shall follow privacy practices no less protective of all users than our practices described in the Policy. We may share your personal information with our contracted service providers that participate in our commercial activities.
4. We may share your personal information with your employer, our Client. In this case, we will only provide the Client with the necessary personal information they need to ensure the Services are being provided in accordance with their requirements, and shall not disclose any information they are not required to obtain from us, such as social insurance number family information, etc. Furthermore, Clients understand that any information provided in this way can only be used for the purpose of assessing and monitoring the status of the Services provided and the Employee’s relocation endeavours, and shall not be used for any other purpose, including for disciplinary measures. Please note that it is your responsibility to ensure not to share with us any personal information which you do not wish to be shared with our Client. While we do not systematically disclose all of your personal information to our Client, if reasonably justified or requested by the Client, any personal information you have provided to us can be disclosed to such Client.
5. We may be asked to disclose your personal information to meet certain legal, regulatory, insurance, and audit requirements, enforce our Terms of Use, respond to claims to the effect that some content breaches the law or the rights of a third person, including intellectual property rights or ensure everyone’s safety and security, and as otherwise with your consent, or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to us or our service providers). In particular, without the need for a subpoena, we are entitled to disclose your personal information, including your family name, first name, postal code, email address, telephone number (if available), your browsing history of our Sites, your IP address, and any other information that might seem relevant, in response to a formal request from a regulatory body in connection with a criminal investigation or allegedly illegal activities or
   any other activity that might expose All Points to legal liability.
6. We may use and disclose personal information in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of All Points, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of All Points, or our business or assets, may use and disclose your personal information for similar purposes as those described in this Policy.

In addition, we can disclose your personal information if we have your consent, or as permitted by applicable privacy laws. If your personal information must be disclosed outside your jurisdiction of residence, we will do so in accordance with applicable laws, and ensure our external partners do the same. In such circumstances, governments, courts, law enforcement, or regulatory agencies of that jurisdiction may be able to obtain access to your personal information through the laws of the foreign jurisdiction. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation. By using the Sites, you consent to such disclosure of your personal information outside your jurisdiction of residence.

Protection of Personal Information

The security of your personal information is important to us. We maintain reasonable administrative, technical, and physical safeguards, that are appropriate with regards to the nature and sensitivity of the information, to protect your personal information against accidental, unlawful, or unauthorized destruction,
loss, alteration, access, disclosure, or use. All information you provide to us is stored on our secure servers. Client and Employee files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and data
processing procedures.

Access to servers containing personal information, as well as physical access to areas where personal information is gathered, processed, or stored is limited to authorized employees with a legitimate reason for accessing it. As a condition of their employment, All Points’ employees are required to follow all
applicable global and local laws and regulations, including this Policy. Unauthorized use or disclosure of confidential client information by any All Points employee is prohibited and may result in disciplinary measures.

Please note that the safety and security of your information is also your responsibility. Your password is an essential tool to ensure the protection of your account granting you access to the Sites. We advise you to create your password with a unique string of numbers, letters and unique special characters and not
give it to anyone. If you give your password or your personal information to other people, be advised that you will be held liable for everything done using your account identifiers. If you lose control of your password, you could also lose, to a large extent, the control of your personal information and will have to bear the consequences of legally binding actions taken in your name. If the security or use of your password is compromised, for any reason whatsoever, you must notify us immediately and create a new password.

All Points Relocation uses secure encryption technologies to protect personal information collected through its website. Personal data is encrypted during transmission and stored securely to help prevent unauthorized access, disclosure, alteration, or destruction. The transmission of information via the internet is not completely secure. Although we will do our best to protect personal information, we cannot guarantee the security of personal information transmitted to our websites or other digital devices that are in the public domain; any
transmission is at your own risk, and we cannot be held liable for any loss, corruption or unauthorized disclosure of information that would be beyond our reasonable control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.