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Introduction
All Points provides a variety of products and services to the public, including but not limited to: Relocation Management Services including Move Management, Home Marketing Assistance, Relocation Expense Management, Destination Services, and other relocation-related services. We understand and respect the importance of our customer’s privacy. We are committed to processing personal information in ways that comply with global and local legal and regulatory obligations (“Applicable Data Protection Laws”) and being clear with customers about what we do with personal information.
This Policy describes the personal information we collect, how we use the information, with whom we share it, how you can exercise your rights on your personal data and the choices you can make about our use of the information. We also describe the measures we take to protect the security of personal information. In some cases, and where applicable, we may ask you to sign a separate document (“Data Protection Letter”) to indicate your explicit consent to our processing of your personal information. You have the right to contact us to review the personal information we collect or ask about our privacy policy.
The following sections comprise All Points’ Privacy Policy:
Personal Information All Points Collects
As part of providing products and services, All Points may collect only the personal information required, with the customer’s consent.
“Personal Information” means information that identifies an individual. This may include, without limitation, the individual’s name, home address, age, income, credit history, other financial information, credit card information, personal preferences, marital status, medical information, sexual orientation, racial or ethnic origin, religious beliefs, other information about his or her family, passport information and immigration status. This information assists us as part of your relocation preferences (i.e., your preferred choice of religious schools or proximity to certain places of worship). Personal Information does not include the name, title, business address, or telephone number of an employee of an organization.
Digital Assets are included in the definition of personal information. This includes, but are not exclusive of photography, logos, illustrations, animations, electronic mail that are stored on digital devices such as personal computers, tablets, and phones.
All Points gathers and uses personal information in order to provide you with the products and services you have requested, namely: information that is required 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 of our corporate clients’ employees and their families for social insurance, health programs, driver’s licensing, education, as well as other programs; and to otherwise provide professional and competent relocation
assistance to clients and to ensure that you are satisfied with the products and services we have provided. All Points may also use your personal information to send you an evaluation questionnaire about our services, so that we may continue to improve our services.
You are not required to supply any of the information that we may request, notably personal information, although this might limit the Services we are able to offer you.
We work closely with third parties (for example, your employer, business partners and sub-contractors) and may receive personal information about you from them.
All Points’ Website
We, our service providers, and other business partners collect certain information by using automated means, such as cookies, when you interact with our websites. This information may include your IP address, browser type, operating system, the full URLs, referring URLs and information on actions taken or interaction with our digital devices.
A cookie is information that a web site stores on your digital device so that it can remember something about you for use later. “Cookies” are small text files that contain a unique identification number that allows our computers to identify your web browser (but not you) each time you visit one of our websites that uses cookies. The information helps All Points improve the functionality of the site and enhance the navigation and security of your session. Most major websites use this technology and most browsers are set up to accept them.
You may disable (not accept) cookies on your browser. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our site. For example, the All Points exclusive web-based service the “Destination Services Web Portal” requires cookies to recognize clients with valid access to the database. If your browser does not accept cookies, the site will not grant you access via the login and password. Disabling the use of cookies should not adversely affect your use of the website.
How All Points Uses Your Personal Information
At All Points, we use personal information for five (5) general purposes:
We will only use personal information for the purpose that we have discussed with you. If we want to use your personal information for a different purpose, we will notify you and ask for your consent.
Access to Personal Information
All Points is obligated to keep your personal information confidential, except under the following circumstances:
During daily operations, access to personal information is limited to those 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 Privacy Policy. Unauthorized use or disclosure of confidential client information by any All Points employee is prohibited and may result in disciplinary measures.
We engage and coordinate third party suppliers to provide you with certain services offered through All Points. Such suppliers are only given the information that is needed to provide the specific service for which we contact 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 the All Points’ Privacy Policy. We will only do this with your express consent and you may withdraw this consent at any time.
We may transfer your personally identifiable information to a third party in connection with a sale, merger, or other disposition (whether of assets, stock, or otherwise) of our business.
Applicable Data Protection Law gives you the right to access personal information held about you. Any request should be made in writing to the Data Privacy Officer at the address found at the end of this policy. As we must be able to identify the person making the request, and because a fee may be due, we request that you confirm any request made by contacting us by phone. When you call we will ask you some questions to ensure that the request is legitimate. We may reject requests where we are entitled to do so under Applicable Data Protection Laws. This may occur where the request is unreasonable, due to its repetitive or systematic nature, require disproportionate effort and/or risks the privacy or confidentiality of others.
Access to personal information is logged and reviewed on a regular basis. A review will be conducted every six (6) months to ensure that access to personal information is limited to those that require it.
Protection of Personal Information
The security, integrity and confidentiality of your personal information is very important to us. All Points has extensive controls in place to maintain the security of its information and information systems. Client and transferred 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. Physical access to areas where Personal Information is gathered, processed, or stored is limited to authorized employees. We encrypt data in transit. Please bear in mind that despite our best efforts to safe guard Your Data, no security measures are perfect or impenetrable.
When you telephone an All Points employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
Maintenance, Transfer, Storage, Retention of Personal Information
All Points will ensure that personal information is kept accurate and up to date where possible. It is your responsibility to inform us of any changes to your personal data. This ensures that the personal information we have is current. This can be done by writing, emailing, or calling, requesting that changes be made. If the request is made via email or writing, we may contact you via phone and ask some questions to verify that you made the request.
The security of your personal information is important to us. We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide, or we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. All information you provide to us is stored on our secure servers. We use secure connection encryption on a few our websites from which we transfer certain personal information.
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. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We store personal information only for as long as it is necessary to fulfil the purpose for which it was collected, unless otherwise required by Global or Local Laws or authorized by Applicable Data Protection Law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which it collected it.
Under Applicable Data Protection Law, you have rights regarding the personal information we maintain about you. We also offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you.
You can choose not to provide personal information to us. You also may refrain from submitting information directly to us. However, if you do not provide your data when requested, or if you exercise your rights you and/or your family may not be able to benefit from our services (as applicable).
To the extent provided by Applicable Data Protection Law, you may withdraw any consent you previously provided to us, or question at any time to the processing of personal information. In some circumstances, withdrawing your consent to our use or disclosure of personal information will mean that you cannot take advantage of certain Services.
You have the right to request the deletion, removal, or anonymization of personal data where there is no compelling reason for its continued processing. Individuals have a right to have personal data erased and to prevent further processing in the following circumstances:
We may refuse to comply with your request for erasure if we are required to comply with a legal or statutory obligation or if the personal information will be required for resolving a claim, complaint or in the defence of a claim or complaint.
A review will be conducted once a year to ensure that personal information is deleted when no longer required for the services being given.
Changes to our Privacy Policy
When changes are made to our Privacy Policy if appropriate, you will be notified by e-mail. It is recommended that you review this policy frequently.
How to contact us
If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like us to update information or preferences you provided to us, please contact our Data Protection Officer. You may reach the Data Protection Officer via e-mail at: dataprotection@allpointsrelocation.com
or write to:
Data Protection Officer
All Points Relocation Service Inc.
3250 Bloor Street W. Suite 440
Toronto Ontario, M8X 2Y9
Canada
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