Privacy Policy

1. Introduction

Chisholm Real Estate Team ("we," "us," "our", or the "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).

This policy is structured around the 10 Fair Information Principles set out in Schedule 1 of PIPEDA, which form the foundation of Canadian private-sector privacy law.

2. Accountability

Chisholm Real Estate Team is responsible for personal information under its control. We have designated a Privacy Officer who is accountable for our compliance with PIPEDA and this Privacy Policy.

• Our Privacy Officer oversees all personal information handling practices and responds to privacy inquiries and complaints
• We maintain internal policies and procedures to protect personal information, including staff training on privacy obligations
• When we transfer personal information to third-party service providers for processing, we use contractual agreements to ensure an equivalent level of protection
• Our accountability extends to all personal information in our possession or custody, including information transferred to third parties

3. Identifying Purposes

We identify the purposes for which personal information is collected at or before the time of collection. We use your information for the following purposes:

• To create and manage your account
• To provide personalized property recommendations and market intelligence
• To send alerts for new listings matching your saved search criteria
• To process transactions and send related communications
• To improve our website, services, and user experience
• To conduct aggregated market research and analytics
• To comply with legal obligations including MLS® data governance requirements
• To contact you regarding account updates and service changes
• To prevent fraud and enhance platform security
• To facilitate communication between you and real estate professionals

If we identify a new purpose for your personal information, we will update this policy and, where required, obtain your consent before using the information for the new purpose.

4. Consent

Under PIPEDA, we are required to obtain your meaningful consent before collecting, using, or disclosing your personal information. We rely on different forms of consent depending on the sensitivity of the information and the reasonable expectations of the individual:

• Express consent: For sensitive information (e.g., financial data, detailed property preferences linked to your identity), we obtain your explicit, affirmative consent
• Implied consent: For less sensitive information necessary to provide our services (e.g., using your email to send account notifications), consent is implied through your use of the service
• Opt-out consent: For marketing communications, we provide clear opt-out mechanisms in every message, in compliance with CASL

You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer or through our Consent Preferences page. We will inform you of the implications of withdrawing consent, which may include an inability to provide certain services.

5. Limiting Collection

We limit the collection of personal information to what is necessary for the purposes we have identified. We collect information by fair and lawful means.

• We do not collect personal information indiscriminately or beyond what is required to deliver our services
• We do not use deceptive or misleading practices to collect information
• Optional fields in forms are clearly marked — you are not required to provide information beyond what is necessary for the specific service
• Automated data collection is tiered by how identifying it is: anonymous performance telemetry (such as page-load speed, tied to no identifier) is collected as a necessary operational purpose; usage analytics that record which pages and features you interact with — along with your general device type, browser, and operating system, grouped by a random per-visit session identifier — are collected only with your explicit opt-in consent; and marketing tracking likewise requires your explicit consent

6. Information We Collect

7. Limiting Use, Disclosure, and Retention

Personal information is used or disclosed only for the purposes for which it was collected, except with your consent or as required by law. We retain information only as long as necessary to fulfill those purposes.

Disclosure

We do not sell your personal information to third parties. We may share information with:

• Real Estate Professionals: Agents and brokers may contact you about properties you have viewed or inquired about
• Service Providers: Third parties who assist in operating our website and conducting business (e.g., payment processors, email providers, and our privacy-focused, cookieless analytics provider Plausible for aggregate site-traffic measurement), bound by contractual privacy obligations
• Legal Requirements: When required by law, court order, or government request
• Business Transfers: In the event of a merger, acquisition, or asset sale, with notice to affected individuals

Retention Periods

• Account data: Retained for the duration of your active account plus 30 days after deletion request
• Transaction records: Retained for 7 years as required by Canadian tax law
• Search history and preferences: Retained for 2 years of inactivity, then automatically purged
• Communication logs: Retained for 1 year after last interaction
• Property page chat transcripts: Retained indefinitely rather than for the communication-logs period above, as a record of what you were told about a property
• Sign-in records: Your name, email address, username, and when and how you signed in. The MLS board requires them to be kept for at least 180 days after each sign-in stops being valid, even if you delete your account. They are then deleted automatically.
• CASL consent records: Retained for 3 years after consent expiry or withdrawal, as recommended by CRTC enforcement guidance
• Usage / behavioural analytics (session-linked): Retained about 26 months, then automatically deleted or anonymized
• Anonymized / aggregate analytics data: Once stripped of any session identifier and reduced to aggregate counts, retained indefinitely for market analysis (not linked to any individual)

You may request deletion of your data at any time, subject to legal retention requirements. We will destroy, erase, or anonymize information that is no longer needed.

8. Accuracy

We take reasonable steps to ensure that personal information is accurate, complete, and up-to-date for the purposes for which it is used.

• You can review and update your personal information at any time through your account settings
• We do not routinely update all personal information — we ensure accuracy for information that is actively used to make decisions about you or provided to third parties
• If you notify us of inaccuracies, we will correct the information promptly and, where appropriate, notify third parties to whom the information was disclosed
• Property and market data sourced from MLS® databases is updated according to the data provider's schedule and may not reflect real-time changes

9. Safeguards

We protect personal information with security safeguards appropriate to the sensitivity of the information, including:

• Physical measures: Our infrastructure is hosted on SOC 2 Type II compliant cloud providers with physical access controls
• Technological measures: SSL/TLS encryption for data in transit, AES-256 encryption for sensitive data at rest, secure password hashing, and automated vulnerability scanning
• Organizational measures: Access to personal information is restricted on a need-to-know basis, staff are trained on privacy obligations, and we conduct regular security audits

While we strive to protect your information, no system is completely secure. We cannot guarantee absolute security of your data.

10. Openness

We make information about our privacy policies and practices readily available. This includes:

• This Privacy Policy, published on our website and accessible from every page via the footer
• A description of the types of personal information we hold and the general purposes for which it is used
• Contact information for our Privacy Officer to whom inquiries and complaints can be directed
• Information about how to exercise your individual access and correction rights
• Descriptions of any information made available to related organizations (e.g., service providers, real estate boards)

If you have questions about our privacy practices that are not addressed in this policy, contact our Privacy Officer and we will respond within 30 days.

11. Individual Access

Under PIPEDA, you have the right to:

• Access: Request access to personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Restriction: Request that we limit how your data is processed
• Withdrawal: Withdraw consent for use of your information

12. Challenging Compliance

You have the right to challenge Chisholm Real Estate Team's compliance with PIPEDA by contacting our Privacy Officer. We take all complaints seriously and have established the following process:

13. Breach Notification

In accordance with PIPEDA, if a breach of security safeguards involving your personal information creates a real risk of significant harm, we will:

• Notify you as soon as feasible after discovering the breach
• Report the breach to the Office of the Privacy Commissioner of Canada
• Notify any other organization or government institution that may be able to reduce the risk of harm
• Maintain records of all breaches for a minimum of 24 months

14. CASL Compliance

Chisholm Real Estate Team complies with Canada's Anti-Spam Legislation (CASL) for all commercial electronic messages (CEMs). This means:

• We obtain express or implied consent before sending commercial messages
• All commercial messages include our identity, contact information, and a functional unsubscribe mechanism
• Unsubscribe requests are processed within 10 business days as required by CASL
• We maintain records of consent (type, date, purpose, method) for audit and compliance purposes
• Implied consent expires after 2 years of inactivity (or 6 months for inquiry-based consent), as defined by CASL

You can unsubscribe from commercial messages at any time via the unsubscribe link in any email, or by emailing unsubscribe@chisholmteam.ca.

15. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience, remember preferences, and analyze site usage. Types of cookies we use include:

• Essential cookies: Required for site functionality (authentication, security) — these cannot be disabled
• Preference cookies: Remember your settings and preferences
• Analytics cookies: Help us understand how you use the site (requires your consent)
• Marketing cookies: Used to deliver relevant content (requires your express consent)

You can control cookie settings through our consent banner on first visit or through your Consent Preferences. Disabling non-essential cookies will not affect core functionality.

16. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any information.

17. Children's Privacy

Chisholm Real Estate Team is not intended for children under the age of 13. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 13, we will take steps to delete such information promptly.

18. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact our Privacy Officer:

You may also file a complaint with the Office of the Privacy Commissioner of Canada.

19. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be effective when posted to the website. We will notify registered users of material changes via email at least 30 days before the changes take effect. Your continued use of Chisholm Real Estate Team following the effective date of changes constitutes your acceptance of the updated policy. Previous versions of this policy are available upon request.