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FirstService Website Privacy Policy Canada

Last updated: May 17, 2024

Overview and Scope

FirstService Corporation (“FirstService“, “we“, “us” or “our“) is committed to safeguarding and handling the personal information that it collects, uses, discloses, and otherwise processes in a responsible and secure manner. This privacy policy (“Privacy Policy“) outlines how FirstService processes the personal information of the users of its websites located at www.firstservice.com, www.purpose.firstservice.com, and www.fsvbrands.com (“Websites“) and other individuals whom we may communicate with online (whereby such users and the other individuals are, collectively and individually, “you” or “your“).

This Privacy Policy does not apply to personal information about FirstService employees or contracted staff, which is dealt with separately. If you apply to FirstService for a job, FirstService will need to consider your personal information as part of its application review process. FirstService normally retains information from candidates after a decision has been made, unless you ask us not to retain such information. If FirstService offers you a job, which you accept, the information will be retained in accordance with our privacy policies and procedures relating to employee records.

We may modify this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. We will provide you with advanced notice by the email or telephone number which we have on file or through a notice on our Websites if we make any material changes to how we collect, use or disclose your personal information. If you continue to access or use our Websites after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.

Please refer to our Terms of Use, which can be found here.

Table of Contents

  • Accountability
  • Acceptance of Privacy Policy
  • Personal Information
  • Consent
  • Why FirstService Collects, Uses and Discloses Your Personal Information
  • How FirstService Collects, Uses and Discloses Your Personal Information
  • When FirstService Discloses Your Personal Information
  • Where FirstService Stores Your Personal Information
  • Security of Your Personal Information
  • Accessing Your Personal Information
  • Updating the Accuracy of Your Personal Information
  • Being Denied Access to Your Personal Information
  • Personal Information and Websites
  • Cookies
  • Traffic Patterns
  • Google Analytics
  • Google AdWords
  • Tracking Information
  • Link to Third Party Websites and Social Media Platforms
  • Collecting Personal Information of Children
  • Data Retention
  • Changes to Privacy Policy
  • Requests, Questions and Challenges Under Privacy Policy

Accountability

FirstService is responsible for the personal information in its custody or control. To ensure this accountability, FirstService has developed this Privacy Policy and has trained its employees or contracted staff in respect of it.

Acceptance of Privacy Policy

If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, do not provide your personal information to FirstService. Of course, certain services that we may provide can only be offered to you if you provide personal information to FirstService, and therefore FirstService may not be able to offer you those services if you choose not to provide it with required personal information.

Personal Information

“Personal information” is any information that is related to you, identifies you, or makes you identifiable. Generally speaking, personal information does not include “business contact information” such as the name, job title, business address, or business telephone number of an employee of an organization.

Consent

FirstService obtains your consent before it collects, uses, or discloses your personal information. Normally, FirstService asks for your consent in writing, but in some circumstances, it may rely on verbal or implied consent where permitted by law.

Subject to legal and contractual requirements and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting FirstService’s Data Privacy Manager (see end of this Privacy Policy for contact information). Please note, however, that by withdrawing your consent, you may not be able to fully access our services.

If you provide FirstService or its service providers with the personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable FirstService to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

There may be circumstances where you have provided personal information for an identified purpose, and FirstService later needs to use that information for a different purpose. In such circumstances, FirstService will seek your consent to use the information for the new purpose.

Why FirstService Collects, Uses and Discloses Your Personal Information

If you are applying for a job with FirstService, we will collect certain personal information from you for the purposes of evaluating your suitability for employment such as your first and last name, employment and educational history, and other personal background information as needed for the position you are applying for. This personal information may be collected directly from you by FirstService or via third-parties (e.g. for the purposes of conducting background checks).

FirstService may also ask for and collect your personal information at certain points throughout the Websites. In addition to the information you provide us with directly, FirstService collects the domain names and IP addresses of visitors to its Websites, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data is used to more efficiently operate FirstService’s business and administer the Websites. We also collect any information you may choose to provide in your communications with us.

When FirstService Discloses Your Personal Information

FirstService discloses your personal information only as described in this Privacy Policy, with your consent, or as otherwise permitted or required by law. Under certain circumstances and consistent with applicable laws, FirstService may disclose your personal information as follows:

  • Third-Party Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We may use third parties to perform certain services, such as:
    • To process and store data (e.g. computer backup services and archival file storage), including your personal information;
    • To track, analyze and modify our Services;
    • For marketing and advertising;
    • To conduct employee background checks; and
    • To support our IT and security efforts.

    Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We also employ appropriate measures to ensure that your personal information is safeguarded adequately and with a comparable level of protection. Our service providers are located in Canada, the U.S. and other foreign jurisdictions.

  • Merger, Bankruptcy or Corporate Reorganization: We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of FirstService, or in connection with a merger, consolidation, restructuring, the sale of all or substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change. We will notify you with any choices you may have regarding your personal information when we are engaged in a merger, bankruptcy, or corporate reorganization.
  • Legal Obligations and Safety: We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Where FirstService Stores Your Personal Information

Your personal information is stored in the Cloud and/or secured locations and/or on servers controlled by FirstService, located either at our offices in Ontario or at the offices of our service providers. Your personal information may be processed, accessed and/or stored in Canada or another foreign jurisdiction.

Security of Your Personal Information

FirstService has implemented reasonable physical, organizational and technological measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. These measures include:

  • Physical security on our premises, such as controlled entry to facilities and on-premise servers;
  • Administrative protocols such as robust internal password policies and restricted access by our personnel to files that contain personal information on a need-to-know basis; and
  • Technological safeguards such as the use of security software and firewalls.

You should be aware, however, that no system or method of transmitting or storing information is completely secure. While FirstService takes appropriate measures commensurate to the volume and sensitivity of personal information we collect to protect such information, there is always a risk that it may be lost, intercepted or misused.

FirstService also cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be secure.

Accessing Your Personal Information

Under Canadian privacy law, you have the right to request access to any personal information FirstService has in its custody or control, and to request updating and/or correction to same.

Subject to certain exceptions and restrictions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include, but are not limited to: information that is prohibitively costly to provide, information that contains the personal information of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

To request access your personal information, please contact us at 1-833-351-1339, or use the link here.

Updating the Accuracy of Your Personal Information

You can help FirstService maintain the accuracy of your personal information by notifying FirstService of any changes to your personal information at the contact information set out below. If FirstService holds information about you and you advise us that it is not accurate, complete and up-to-date, FirstService will take reasonable steps to correct it.

Being Denied Access to Your Personal Information

Your rights to access your personal information are not absolute. FirstService may deny access in a number of circumstances in accordance with applicable law, which include but are not limited to:

  • denial of access is required or authorized by law;
  • granting you access would have an unreasonable impact on another individual’s privacy;
  • for the purposes of protecting FirstService’s rights and property; and
  • in the context of frivolous or vexatious requests.

If FirstService denies your request for access to your personal information, or refuses a request to correct information, FirstService will explain why.

Personal Information and Websites

Cookies

The Websites and our third-party service providers may use “cookies”, a technology that installs information on a Websites user’s computer to permit the Websites to recognize future visits using that computer and to track information about your use of our Websites. Cookies are small text files that enhance the convenience and use of the Websites. We use them to determine Website traffic, information about your devices and internet connection, including your IP address, operation system and browser type, convey useful information about your interests, and to personalize any future visits you make to our Websites. We may maintain or associate this information with personal information we collect in other ways or receive from third parties. It helps us to improve our Websites and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Websites according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Websites.

The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically.

If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser’s cookie options, please refer to the instruction documentation of your particular browser or seek online assistance.

Like many other websites, the Websites may make use of “per session” and “persistent” cookie technology. Per session cookies track information during an open session and are stored only temporarily in your computer’s memory. Persistent cookies are deposited on a visitor’s computer until they expire or until the visitor deletes the cookies. Information from these cookies help FirstService analyze traffic patterns to the Websites, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that the Website’s visitors use. FirstService uses this information to facilitate and enhance your online visits.

Traffic Patterns

On the Websites, like most other commercial websites, FirstService may monitor traffic patterns, site usage and related site information. This is done in order to optimize its web service. FirstService may provide aggregated information to third parties, but these statistics do not include any personal information.

Google Analytics

We use Google Analytics to help us collect and analyze information, in an anonymous form, about how visitors use the Websites, including the number of visitors to the Websites, the pages they have visited, search terms used, and other engagement data. FirstService uses such information to compile reports and to help it evaluate and improve the user experience and convenience of our Websites. By using the Websites, you agree to such use of Google Analytics. For more information on Google’s privacy practices or should you wish to opt-out of the use of Google Analytics, please click on the following link: https://tools.google.com/dlpage/gaoptout.

Google AdWords

The Websites may also use third party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. This means FirstService may show ads to you across the Internet, specifically on the Google Display Network. FirstService does not collect personal information through the use of Google’s or any other third party remarketing system. Rather, the third party vendors will place cookies on web browsers in order to serve ads based on past visits to the Websites. This allows FirstService to continue to market its services to those who have shown interest in FirstService.

You may opt out of Google’s use of cookies by visiting Google’s Ads Settings. Also, you can opt out of other participating third party vendors’ use of remarketing cookies by visiting the Digital Advertising Alliance of Canada’s AdChoices Program opt-out tool page at: http://youradchoices.ca/choices/.

Tracking Information

In addition, FirstService may use non-personal information to create aggregate tracking information reports regarding Websites user demographics and Websites traffic patterns. None of the tracking information in the reports can be connected to the identities or other personal information of individual users. FirstService also may link tracking information with Websites users’ personal information. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Privacy Policy, and in accordance with the law.

Link to Third Party Websites and Social Media Platforms

The Websites may present links to other websites. We provide links to third party websites as a convenience to users and these links are not intended as an endorsement of, or referral to such linked websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. FirstService is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies and Terms of Use before providing them with your personal information.

Our Websites may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Websites.

Collecting Personal Information of Children

Our Websites and marketing activities are not directed to children under the age of 13, and we do not knowingly collect, maintain, or use personal information from children. If we become aware that we have collected the personal information of children, we will promptly take steps to delete such personal information. If you discover your child has provided us personal information without your consent, please contact us.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you and without your consent.

Changes to Privacy Policy

Privacy laws are rapidly evolving and as a result, FirstService reserves the right to change this Privacy Policy at any time. The most current version of this Privacy Policy is posted on the Websites. Regardless of any changes, FirstService makes to this Privacy Policy, FirstService will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information or as otherwise required or permitted by law unless you have given your express consent for FirstService to do otherwise.

Requests, Questions, and Challenges Under Privacy Policy

If you have any questions or comments about this Policy or the manner in which we or our service providers treat your personal information, you may contact us in writing by email or by mail at:

FirstService Corporation
1255 Bay Street
Suite 600
Toronto, Ontario
Canada, M5R 2A9

Attention: Data Privacy Manager privacymanager@firstservice.com

To request access to your personal information, please contact us at 1-833-351-1339 or use the link here.

If you are not satisfied with FirstService’s response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Place du Ville Tower, 3rd Floor
Ottawa, Ontario K1A 1H3

1.800.282.1376