Last Revised: August 5, 2020
RIFO has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.
Information RIFO collects
a. Personal Information
Personal Information that RIFO collects includes, but is not limited to:
- Registration information, such as name, e-mail address, address, date of birth, usernames, passwords, phone numbers, mailing address, profession and job title;
- Billing and payment information, including credit card information and bank account details;
- Any other Personal Information that You may provide when You use the Services, or when you contact RIFO with questions and/or inquiries;
- Technical support records;
- Service requests and inquiries; and
- Any information that RIFO collects from You that is intended to improve and personalize RIFO’s Services.
b. Non-Personal Information
RIFO collects non-specific Personal Information (“NPI”) about Users when they interact with the Services. For instance, NPI may include, but is not limited to, device information, IP address, geo-location information, browser name, type of computer or device, and technical information about a User’s means of connecting to the Services, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does RIFO collect, use and share NPI?” for more information.
Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
How does RIFO use personal information?
RIFO collects Personal Information for the following usage purposes:
- To provide Services to You and other Users;
- To facilitate transactions between You, other Users and RIFO;
- To establish and maintain responsible commercial relations with You;
- To communicate with You in order to provide the Service;
- To permit RIFO’s third party payment provider(s) to provide payment services;
- To respond to any correspondence You may direct to RIFO;
- To understand RIFO’s Users’ needs and preferences;
- To enforce RIFO’s Terms of Service;
- To provide You with Service or administrative messages;
- To meet legal and regulatory requirements;
- To prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
- To improve the Services; and
- For any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
How does RIFO collect, use and share NPI?
RIFO uses NPI in an ongoing effort to better understand and serve the Users of RIFO’s Services, including to provide the Services and to improve the content and functionality of the Services.
For instance, RIFO uses NPI to monitor traffic and to collect statistical data.
Specific Uses of NPI by RIFO:
- To monitor traffic, provide the Services, and conduct internal research on RIFO’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors.
Specific NPI Collected by RIFO:
- The Services may automatically receive and store certain types of information about Users’ use of the Services via web browser, including IP address, browser type, browser version, web pages viewed, date and time, time spent on Services, unique device identifier, , and other diagnostic information, as well as how users interact with RIFO.
- When you access the Services with a mobile device, the Services may collect information such as the type of mobile device you use, your mobile device unique identifies, the IP address of your mobile device, your mobile operating system, your mobile network, device phone number, the type of mobile Internet browser you use, and other diagnostic information.
- The Services also may access metadata and other information associated with other files stored on Your device. This may include, for example, audio and video clips, personal contacts, and address book information, and Your device’s camera application to assist with real estate listings.
Technology Used to Collect NPI:
- RIFO uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.
Collection and transmission of social account information
RIFO respects Your privacy and, unless otherwise required by law, RIFO will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing RIFO Personal Information to register for RIFO’s Services is implied consent to use such information to provide You the associated Services.
Where appropriate, RIFO will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when RIFO wants to use information for a purpose other than those identified above). In obtaining consent, RIFO will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by RIFO may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, RIFO shall take into account the sensitivity of the Personal Information and the reasonable expectations of RIFO’s Users. RIFO will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to RIFO in writing.
Limiting use, disclosure and retention
[When You sell or buy services via the Services, the Vendor or Agent (as applicable) may receive Your Personal Information for service provision purposes.]
In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, RIFO will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.
Subject to the foregoing, only RIFO’s and RIFO’s Affiliates’ employees and contractors with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about RIFO’s Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of RIFO’s Users’ Personal Information.
RIFO will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by RIFO.
RIFO will disclose Personal Information without Your knowledge or consent if RIFO receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If RIFO receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, RIFO’s policy is to provide the requested information.
Links to other services
Storage outside of Canada
Your Personal Information will not be used or stored by RIFO or RIFO’s service providers outside of Canada. RIFO requires that RIFO’s service providers safeguard Your Personal Information.
Children and minors
RIFO’s Services are not directed to children under the age of 18 years. RIFO will not knowingly collect Personal Information about a child under the age of 18. RIFO does not allow minors (persons who are under the age of majority in their place of residence) to make purchases.
How can I access my personal information?
Upon request, RIFO will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. RIFO will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, RIFO may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. RIFO will provide the reasons for denying access upon request.
RIFO protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. RIFO will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
RIFO’s methods of protection include:
- Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to RIFO's place of business in general and to internal offices as well;
- Organization measures, such as security clearances and limited access on a need to know basis; and
- Technological measures, such as the use of passwords, firewalls and encryption.
Inquiries; challenging compliance
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If RIFO finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact RIFO’s Privacy Office as follows:
7030 Woodbine Ave #900, Markham, ON L3R 6G2