1. Introduction
This website (the "Site") offers information, products, and services related to real estate (the "Services") provided by Warsan Real Estate Inc. ("Warsan", "we", "us", "our"). We operate this website and may use third-party contractors to support the delivery of the Services and the Site ("Service Providers").
This Privacy Policy and Terms of Use describes how we collect, use, and disclose your personal information in connection with your use of the Site, and the choices available to you. Our handling of personal information is governed by Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and its 10 fair information principles. This policy does not apply to websites, applications, or other online services that do not link to it.
2. Accountability and Our Privacy Officer
Warsan is responsible for personal information under its control, including personal information handled by our Service Providers on our behalf. We have appointed a Privacy Officer to oversee compliance with PIPEDA and this policy.
Privacy Officer, Warsan Real Estate Inc.
If you have questions about our use of your personal information, or wish to exercise any right described in this policy, please contact our Privacy Officer.
3. The 10 Fair Information Principles
PIPEDA's 10 fair information principles form the ground rules for how we handle your personal information: accountability; identifying purposes; consent; limiting collection; limiting use, disclosure, and retention; accuracy; safeguards; openness; individual access; and challenging compliance. This policy is published in keeping with the openness principle, so you can understand what we collect, why, and what we do with it.
4. Personal Information We Collect
We collect information from you in various ways when you access or use the Site or otherwise interact with the Services. This information may include:
Information you provide to us: contact information, such as your first and last name, email address, home address, and phone number; feedback or correspondence, such as information you provide when you contact us with questions, feedback, or other correspondence; marketing information, such as your preferences and/or consents for receiving communications about our activities, events, and publications, and details about how you engage with such communications; and other information which you may provide voluntarily or that is necessary in connection with your interactions with us through the Site or Services.
Information we obtain from third parties: social media information — we may maintain pages on social media platforms, such as Facebook, LinkedIn, and Instagram. When you visit or interact with these pages, the platform providers' privacy policies will apply to their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this policy. Data enrichment sources — we may obtain additional information about you from third-party data providers and publicly available sources, including property records, other public records, contact information, and professional or business information. We do not use enrichment data, and do not permit any third party to use enrichment data obtained through us, to make decisions about your eligibility for housing, credit, insurance, or employment. Other sources — we may obtain your personal information from other third parties, such as third-party analytics services, marketing partners, publicly available sources, and data providers.
CRM and communication data: if you communicate with us via email, text message, or other electronic means, or if we use customer relationship management ("CRM") tools to manage our interactions with you, we may collect and process email message content, headers, metadata, and attachments; text message content and metadata; communication timestamps, read receipts, and delivery status; contact information and communication history; and notes and records relating to our interactions with you. Our CRM services may synchronize with email accounts to facilitate communication management. When email synchronization is enabled, information from emails exchanged with you may be processed and stored, including email content, sender and recipient information, timestamps, and attachments. This data is used to provide better service, maintain accurate records, and facilitate follow-up communications.
Automatic data collection: we and our Service Providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications, and other online services, such as device data (including your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, province, or geographic area); and online activity data (such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them). We use cookies (text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser); local storage technologies (like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data); and web beacons (also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked).
Chat and messaging features: if the Site offers live chat, an automated chat assistant, or a similar messaging feature, your conversations may be recorded, stored, and processed by us and by the Service Providers who operate that feature on our behalf. Please do not submit sensitive personal information through a chat feature.
5. Purposes: How We Use Your Personal Information
We identify the purposes for collecting your personal information before or at the time of collection, and we use it only for those purposes, unless you consent otherwise or the use is permitted or required by law. We may use your personal information:
To provide and operate our Services and our Site: to provide, operate, and improve our Services and Site; communicate with you about our Services and business, including by sending announcements, updates, security alerts, and support and administrative messages; and provide support and respond to requests, questions, and feedback.
To manage our relationship with you: we use CRM tools and services to maintain records of our communications, track your preferences and interests, and provide personalized service. This may include analyzing your interactions with us to better understand your needs and preferences.
To send you follow-up and marketing communications: if you have consented to receive them, we (or our Service Providers) may from time to time send you follow-up or marketing communications as permitted by law, including through phone, email, and SMS text messages, some of which may use artificial or prerecorded voices. You may withdraw your consent as set out in Sections 6 and 17 below.
To comply with law: as we or our Service Providers believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety: to protect our, your, or others' rights, privacy, safety, or property (including by making and defending legal claims); enforce the terms and conditions that govern our Services; and protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
To create anonymous data: we may create anonymous data from your personal information and other individuals whose personal information we collect, by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services, conduct research, and promote our business.
6. Consent
We collect, use, and disclose your personal information with your meaningful consent, except where PIPEDA permits or requires otherwise (for example, to comply with a legal obligation). Consent may be express (for example, ticking a consent box or subscribing) or implied where the circumstances reasonably indicate it. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer or using the unsubscribe options described in this policy. Withdrawing consent for marketing communications does not affect our ability to contact you about an ongoing transaction or to meet legal obligations.
7. Limiting Collection, Use, Disclosure, and Retention
We limit collection to what is necessary for the purposes we have identified, and we collect it by fair and lawful means. We use and disclose your personal information only for the purposes for which it was collected, unless you consent otherwise or it is required by law. We keep personal information only as long as necessary to serve those purposes, including to satisfy legal, accounting, or reporting requirements.
Contact information and communication records are generally retained for the duration of our relationship with you and for a reasonable period thereafter to allow for follow-up and to comply with legal requirements; CRM data is retained for as long as you maintain an active relationship with us, unless longer retention is required by law; transaction records are retained as required by the Real Estate Council of Ontario (RECO), which requires brokerage records to be kept for at least six years; and marketing preferences are retained until you update them or withdraw consent. When personal information is no longer necessary, we securely delete or anonymize it. In some cases, we may retain certain information in anonymized or aggregated form for analytical purposes.
8. How We Share Your Personal Information
We do not sell your personal information. We may share it as described below and elsewhere in this policy:
Internal team, partners, and affiliates: our employees and contractors, partners, and affiliates, including to facilitate your interactions with us.
Our Service Providers: companies and individuals that provide services on our behalf or to help us provide the Services, the Site, or our business (such as hosting, information technology, CRM services, email delivery, text message and other messaging delivery, AI and machine learning services, advertising, and website analytics services). Our Service Providers handle personal information only on our instructions and under contracts requiring them to protect it. We remain responsible for it.
Professional advisors: we may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us or our Service Providers.
For compliance, fraud prevention, and safety: we or our Service Providers may share your personal information for the compliance, fraud prevention, and safety purposes described above.
Business transfers: we (or our Service Providers) may sell, transfer, or otherwise share some or all of our (or our Service Providers') business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this policy.
Other than as set forth herein, data will not be shared with third parties for marketing or promotional purposes. We will never disclose any personal information such as phone numbers and SMS consent to any third parties for marketing purposes, and we do not include telephone numbers in any list uploaded to an advertising platform.
9. Service Providers Outside Canada
Some of our Service Providers may process or store your personal information outside Canada, including in the United States. Where that happens, we use contractual and other measures to require a comparable level of protection, and we remain accountable for it. Personal information handled outside Canada may be subject to the laws of that country.
10. Use of Artificial Intelligence
We use artificial intelligence ("AI") and machine learning technologies to provide and improve our Services. This section describes how AI is used in connection with the Site and Services.
AI-generated content: we may use AI technologies to generate, assist with, or enhance content displayed on the Site or provided through our Services, including property descriptions and listing information; blog posts, articles, and other written content; social media posts and marketing materials; email communications and newsletters; and advertising copy and promotional content. AI-generated content is created using large language models and other machine learning systems. While we review AI-generated content for accuracy and appropriateness, such content may contain errors, omissions, or inaccuracies. You should not rely solely on AI-generated content for important decisions, including real estate transactions, without independent verification.
AI-assisted communications: we may use AI to assist with communications, including drafting and suggesting responses to inquiries, analyzing communication patterns to improve service, providing automated responses to common questions, and prioritizing and categorizing incoming communications. When AI assists with communications, a human may review and approve messages before they are sent, though some automated responses may be sent without individual human review.
AI-based analysis and recommendations: we may use AI to analyze data and provide recommendations, including identifying potential opportunities based on your stated preferences and behavior, suggesting properties that may match your criteria, analyzing market trends and conditions, and optimizing the timing and content of communications. These analyses and recommendations are provided for informational purposes and should not be considered professional advice. Important decisions should be made in consultation with qualified professionals. We do not use AI to make, and AI does not make, any decision that produces a legal or similarly significant effect concerning you.
Your choices regarding AI: you may ask us whether AI was used to generate specific content provided to you, ask that a person review any significant determination made with AI assistance, and provide feedback on AI-generated content or recommendations. To exercise these rights or ask questions about our use of AI, please contact our Privacy Officer.
11. Advertising and Tracking Technologies
We may use advertising and tracking technologies to deliver relevant advertising and measure the effectiveness of our marketing efforts.
Third-party advertising platforms: we may share certain information with third-party advertising platforms, including Meta (Facebook/Instagram), Google, and other advertising networks, to deliver targeted advertisements to you based on your interests and interactions with our Site; measure the effectiveness of our advertising campaigns; create audiences of similar users for advertising purposes ("lookalike audiences"); and track conversions and attribute advertising performance. When you interact with our Site, third-party advertising platforms may collect information through cookies, pixels, and similar technologies. This information may include your device identifiers, browsing behavior, and interactions with our advertisements.
Tracking pixels and conversion events: we use tracking pixels (also known as web beacons or clear GIFs) on our Site to track when you view or interact with our content, measure the effectiveness of our email campaigns, attribute conversions to specific advertising campaigns, and analyze user behavior on our Site. These tracking technologies may transmit information to third-party platforms, including information about the pages you visit, actions you take on our Site, and information about your device.
Interest-based advertising: we participate in interest-based advertising, which means that you may see our advertisements on third-party websites and platforms based on your browsing behavior and inferred interests. Third-party advertising platforms use cookies and similar technologies to collect information about your online activities across different websites and services to provide you with more relevant advertisements.
Your choices: you can limit tracking by blocking cookies in your browser (most browsers let you remove or reject cookies, including cookies used for interest-based advertising; for more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org); blocking advertising ID use in your mobile settings; and using privacy plug-ins or browsers (such as Brave, Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin). The following advertising partners offer opt-out features for interest-based advertising: Google (https://adssettings.google.com/) and Facebook (http://www.facebook.com/about/ads). You can also use the Digital Advertising Alliance (http://optout.aboutads.info/) and Network Advertising Initiative (http://optout.networkadvertising.org/) opt-out tools. Note that these opt-out mechanisms are specific to the device or browser on which they are exercised, so you will need to opt out on every browser and device that you use.
12. Your Rights Under PIPEDA
You have the following rights, subject to the exceptions and limits in PIPEDA:
Access: upon written request, we will inform you whether we hold personal information about you, and give you access to it, including how it has been used and to whom it has been disclosed. We will respond no later than 30 days after receiving your request; if we need more time, we may extend the response by up to 30 additional days and will notify you within the original 30 days.
Correction: you may challenge the accuracy and completeness of your personal information and ask us to correct it as appropriate.
Withdrawal of consent: you may withdraw your consent as described in Section 6 above, subject to legal or contractual restrictions.
Challenging compliance: you may challenge our compliance with PIPEDA's fair information principles by contacting our Privacy Officer. We will investigate your concern and respond.
To exercise any of these rights, contact our Privacy Officer using the details in Section 2. We may ask for information to verify your identity before responding, and will use it only for that purpose. If we decline a request, we will explain why. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec K1A 1H3, telephone 1-800-282-1376, website www.priv.gc.ca.
How we handle requests to delete: when we grant a request to delete your personal information, we delete it from our systems and direct our Service Providers to do the same. We retain a record that you made the request, together with the limited identifying information needed to recognize you, so that we can continue to honor your request and demonstrate that we honored it. We do not use that record for any other purpose, and it is not used to contact you or to market to you. If you would prefer that we retain nothing at all, you may tell us so when you make your request, and we will remove that record as well. Copies that remain in backup or disaster-recovery systems are overwritten in the ordinary course of those systems' rotation.
13. Safeguards and Breach Response
We protect your personal information with safeguards appropriate to its sensitivity, including administrative, technical, and physical measures, to guard against loss, theft, and unauthorized access, disclosure, copying, use, or modification. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.
If a breach of security safeguards occurs involving personal information under our control, and it is reasonable to believe the breach creates a real risk of significant harm to an individual (including bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on a credit record, or damage to or loss of property), we will report the breach to the Office of the Privacy Commissioner of Canada and notify affected individuals as soon as feasible. We keep a record of every breach of security safeguards, regardless of whether it presents a real risk of significant harm, for at least 24 months.
14. Accuracy
We keep personal information as accurate, complete, and up-to-date as necessary for the purposes for which it is used. If your information changes, please tell us so we can update it.
15. Third-Party Links and Services
The Site and Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
16. Children
The Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child's parent or guardian as required by law, we will delete it.
17. Electronic Messages (Canada's Anti-Spam Legislation)
We send commercial electronic messages (including email and SMS) only with consent, as required by Canada's anti-spam legislation, and every message identifies Warsan Real Estate Inc. and provides a way to unsubscribe.
SMS text messaging: we use SMS text messaging to confirm appointments, send reminders, and notify clients of schedule updates or important changes. To opt out of receiving SMS communications, reply STOP to any SMS communication sent to you; after you send "STOP", we will send you a confirmation message and you will no longer receive SMS messages from us, unless you sign up again. If you are experiencing issues with the messaging program, you can reply with the keyword "HELP" for more assistance, or you can get help directly at info@warsanrealestate.ca. Carriers are not liable for delayed or undelivered messages. Message and data rates may apply for any messages sent to you from us and to us from you. Message frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
Email communications: you may unsubscribe from email updates sent by us at any time by following the unsubscribe link in the email.
18. Terms of Use
The content of this Site is provided for general information only and is not professional, legal, or financial advice. Property details, prices, availability, and completion dates may change and should be independently confirmed; please see the Website Disclaimer in this submission. You agree not to misuse the Site, interfere with its operation, or submit sensitive personal information through chat or contact features. Links to third-party sites are provided for convenience only and do not imply endorsement. We may update or change the Site and its content at any time without prior notice.
19. Changes to This Privacy Policy and Terms of Use
We reserve the right to modify this Privacy Policy and Terms of Use at any time. If we make material changes, we will notify you by updating the date of this policy and posting it on this website. Where required by law, we will provide additional notice or obtain your consent.
20. Contact Us
If you have any questions or concerns regarding this Privacy Policy and Terms of Use, please contact our Privacy Officer:
Privacy Officer, Warsan Real Estate Inc.
Warsan Real Estate Inc. • 320 Colton Circle, Kitchener, ON N2A 4K1 • 437.779.9980 • info@warsanrealestate.ca