Because it matters

Insider Privacy

INSIDER REALTY recognizes the importance of protecting the personal
information of our Customers, our prospective customers, brokers and
agents and anyone else from whom we may collect personal information
from time to time whether in the course of real estate transactions or
otherwise.
This Privacy Policy discloses the type of personal information we gather
from or about you (“You”), how we may use it, how and to whom we may
disclose it, your right to access your personal information which we have
collected and your right to correct or change that information where You
believe it may be inaccurate. At INSIDER REALTY we hope to give You as
much control about your personal information as possible.
INSIDER REALTY provides real estate broker services. Real estate broker
services are provided exclusively by INSIDER REALTY.
What We Mean By Personal Information?
Personal information is any information in whatever form about an
identifiable individual. However, it does not include:
1. your name or information which would enable us to contact You at your
place of employment including your name, position name or title, business
telephone number, business address, business email and business fax
number;
2. personal information about You that is publicly available information such
as information available from a public registry or contained in a telephone
book;
3. aggregated information that cannot be associated with You as a specific
individual; and
4. information which is not about a person but which is about a company,
association or another organization.
What Personal Information Does INSIDER REALTY Collect?
INSIDER REALTY collects the following personal information:

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1. personal information which You voluntarily provide to us when You visit
the INSIDER REALTY office or otherwise provided directly to an INSIDER
REALTY agent in person or by telephone, email, mail or fax;
2. photographic images of your property, descriptions of the property and
its sale price for marketing purposes, but only where we have obtained
your prior consent; and
3. personal information which You voluntarily provide to us when You visit
our website (the “Website”), such as when You open an account or
subscription or complete a contact request, and personal information
relating to your use of the Website (in accordance with our more detailed
Website Privacy Policy set out below).
Except where permitted by law, INSIDER REALTY collects, uses and
discloses your personal information with your knowledge and consent and
we will do so fairly and openly.
How We Use Your Personal Information
INSIDER REALTY uses personal information for the following purposes:
1. to put You in touch with a broker or sales person who may contact You to
assist You with listing property for sale or purchasing property;
2. to assist the broker or sales person in finding appropriate property for
You;
3. unless You choose to opt-out, INSIDER REALTY may use information
about your home in marketing material (we will not use your name), and
may use your contact information to promote and market additional
services, products and special offers from INSIDER REALTY; and
4. for the purposes relating to use of personal information collected on the
Website set out below in our Website Privacy Policy.
Why We Disclose Your Personal Information

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1. INSIDER REALTY may share personal information with third parties
engaged to assist us in providing services or products to You or to carry
out one or more of the purposes described above. These service
providers are prohibited from using personal information for any
purpose other than to provide this assistance and are required to
protect personal information disclosed to them by us and to comply with
the general privacy principles described in this Privacy Policy

2. INSIDER REALTY discloses personal information when it makes the
personal information a person has provided online available to its
brokers and sales people.
3. INSIDER REALTY may disclose personal information gathered on the
Website for the purposes set out below in our Website Privacy Policy.
INSIDER REALTY reserves the right to collect, use and disclose other
personal information without your knowledge or consent if we are required
to do so or if we are allowed to by law.
Consent
Except where required or permitted to do so without your consent,
INSIDER REALTY only collects your personal information with your
consent. In most cases, INSIDER REALTY relies on express consent.
However, where the purpose of the collection of personal information is
obvious on its face, INSIDER REALTY may rely on your implied or deemed
consent.
In some cases, such as using your personal information for marketing
services to You, INSIDER REALTY will rely on opt-out consent. (You will
receive the information unless You advise us You do not wish to receive it.)
INSIDER REALTY only collects personal information where it is reasonably
necessary to provide the service which You are seeking and which we have
agreed to provide. We do not use deceptive or misleading practices to
obtain your consent.
INSIDER REALTY does not require You to consent to the collection, use or
disclosure of personal information as a condition of the supply of a service
by us unless such collection, use or disclosure is required to fulfill the
aforementioned purposes of collection.

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INSIDER REALTY reserves the right to collect, use or disclose personal
information in certain limited circumstances, without your knowledge and
consent, where required or permitted by law.
You may withdraw your consent to the collection, use and disclosure of
personal information in connection with the services that You have
requested from us at any time, subject to legal or contractual restrictions
and reasonable notice. INSIDER REALTY will inform You of the
implications of withdrawing your consent. If You wish to withdraw your
consent at any time, please contact INSIDER REALTY’s Privacy Officer
(see below for contact information).
Access To Your Personal Information
You have the right to access your personal information in the possession or
control of INSIDER REALTY and to know how that personal information
has been and is being used, and to whom it has been disclosed. INSIDER
REALTY reserves the right to refuse to comply with all or part of a request
where we are required to or are permitted to refuse to do so by the
provisions of applicable personal information protection legislation.
Applications must be in writing and be sent to our Privacy Officer either by
mail or email at the addresses set out below. Applications should have
sufficient detail that allows us to identify You and the personal information
You are requesting.
You may ask to have errors or omissions in your personal information in our
possession or control corrected. If we are satisfied that the correction is
reasonably necessary, we will correct the personal information and notify
anyone to whom we have provided the personal information in the previous
12 months of the correction. If we are not satisfied that the correction
should be made, we will annotate the personal information under our
control of the correction requested but not made.
Requests for access and correction will usually be responded to within 30
calendar days of receiving the request unless we apply to the applicable
Privacy Commissioner for an extension. We charge $25 plus $.25 per page
for providing You with copies of your personal information. In the event that
it will take an unusually long time to collect your personal information, we
may charge an additional amount. In each case, we will give You a full
quote before photocopying the personal information. There is no charge for
correcting personal information.

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We will assist You with your request and will respond as accurately and
completely as reasonably possible. Where we refuse all or part of your
request, we will give You the reasons for the refusal and the applicable
legislation on which we base our refusal; the name and contact information
of someone within INSIDER REALTY who can explain the basis for the
refusal and of your right to apply to a Privacy Commissioner for review.
How We Protect Personal Information
INSIDER REALTY makes reasonable efforts to ensure that Your personal
information is protected against loss and unauthorized access, collection,
use, disclosure, copying, modifying, disposal or similar risks. This
protection applies in relation to personal information stored in both
electronic and hard copy form and will vary depending on the sensitivity of
the information.
Access to non-public personal information is restricted to selected
employees or representatives on a need-to-know basis. In addition,
INSIDER REALTY employs generally accepted information security
techniques, such as firewalls and access control procedures in order to
protect personal information against unauthorized access, collection, use,
disclosure, copying, modifying, disposal or similar risk.
Retention of Personal Information
INSIDER REALTY retains personal information for as long as necessary to
fulfill the purpose(s) for which it was collected and to comply with applicable
laws. Personal information which is collected and used to make a decision
about You is retained for at least one year. Your consent to such purpose(s)
remains valid after termination of INSIDER REALTY’s relationship with You.
Changes to this Privacy Policy
INSIDER REALTY reserves the right to modify this Privacy Policy at any

time without notice. The Privacy Policy distributed at any time or from-time-
to time posted on the Website shall be deemed to be the Privacy Policy

then in effect.
Accountability
INSIDER REALTY is responsible for the personal information under its
control, and we have designated a Privacy Officer who is responsible for
our compliance with this Privacy Policy and with applicable laws. Other

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individuals within INSIDER REALTY may be delegated to act on behalf of
the Privacy Officer and INSIDER REALTY will use appropriate means to
provide a comparable level of protection while information is being
processed by a third party. You may contact our Privacy Officer as follows:
INSIDER REALTY
Attention:Privacy Officer
Address: 2300 YONGE STREET #1600
TORONTO, Ontario M4P1E4
Phone:
416-549-5070
Email:
privacy@insiderr.ca
Dispute Resolution
If You are unhappy about the collection, use or disclosure of your personal
information by INSIDER REALTY, we ask that You discuss the matter
further with our Privacy Officer.
If You are not satisfied with the response, You may make an application or
complaint to the appropriate Privacy Commissioner.
Note to Agents
In order to promote the services of our Agents, INSIDER REALTY collects
certain personal information about them, such as photographs and contact
information, in a variety of ways, including through Online registration. This
information is disclosed by INSIDER REALTY when it makes the
information available for Customers to access on the Website or through
other means by which INSIDER REALTY promotes their services.
Much of this information is business contact information, which is not
subject to privacy law or this Privacy Policy. However, to the extent that
such information is personal in nature, INSIDER REALTY will collect, use
and disclosure this information in accordance with this Privacy Policy (see
above) and, where applicable, with our Website Privacy Policy.
INSIDER REALTY WEBSITE PRIVACY POLICY
The following addresses the personal information INSIDER REALTY may
collect about You during any interaction with our website (the “Website”).

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Your Acceptance of this Website Privacy Policy By using the Website, You
signify your agreement with and acceptance of INSIDER REALTY’s
WebsitePrivacyPolicy. If You do not accept this Website Privacy Policy,You
must not access or use the Website.
INSIDER REALTY may, at any time, without notice or liability, revise this
Website Privacy Policy by updating this posting. You should periodically
revisit this posting to review any revisions to thisWebsitePrivacyPolicy. If
any revision is not acceptable toYou, You must cease accessing and using
the Website. If You continue to access or use the Website after any
revisions are posted You will be deemed to have accepted those revisions.
Types of Personal Information
We receive two types of personal information from Customers who visit the
Website: (1) personal information that Customers provide through
registration or other communication on the Website; and (2) personal
information INSIDER REALTY gathers through aggregated tracking
procedures, such as tallying the number of page views throughout the
Website over a given period of time. The second type of personal
information enables us to tailor the Website content to better meet the
needs of our Customers. However, we assure You that INSIDER REALTY
will not disclose your personal information to third parties except as
permitted by applicable law.
INSIDER REALTY
Real estate broker services are provided exclusively by INSIDER REALTY.
Customers applying for services through the Website apply directly through
INSIDER REALTY. INSIDER REALTY has undertaken extensive measures
to control and ensure the privacy and security of personal information
obtained through the Website. Customers and prospective customers who
have concerns about the treatment of their personal information by an
Agent with which they are dealing are urged to contact that Agent directly.
How Does INSIDER REALTY Collect Personal Information?
(a) Registration: INSIDER REALTY does not collect your personal
information through the Website except when such personal information is
provided to us on a voluntary basis. For example, INSIDER REALTY will

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collect a user’s name, address, phone number and/or e-mail address and
any additional details that a user chooses to provide if he or she completes
the portion of the Website that requests that INSIDER REALTY contacts
the user or the user registers for an account or subscription on the Website.
If you choose not to provide your personal information, please note that
certain services associated with the Website may not be available to You
as they cannot be supplied without your personal information. The personal
information gathered through the Website is governed by the foregoing
Privacy Policy.
(b) Usage tracking:
(i) Use of IP Addresses: An IP address is a number that is automatically
assigned to your computer whenever You are surfing the Internet. Web
servers automatically identify your computer by its IP address.
INSIDER REALTY and/or its affiliates collect IP addresses for the purposes
of system administration, to report aggregated information to our
advertisers, and to audit the use of the Website. When Customers request
pages from the Website, our servers log the requesting Customers’ IP
addresses. Except where You participate in any online transaction
INSIDER REALTY may offer from time to time, we normally will not link IP
addresses to anything personally identifiable, which means that Customers’
sessions will be logged, but Customer identity remains anonymous to us.
We can and will use IP addresses to identify a Customer when we feel it is
necessary to enforce compliance with our rules or terms of service or to
protect our service, the Website, or any person, or where it is otherwise
permitted by law.
(ii) Use Of Cookies: Cookies are bits of information that a website transfers
to an individual’s hard drive for record-keeping purposes. Cookies make
Web surfing easier for You by saving your preferences while You visit the
Website. We never save passwords or credit card information in cookies.
The use of cookies is an industry standard, and, as such, You’ll encounter
them at most major websites.
By showing how and when Customers use the Website, cookies help us
see which areas are popular and which are not. Many improvements and
updates to the Website are based on data collected using cookies, such as
the total number of visitors and pages viewed in a given period of time. This
kind of information is most easily tracked using cookies.

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INSIDER REALTY and/or its affiliates have two primary uses for its cookies.
First, we use them to specify preferences. For example, Customers can
specify keywords across several categories or markets so You do not have
to tell us over and over again about the kinds of homes You are interested
in obtaining information about. Secondly, we use cookies to track Customer
trends and patterns. This helps us to better understand our Customers’
needs and to improve areas of INSIDER REALTY and/or its affiliates’
services that our Customers may find valuable. Sometimes, information
from cookies is attached to messages sent to our Customer Service
department. While all of these situations depend on the use of a cookie,
You always have the option of disabling the receipt of cookies on your
computer by adjusting the cookies setting in your Web browser
preferences.
Most browsers are initially set up to accept cookies. You can reset your
Web browser to either refuse all cookies or indicate when a cookie is being
sent, with a concurrent option to accept or receive the cookie. However,
note that some of the services offered on the Website will not function
properly or may be considerably slower if You refuse to receive cookies.
For example, without cookies, You will not be able to set personalized
preferences. You might also encounter difficulties participating in online
transactions offered on the Website from time to time.
Occasionally, You may receive cookies from our advertisers. INSIDER
REALTY and/or its affiliates do not control these cookies. The use of
advertising cookies sent by third-party servers is standard in the Internet
industry.
(iii) Other: INSIDER REALTY automatically collects anonymous statistical
information regarding usage of the Website. For instance, the Website will
recognize the type of browser you are using (Netscape, Internet Explorer,
Safari, etc.), the address of the Internet Service Provider You are using, the
site that linked You to the Website, the pages You visit at the Website and
similar information. None of this information identifies You personally.
With Whom Does INSIDER REALTY Share Your Personal Information?
As a general rule, INSIDER REALTY will not disclose any of your personal
information except when we have your permission or under special
circumstances, such as when we believe in good faith that the law requires
it or under other specified circumstances, including those described below:

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(a) Business Partners & Sponsors: INSIDER REALTY may disclose some
or all your personal information to business partners or sponsors, but this
use will be specifically described to You prior to either the collection or
transfer of the personal information. Many promotions offer opportunities to
request additional information from sponsors. By requesting more
information, You give INSIDER REALTY permission to transfer your
personal information to the sponsor so they can fulfill your request. In many
instances, only your e-mail address will be shared with the sponsor. If we

intend on sharing more personal information with the sponsor than your e-
mail, You will be notified prior to the transfer.

(b) Third Party Data and Data in the Aggregate: From time to time, on the
Website You may be offered the opportunity to receive material or special
offers from third parties. If You opt to receive information from these third
parties, INSIDER REALTY will (with your permission) share your name and
e-mail address with such third parties. Under confidentiality agreements,
INSIDER REALTY may match Customer information with third party data.
Also, INSIDER REALTY may disclose aggregated Customer statistics (i.e.,
where we disclose a characteristic of our Customers as a group and not as
individuals) in order to describe our services to prospective partners,
advertisers, and other third parties, and for other lawful purposes.
(c) Service Providers: Information INSIDER REALTY receives through the
Website is provided to services providers retained by CENTURY 2, in order
to organize and distribute appropriate personal information to enable
INSIDER REALTY and its Agents to communicate with its Customers and
to provide information about marketing initiatives that may be of interest to
its Customers.
(d) Other: INSIDER REALTY may disclose account information in special
cases when we have reason to believe that disclosing this information is
necessary to identify, contact or bring legal action against someone who
may be violating INSIDER REALTY’s Terms of Use or may be causing
(either intentionally or unintentionally) injury to or interference with
INSIDER REALTY’s rights or property, other INSIDER REALTY Customers,
or anyone else that could be harmed by such activities. INSIDER REALTY
may disclose or access account information when we believe in good faith
that the law requires it and for administrative and other purposes that we
deem necessary to maintain, service, and improve our products and
services. Note that to the extent that INSIDER REALTY retains a service
provider (including, for example, WhereToLive.com, Inc.), the personal

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information in that service provider’s control or possession is subject to the
laws of the jurisdiction in which it operates.
How Can You Control the Use of Your Personal Information?
In case You change your mind or some personal information changes (such
as your zip code or e-mail address), we will endeavour to provide a way to
correct, update or remove the personal information You give us.
Additionally, to keep You in control of the communications directed to You,
we offer Customers the opportunity to “opt out” of having personal
information shared with parties outside of INSIDER REALTY and/or its
affiliated companies. If You wish, for any reason, to update your personal
information or if You object to any use of your personal information
described in this Website Privacy Policy, You may contact INSIDER
REALTY’s Privacy Officer:
INSIDER REALTY Privacy Officer
2300 YONGE STREET #1600
TORONTO, Ontario M4P1E4
Phone: 416-549-5070
Email: privacy@insiderr.ca
What happens when You link to a Third Party Website?
You should be aware that when You are on the Website You could be
directed to other third party websites that are beyond our control. There
may,from time to time,be links to other third party websites from the
Website that take You outside our service areas. For example, if You
“click” on a banner advertisement on the Website, the “click” typically takes
You off the Website. These other sites may include websites of advertisers,
sponsors and partners that may use INSIDER REALTY’s and/or its
affiliates’ logos as part of a co-branding agreement. These other websites
may send their own cookies to Customers, or other wise collect data or
solicit information.
INSIDER REALTY and its affiliates do not control such third party websites,
and, therefore, are not responsible for their content. INSIDER REALTY’s
and/or its affiliates’ provision of hyperlinks to these websites does not imply
any endorsement of the material on such websites or any association with
their operators. This Website Privacy Policy does not extend to anything

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that is inherent in the operation of the Internet and which is beyond the
control of INSIDER REALT or its affiliates.
Please keep in mind that whenever You give out personal information
online (for example, via message boards or chat lines), that personal
information can be collected and used by people You do not know. While
INSIDER REALTY and its affiliates strive to protect their Customers’
personal information and privacy, we cannot guarantee the security of any
personal information You disclose online and so You disclose such
information at your own risk.
Is your Personal Information Secure from Others using the INSIDER
REALTY Website?
The importance of securing your personal information is of the utmost
concern to us. We exercise great care in providing secure transmission of
your information from your computer to our servers. Unfortunately, no data
transmission over the Internet can be guaranteed to be 100% secure. As a
result, while we strive to protect your personal information, INSIDER
REALTY and its affiliates cannot promise or warrant the security of any
personal information You transmit to us, including through the use of our
online products or services. Any such transmission is done so at your own
risk. Once we receive your transmission, INSIDER REALTY uses industry
standard efforts to safeguard the confidentiality of your personal
information, such as firewalls and Secure Socket Layers. However, ironclad
security does not yet exist on the Internet.