S&P Real Estate^® Group Privacy Policy

Your privacy is important to S&P Real Estate Corp. and its corporate subsidiaries, affiliates and partners, including World Housing CCC Inc. (collectively “S&P Real Estate Group” and each an “S&P Real Estate Company”). This Privacy Policy explains how each S&P Real Estate Company collects, uses, discloses and retains personal information, including information collected through websites and correspondence and when providing services.

2. Your Consent

By providing an S&P Real Estate Company with your personal information, you consent to the collection, use, disclosure and retention of that information by the S&P Real Estate Company and other members of the S&P Real Estate Group in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to the relevant S&P Real Estate Companies, but then you might not be able to proceed with your intended interactions or transactions with those S&P Real Estate Companies or otherwise receive the full benefit of their services.

3. Personal Information

“Personal information” is broadly defined and includes any information about an identifiable individual, as well as more technical information that is collected automatically. Information that is business contact information or aggregated or anonymized is not considered to be personal information.

In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

4. Information that S&P Real Estate Group Collects

S&P usually collects personal information directly from you, such as when you use a service provided by an S&P Real Estate Company. S&P may also collect personal information automatically, such as when you visit an S&P Real Estate Company’s website.

(a) Information You Provide

You may be asked to voluntarily give your personal information to an S&P Real Estate Company when you interact with the S&P Real Estate Company, including when you subscribe to a newsletter, request information or use a service provided by the S&P Real Estate Company. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with the S&P Real Estate Company or otherwise receive the full benefit of the desired service.

If you give an S&P Real Estate Company the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to the S&P Real Estate Company and to the S&P Real Estate Company’s use, disclosure and retention of the personal information.

(b) Automated Collection

An S&P Real Estate Company may automatically collect certain information regarding your use of the S&P Real Estate Company’s website, such as the dates and times that you use the website, the browsers, operating systems, software and devices that you use to access the website and details of your use of the website.

An S&P Real Estate Company’s website, email messages and advertisements may use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists the S&P Real Estate Company to improve its products, services, customer communications and advertising and to prevent fraud. An S&P Real Estate Company may use information collected through technological means to recognize you as a user of the S&P Real Estate Company’s website, to facilitate and improve your use of the S&P Real Estate Company’s website, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of a website. More information about cookies used for interest-based advertising is set out in section 5(c) below.

Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and each S&P Real Estate Company will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

(c) Information from Other SourceS

An S&P Real Estate Company may collect personal information from various publicly available sources.

5. How S&P Real Estate Group Uses Personal Information

S&P may use your personal information to provide relating to or arising from your relationship and transactions with an S&P Real Estate Company, for S&P’s own internal purposes and for additional purposes, subject to your right to withdraw consent as set out in this Privacy Policy.

(a) General

Each S&P Real Estate Company may use your personal information collected by the S&P Real Estate Company for purposes relating to or arising from your relationship and transactions with the S&P Real Estate Company and as otherwise set out in this Privacy Policy or permitted by applicable law, including: (i) to administer your relationship with the S&P Real Estate Company, including to contact and correspond with you regarding those matters; (ii) to facilitate your interactions and transactions with the S&P Real Estate Company; (iii) to provide services to you; (iv) to process and respond to your inquiries, requests and other communications; (v) to provide you with information (including by email and other electronic messages) regarding the S&P Real Estate Company and its business and services and services offered by other businesses, to the extent permitted by applicable law; (vi) to maintain, protect and improve the S&P Real Estate Company’s services and to develop new services; (vii) to protect and enforce the S&P Real Estate Company’s legal rights, interests and remedies and to protect the business, operations and customers of the S&P Real Estate Company or other persons; and (viii) to assist other S&P Real Estate Companies to collect, use, disclose and retain your personal information in accordance with this Privacy Policy.

Subject to your right to withdraw consent as described in this Privacy Policy, S&P may also use your personal information collected by S&P for the following additional purposes that are not required for S&P to provide you with services: (i) to administer and facilitate your participation in contests and promotions related to the S&P Real Estate Company; and (ii) to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional services that may be of interest to you.

Each S&P Real Estate Company may combine your personal information collected by the S&P Real Estate Company through various sources. S&P may use your personal information to create non-personal information, and S&P may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.

(b) S&P Real Estate Group

Each S&P Real Estate Company may share your personal information with the entire S&P Real Estate Group, and the S&P Real Estate Group may develop, maintain and share a confidential profile for you for use by each S&P Real Estate Company to provide information and services to you, to facilitate your dealings with each S&P Real Estate Company and as otherwise set out in this Privacy Policy.

(c) Interest-Based Advertising

The S&P Real Estate Group may use interest-based advertising services (sometimes called “remarketing” or “retargeting”) provided by third party vendors (such as Google, iovation and Facebook) to display advertisements on third party websites and social media sites visited by users of an S&P Real Estate Group website. Advertising vendors (such as Google, iovation and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses S&P Real Estate Group websites – to display ads based on the computer’s past access to S&P Real Estate Group websites. You can opt-out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page.

(d) Information Regarding Referred Transactions

If an S&P Real Estate Company refers you to an independent business (e.g. a sales partner) for a proposed transaction (e.g. a purchase of a property), then the S&P Real Estate Company may collect from that independent business information regarding the transaction for use by the S&P Real Estate Company to update your confidential profile for use by the S&P Real Estate Company as set out in this Privacy Policy.

6. How S&P Real Estate Group Discloses Personal Information

Each S&P Real Estate Company may disclose your personal information to its service providers, and to other persons in accordance with specific consents that you give to the S&P Real Estate Company. In some situations, an S&P Real Estate Company may also disclose your personal information to third parties as permitted or required by law (for example, in response to a court order or investigation).

(a) General

Each S&P Real Estate Company discloses your personal information for purposes relating to or arising from your relationship and transactions with the S&P Real Estate Company and as otherwise set out in this Privacy Policy or permitted by applicable law.

(b) Specific Consents

Each S&P Real Estate Company may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with the S&P Real Estate Company.

(c) Property Developers

If an S&P Real Estate Company collects your personal information in connection with a specific property development or if you otherwise consent to the use of your personal information in connection with a specific property development, then the S&P Real Estate Company may share your personal information with the developer of the property, and in those circumstances, the S&P Real Estate Company has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the property developer, and the use, disclosure and retention of the disclosed information by the property developer is not subject to this Privacy Policy.

(d) Referred Transactions

If an S&P Real Estate Company refers you to an independent business (e.g. a sales partner or property developer) for a proposed transaction (e.g. a purchase of a property), then the S&P Real Estate Company may disclose your personal information to the independent business to facilitate the proposed transaction, and in those circumstances, the S&P Real Estate Company has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the independent business, and the use, disclosure and retention of the disclosed information by the independent business is not subject to this Privacy Policy.

(e) Suppliers and Service Providers

Each S&P Real Estate Company may disclose your personal information to its suppliers and service providers to assist the S&P Real Estate Company in the provision of information and services to you, to provide services to the S&P Real Estate Company, to assist the S&P Real Estate Company to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.

(f) Law Enforcement/Legal Disclosures

Each S&P Real Estate Company may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. Each S&P Real Estate Company may disclose your personal information to law enforcement agencies or other independent organizations if the S&P Real Estate Company reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if the S&P Real Estate Company reasonably believes the disclosure is necessary or appropriate to protect and enforce the S&P Real Estate Company’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of the S&P Real Estate Company or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of the S&P Real Estate Company’s services). An S&P Real Estate Company has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom the S&P Real Estate Company discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.

(g) Business Transactions

Each S&P Real Estate Company may disclose your personal information in connection with a proposed or actual business transaction in which the S&P Real Estate Company is involved (e.g. a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of the S&P Real Estate Company’s business or assets), but the S&P Real Estate Company will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

7. Your Right to Withdraw Consent

When you interact with an S&P Real Estate Company, through its website, in person or by other means, you consent to the collection, use, disclosure and retention of your personal information as set out in this Privacy Policy.

You have a right to withdraw your consent at any time. However, if you withdraw your consent to purposes that are integral to the provision of a service by an S&P Real Estate Company, the S&P Real Estate Company may have to limit the services it is able to provide to you. Other purposes, such as advertising purposes, are not integral to the provision of services by an S&P Real Estate Company and your withdrawal of consent to those purposes will not impact the provision of services by the S&P Real Estate Company to you.

As described in section 2 of this Privacy Policy, in general, when you interact with an S&P Real Estate Company, you consent to the collection, use, disclosure and retention of personal information as set out in this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawing your consent for integral purposes. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to the relevant S&P Real Estate Companies, but then you might not be able to proceed with your intended interactions or transactions with those S&P Real Estate Companies or otherwise receive the full benefit of their services.

Withdrawing your consent for additional purposes. Withdrawing your consent for additional purposes that are not integral to the provision of an S&P Real Estate Company’s products and services will not impact the provision of those products and services to you. You may withdraw your consent to your personal information being used or shared for the following additional purposes:

To communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you. You can always limit the electronic communications that S&P sends to you. To opt-out of commercial emails, click the “unsubscribe” link at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, an S&P Real Estate Company may still need to contact you with important information about your transactions with that S&P Real Estate Company.
To administer and facilitate your participation in contests and promotions related to an S&P Real Estate Company.

To withdraw your consent, you may contact S&P’s Chief Privacy Officer by mail or email at: S&P Real Estate Group – Chief Privacy Officer, 2733 McKenzie Ave, Surrey, British Columbia, Canada V4A 3H2; email: privacy@sprec.com.

8. Location of Personal Information

Each S&P Real Estate Company and its service providers may process, store and use your personal information outside your province or territory or in other countries. As a result, your personal information may be subject to the laws of other jurisdictions.

Each S&P Real Estate Company and its service providers may process, store and use your personal information at facilities in various countries, including Canada, the United States of America and one or more countries in Europe or Asia. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to an S&P Real Estate Company, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

9. Retention of Personal Information

S&P only retains your personal information for the period reasonably necessary to fulfill the purpose for which it was collected, unless required or permitted by applicable law.

Each S&P Real Estate Company will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with the S&P Real Estate Company’s legal obligations or enforce or protect the S&P Real Estate Company’s legal rights, or a longer period required or permitted by applicable law. Each S&P Real Estate Company will delete or dispose of your personal information, or depersonalize the information, when the S&P Real Estate Company is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

10. Protection of Personal Information

S&P strives to protect your personal information against unauthorized access. S&P maintains administrative, technical and physical safeguards to protect your personal information.

Each S&P Real Estate Company uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in the S&P Real Estate Company’s possession or under the S&P Real Estate Company’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and the S&P Real Estate Companies cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy.

11. Accuracy and Access to Personal Information

You have the right to access your personal information and to have it corrected by contacting S&P as set out in section 19 below.

Each S&P Real Estate Company will rely on you to ensure that the personal information that you provide to the S&P Real Estate Company is as accurate, complete and up to date as necessary for the purposes for which the S&P Real Estate Company uses the personal information. You will promptly notify each S&P Real Estate Company of any changes to the personal information that you provide to the S&P Real Estate Company using the procedures made available for that purpose by the S&P Real Estate Company or by contacting the S&P Real Estate Group’s Chief Privacy Officer using the contact information noted below.

You may reasonably request access to your personal information collected an S&P Real Estate Company and information about the S&P Real Estate Company’s use, disclosure and retention of that personal information by submitting a written request to the S&P Real Estate Group’s Chief Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have the information revised as appropriate. You may be required to pay a reasonable fee for access to your personal information. Each S&P Real Estate Company may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law.

12. Non-Personal Information

S&P may use non-personal information (information that is not about an identifiable individual) for any purpose, unless it is combined with personal information.

Each S&P Real Estate Company may use personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Each S&P Real Estate Company may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then each S&P Real Estate Company will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with your personal information.

13. Other Websites and Businesses

This Privacy Policy only addresses the collection, use, disclosure and retention of personal information by S&P. Other websites have their own privacy policies and practices.

Each S&P Real Estate Company’s website and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. An S&P Real Estate Company has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

14. Social Media and Similar Situations

This Privacy Policy only addresses the collection, use, disclosure and retention of personal information by S&P. Social media websites have their own privacy policies and practices and you are responsible for the personal information you post to those websites.

When you use certain aspects of S&P’s websites or other services to access or post information to social media websites (e.g. there may be links to S&P’s Facebook, Twitter, Instagram or LinkedIn pages), the personal information that you post or share in connection with these third party websites is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages to you. When you click on a link to a social media website, you will leave the S&P websites and go to that social media website. Any information provided to such third party social media websites and other websites is governed by their own privacy policies, which you may read on the applicable website. You are solely responsible for the personal information that you choose to post or share in those situations. S&P has no control over, or responsibility or liability for, the collection, use, disclosure and retention of the personal information that you disclose in those situations, and this Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites.

15. Children and Personal Information

S&P does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian.

S&P does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian. If an S&P Real Estate Company becomes aware that it has collected or received personal information from a child where parental confirmation was required, the S&P Real Estate Company will delete that information. If you believe an S&P Real Estate Company might have any information from or about a child where parental consent should have been obtained, please contact S&P’s Chief Privacy Officer using the contact information set out in section 19 below.

16. Disclaimers, Liability Exclusions/Limitations and Disputes

The other agreements you have with an S&P Real Estate Company may contain disclaimers, liability exclusions and limitations and dispute resolution provisions that apply to matters arising in relation to this Privacy Policy, to the extent permitted by applicable law.

The agreements (including any website terms of use) that you accept when you apply, register for, order or use an S&P Real Estate Company’s services contain important provisions, including provisions disclaiming, limiting or excluding the liability of the S&P Real Estate Company and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or the S&P Real Estate Company’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they were reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

17. Changes to this Policy

Generally, changes to this Privacy Policy will be posted to S&P’s websites. Please check the “Last Updated” date at the top of this Privacy Policy and review any changes since the last version.

Each S&P Real Estate Company may change this Privacy Policy as it applies to the S&P Real Estate Company from time to time by posting a new version of this Privacy Policy on the S&P Real Estate Company’s website. Each S&P Real Estate Company’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with an S&P Real Estate Company after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by the S&P Real Estate Company as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

18. Other Matters

(a) Notices to You: You consent to S&P sending you emails (to the email address you provide to S&P) regarding this Privacy Policy and related matters.

(b) English Language: You and each S&P Real Estate Company have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressément que cette Politique de Confidentialité et tous les documents qui s’y rapportent soient rédigés en anglais.

19. Contacting S&P Real Estate Group’s Chief Privacy Officer

If you have any comments or questions about this Privacy Policy or how an S&P Real Estate Company deals with your personal information, please contact S&P Real Estate Group’s Chief Privacy Officer by mail or email at: S&P Real Estate Group – Chief Privacy Officer, 2733 McKenzie Avenue, Surrey, British Columbia, Canada V4A 3H2; email: privacy@sprec.com.

Table of Contents

Introduction
Your Consent
Personal Information
Information that S&P Real Estate Group Collects
How S&P Real Estate Group Uses Personal Information
How S&P Real Estate Group Discloses Personal Information
Your Right to Withdraw Consent
Location of Personal Information
Retention of Personal Information
Protection of Personal Information
Accuracy and Access to Personal Information
Non-Personal Information
Other Websites and Businesses
Social Media and Similar Situations
Children and Personal Information
Disclaimers, Liability Exclusions/Limitations and Disputes
Changes to this Policy
Other Matters
Contacting S&P Real Estate Group’s Chief Privacy Officer

S&P Real Estate® Group Privacy Policy

Table of Contents

Key Terms of S&P’s Privacy Policy

1. Introduction

2. Your Consent

3. Personal Information

4. Information that S&P Real Estate Group Collects

(a) Information You Provide

(b) Automated Collection

(c) Information from Other SourceS

5. How S&P Real Estate Group Uses Personal Information

(a) General

(b) S&P Real Estate Group

(c) Interest-Based Advertising

(d) Information Regarding Referred Transactions

6. How S&P Real Estate Group Discloses Personal Information

(a) General

(b) Specific Consents

(c) Property Developers

(d) Referred Transactions

(e) Suppliers and Service Providers

(f) Law Enforcement/Legal Disclosures

(g) Business Transactions

7. Your Right to Withdraw Consent

8. Location of Personal Information

9. Retention of Personal Information

10. Protection of Personal Information

11. Accuracy and Access to Personal Information

12. Non-Personal Information

13. Other Websites and Businesses

14. Social Media and Similar Situations

15. Children and Personal Information

16. Disclaimers, Liability Exclusions/Limitations and Disputes

17. Changes to this Policy

18. Other Matters

19. Contacting S&P Real Estate Group’s Chief Privacy Officer

S&P Real Estate^® Group Privacy Policy