We respect your privacy. This Policy informs you of our privacy practices, and of the options you have with regard to how your personal information is collected and used.
FirstService Residential Management, Inc. and its wholly owned subsidiaries (collectively, “Company”, “We”, “Us” or “Our”) self-certify the privacy policies described below in accordance with the U.S.-E.U. Safe Harbor principles, specifically, Notice, Choice, Onward Transfer, Access and Accuracy, Security, and Oversight/Enforcement.
More information about the U.S. Department of Commerce’s Safe Harbor Program can be found at http://www.export.gov/safeharbor .
I. Application of Policy.
II. Scope; Usage.
Collection of Personal Information
For the purposes of this Policy, “Personal Information” means any information that identifies, or could be used by or on behalf of FirstService to identify, an individual. Personal Information does not include information that is encoded, nor does it include publicly available information that has not been combined with non-public Personal Information.
In order to provide you with the highest level of service, we ask that you voluntarily provide us with certain Personal Information about yourself. Your Personal Information includes all information that we receive from you when you complete a registration application with or through the Website, including your first and last name, your current address, your telephone number, your drivers license number (or some other form of government-issued identification), your social security number, and certain employer / income information.
We may also collect certain information automatically through our Website, including: your browser type and operating system, your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area, unique identifiers, including mobile device identification numbers that can identify the physical location of such devices in accordance with applicable law, information collected through cookies, web beacons, and other technologies, and information about your interactions with other content available on FirstService’s Websites, such as the type of content viewed, and information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded.
Use of Your Personal Information
We use your Personal Information to provide you with services such as property tours, information about rental unit availability, and to help facilitate certain online financial transactions, such as the acceptance of online payments (collectively, “Services”). The Services may vary from time to time, and you will be notified of changes to the Services either by email or by postings at our website, www.fsresidential.com
Your Personal Information is disclosed to our affiliated partners (each, a “Partner”) in order to deliver the Services to you. Rest assured, however, that each Partner is required to keep your Personal Information confidential, and to the extent that the Partner receives or facilitates financial transactions, the Partner maintains all proper certifications as required by local, state or federal law, as well as all certifications required under Payment Card Industry (PCI) regulations, if relevant. When stored on our servers or on our Partners’ servers, your Personal Information is kept in an encrypted format.
On occasion, we may hire third parties to perform certain functions on our behalf. Examples include removing repetitive information from our customer lists, analyzing data, providing marketing assistance, and providing customer service. These third parties have access to your Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.
We may also disclose your Personal Information if we are required to do so by law or we in good faith believe that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of any FirstService Website; or (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
We may also use your Personal Information in the aggregate to determine our customers’ demographics and preferences. By doing so, we are able to deliver to you targeted events, such as relevant advertisements and information that you may find to be helpful and informative.
In addition, we may use your Personal Information to analyze the use of the FirstService Websites to understand and improve our service, customize content or for comparable purposes, including ensuring technical functioning of our network, developing new services or features.
Sharing of Your Personal Information
Where FirstService has knowledge that one of FirstService’s employees or agents is using or disclosing Personal Information in a manner contrary to this Policy, FirstService will take reasonable steps to prevent or stop the use or disclosure. FirstService holds its employees and agents accountable for maintaining the trust that our customers place in our company.
Also, in the event that all or substantially all of FirstService’s assets are acquired in a sale or assignment, or in connection with similar corporate transactions, your Personal Information may be one of the transferred assets. It is FirstService’s practice to seek appropriate protection for information in these types of transactions.
You will have the option to opt-out of any uses of Your Personal Information in which your Personal Information would be disclosed to a non-agent third party, or where such information would be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. FirstService will provide you with reasonable “opt out” mechanisms to exercise your choice before FirstService discloses any information as described in this paragraph.
Accuracy & Access
FirstService will take reasonable steps to ensure that you Personal Information is relevant accurate, complete and current, to its intended use. We provide individuals with reasonable access to personal information that they provided to us, as well as the ability to review and correct such information, as applicable.
To protect your privacy and security, we also take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your Personal Information. To view and change the Personal Information that you directly provided to us, you can return to the Web page where you originally submitted your data and follow the instructions on that Web page, or contact FirstService’s Privacy Officer as indicated below.
In addition, we may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to Personal Information.
Please note that we may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of Your Information may remain in back-up storage even if you ask us to delete it. In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you.
To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of your Personal Information, we utilize physical, technical and administrative procedures to safeguard the information we collect.
Among other things, we use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data, such as credit card information. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see the symbol of either an unbroken key or a closed lock (depending on your browser) at the bottom of your browser window.
We also use firewalls and restricted access methods to ensure the security of the information we collect. We limit access to your Personal Information and data to those persons in FirstService, or as agents of FirstService or Partners, that have a specific business purpose for maintaining and processing such information. FirstService’s employees who have been granted physical access to your Personal Information will be made aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.
Contact for Privacy Issues
FirstService’s designated contact for questions related to our website’s privacy is Bradley J. Gross, Esq., c/o Becker & Poliakoff, P.A., 3111 Stirling Road, Fort Lauderdale, Florida 33312,
If you have any questions or comments about this Policy, please direct them to the above- designated person.
III. Dispute Resolution
FirstService will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between FirstService and the complainant, we have agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that we or such authorities determine that we did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance.
Any person who we determine is in violation of our privacy policies will be subject to disciplinary process.
The practices described in this Policy are the current Personal Information protection policies as of August 1, 2010. FirstService reserves the right to modify or amend this Policy at any time consistent with the requirements of the Safe Harbor Principles. Appropriate notice will be given concerning such amendments.