Privacy Policy

PRIVACY POLICY

Red Door Realty Ltd., Brokerage

Effective Date: December 2025

Red Door Realty Ltd., Brokerage (“we,” “us,” “our,” or “the Brokerage”) is committed to protecting the privacy, confidentiality, and security of all personal information that we collect while providing real estate services in Ontario.
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Trust in Real Estate Services Act (TRESA), RECO guidance, and applicable FINTRAC AML/ATF regulations.

This Privacy Policy explains, in detail, how we collect, use, disclose, safeguard, and retain personal information.

1. Scope & Application

This Policy applies to:

• Clients
• Customers
• Website visitors
• Individuals completing forms, surveys, or email subscriptions
• Vendors and cooperating brokerages
• Past, current, and prospective clients

This policy applies to information gathered through:

• Real estate transactions
• MLS® systems
• In-person or virtual meetings
• Phone, email, text, or website forms
• Open houses
• Newsletters and marketing campaigns
• FINTRAC verification
• Any third-party systems we use to deliver real estate services

2. What Personal Information We Collect

We collect only the information necessary for brokerage operations and compliance with federal and provincial law.

2.1 Identification Information

• Full legal name
• Home/mailing address
• Email address
• Phone numbers
• Date of birth (FINTRAC)
• Occupation (FINTRAC)
• Government-issued identification details (FINTRAC, anti-fraud)

2.2 Real Estate Transaction Information

• Property details and MLS® data
• Listing contracts, buyer representation agreements
• Offers, agreements of purchase and sale
• Mortgage status (if shared)
• Tenant/landlord information for leases
• Home inspection, appraisal, or contractor reports (when provided)

2.3 Regulatory Compliance Information

Collected solely for legal obligation:

• FINTRAC identity verification records
• Source of funds declarations
• Suspicious/large transaction information
• Receipt of funds records
• Compliance documentation
• Data required to meet RECO audit expectations

2.4 Financial Information

(Only when required for a transaction)

• Banking details
• Deposit information
• Lawyer trust account confirmation
• Proof of funds (if voluntarily submitted)

2.5 Website & Digital Information

• IP address
• Browser type
• Cookie and tracking data
• Form submissions
• Time spent on website pages
• Lead activity from Facebook, Google, Mailchimp, CRM, etc.

2.6 Marketing Consent Information

• Newsletter opt-in records
• Unsubscribe requests
• Preferences for email, SMS, or social communication

3. How We Use Personal Information

We use personal information for lawful purposes, such as:

3.1 Real Estate Services

• Listing properties for sale or lease
• Assisting buyers in acquiring properties
• Drafting and negotiating agreements
• Providing market analyses and pricing
• Coordinating showings, inspections, appraisals
• Communicating with cooperating brokerages and boards

3.2 Legal & Regulatory Requirements

• Identity verification (FINTRAC)
• Record-keeping obligations (RECO & federal law)
• Regulatory audits or investigations

3.3 Client Communication

• Responding to inquiries
• Providing updates, reminders, or follow-ups
• Sending property alerts or market reports

3.4 Marketing (with consent)

• Newsletters
• Market updates
• Promotions for brokerage services
• Client appreciation events
• Social media communication

3.5 Website Experience

• Improving website functionality
• Analyzing visitor activity
• Optimizing lead generation

4. Disclosure of Personal Information

Your information is shared only when required and only on a need-to-know basis.

We may share information with:

4.1 Real Estate Participants

• Realtors and brokerages involved in a transaction
• Real estate boards (MLS® systems)
• Lawyers, appraisers, inspectors, lenders

4.2 Service Providers to the Brokerage

(e.g., for operational or marketing purposes)

• CRM platforms (e.g., Follow Up Boss, kvCORE)
• Email marketing suppliers (e.g., Mailchimp)
• Photography/videography companies
• Cloud storage and document signing systems (e.g., DocuSign)
• Website hosting providers
• IT and software management vendors

4.3 Government, Regulators & Legal Authorities

Only when legally required:

• FINTRAC
• RECO
• Courts or law enforcement (with proper legal authority)

4.4 With Your Consent

• When you authorize us to share with a third party
• Referrals to other professionals

We never sell personal information.

5. Consent

Consent may be:

• Express (written, verbal, email opt-in)
• Implied (e.g., providing information to complete a transaction)

You may withdraw consent at any time unless:

• Required by law
• Necessary to complete an ongoing real estate transaction

6. How We Protect Personal Information

We maintain strict security safeguards, including:

6.1 Physical Safeguards

• Locked filing cabinets
• Restricted-access brokerage offices
• Secure document disposal (shredding)

6.2 Electronic Safeguards

• Firewalls and anti-malware tools
• Limited administrative access rights

6.3 Administrative Safeguards

• Staff confidentiality agreements
• FINTRAC & privacy compliance training
• Policies governing mobile devices and remote work
• Annual policy reviews

7. Retention & Destruction of Information

We retain records only as long as required:

Real Estate Records: minimum 6 years (RECO/TRESA)

FINTRAC Records: 5 years

Business Records: per CRA rules

Marketing Data: until consent is withdrawn

After retention periods expire, information is:

• Securely destroyed
• Permanently deleted
• Anonymized where appropriate

8. Access to Personal Information

You may request:

• Access to your personal information
• Corrections to inaccurate data
• Information about how your data has been used
• A copy of our retention and security procedures

We respond within 30 days as required by PIPEDA.

9. Cookies, Website Tracking & Online Data

Our website may use:

• Cookies
• Pixel tags (including Facebook Pixel)
• Google Analytics
• Lead capture tools
• Location-based analytics

These tools collect anonymous data unless you voluntarily submit personal information through a form.

You may disable cookies in your browser settings.

10. Third-Party Links

Our website or communications may contain links to:

• Mortgage brokers
• Lawyers
• Inspectors
• Other real estate resources

We are not responsible for the privacy practices of external websites.

11. Children’s Privacy

We do not knowingly collect information from individuals under 16 without parental consent.

12. Data Breach Procedure

In the event of a data breach:

1. We take immediate steps to secure systems.
2. We assess the scope and impact.
3. We notify affected individuals as required by law.
4. We report to the appropriate authorities when necessary.
5. We implement corrective measures.
6. Contact: Privacy Officer

To request access, correction, or raise a privacy concern:

Privacy Officer
Red Door Realty Ltd., Brokerage
4010 Brigham Rd., RR33,

London, ON.
reddoorrealtylondon@gmail.com

We respond to all privacy inquiries promptly and in accordance with PIPEDA.

14. Updates to This Policy

We may revise this Privacy Policy periodically. The latest version will always be available upon request or posted on our website.