Mullin Commercial Mortgages provides a variety of products and services to the public, including, but not limited to, real estate brokerage services, real estate agency services, advising with respect to real estate purchase and sale, home leasing, property management, real estate brokerage franchising services, and other real estate advisory services.
In the course of providing these products and services, we may collect certain personal information about its clients with their consent.
“Personal Information” means information about an identifiable individual. This may include, without limitation, the individual’s name, home address, age, income, credit history, or other financial information, credit card information, personal preferences, and other information about his or her family. Personal Information does not include the name, title, business address, or telephone number of an employee of an organization.
The ten principles of privacy
The following ten principles govern our actions as they relate to the use of Personal Information:
- Identifying purposes
- Limiting collection
- Limiting use, disclosure, and retention
- Safeguarding personal information
- Addressing complaints
Principle 1: Accountability
Mullin Commercial Mortgages is accountable for all Personal Information in its possession or custody, including Personal Information disclosed to third parties for purposes of providing services requested by you.
Principle 2: Identifying purposes
Mullin Commercial Mortgages will inform you of the purposes for which it is collecting any Personal Information, before or at the time the information is collected.
Principle 3: Consent
Mullin Commercial Mortgages will obtain your consent before or when it collects, uses, or discloses your Personal Information.
Consent can be express, implied, or given through an authorized representative. You may withdraw your consent at any time (subject to any legal consequences of which you will be informed). Mullin Commercial Mortgages, however, may collect, use, or disclose Personal Information without your knowledge or consent in exceptional circumstances where such collection, use, or disclosure is permitted or required by law.
Principle 4: Limiting collection
The information collected by Mullin Commercial Mortgages will be limited to those details necessary for the purposes it has identified to you or to perform the services you have requested. Information will be collected by fair and lawful means.
Principle 5: Limiting use, disclosure, and retention
Personal Information will only be used or disclosed for the purpose for which it was collected unless you have otherwise consented. Personal Information may only be retained for the amount of time needed to fulfill the purpose for which it was collected.
In certain exceptional circumstances, Mullin Commercial Mortgages may have a legal duty or right to disclose Personal Information without your knowledge or consent with respect to matters that concern the company’s or the public’s interest.
Principle 6: Accuracy
Mullin Commercial Mortgages will keep Personal Information as accurate, complete, and current as necessary to fulfill the identified purposes for which it was collected. You may have this information amended where it is found to be inaccurate or incomplete.
Principle 7: Safeguarding personal information
Personal Information is safeguarded using measures appropriate to the sensitivity of the information.
Principle 8: Openness
Mullin Commercial Mortgages will make information available to its clients and employees about the policies and procedures Mullin Commercial Mortgages uses to manage Personal Information. You have access to this information through our website, or through alternative means if requested.
Principle 9: Access
Upon written request, you will be informed of the existence, use, and disclosure of your Personal Information, and will be given access to it. Mullin Commercial Mortgages will respond to such requests as efficiently as possible. If Mullin Commercial Mortgages is prohibited from providing such access they will explain the reasons for the lack of access, except where prohibited by law.
Principle 10: Addressing complaints and suggestions
Application of the ten privacy principles – how we treat your personal information
The kind of information we collect
Mullin Commercial Mortgages gathers and uses Personal Information in order to provide you with the products and services you have requested, namely: information that is required to effectively market and sell the property of sellers or lessors; to locate, assess, and qualify properties for buyers; to evaluate independent broker applicants; and to otherwise provide professional and competent real estate services to clients as well as to ensure that you are satisfied with the products and services we have provided. Mullin Commercial Mortgages may also use your Personal Information to update you about our services and to offer you additional products or services that you may be interested in, so that we may continue to serve your real estate needs.
We may be required to collect your social insurance number if the federal government obligates us to do so pursuant to the Income Tax Act.
How we use your information
At Mullin Commercial Mortgages, we use Personal Information for three general purposes:
- To communicate with you in order to provide you with our products and services.
- For inclusion in documentation relating to your particular real estate transaction.
- Transactional information to monitor our level of service and report back to you to ensure your satisfaction with the provision of such services.
We will only use Personal Information for the purpose that we have disclosed to you. If we want to use your information for a different purpose, we will notify you and ask for your consent first.
When we are permitted to disclose your information
Mullin Commercial Mortgages is obliged to keep your Personal Information confidential except under the following circumstances:
(i) When authorized by you
Many of the services offered by Pemberton Holmes Ltd. require us to obtain Personal Information about you in order to perform the services you have engaged us to provide. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you about.
You may withdraw your consent at any time, subject to any legal implications (which we will inform you about). In some cases, if you do not consent to our use or disclosure of certain Personal Information, we may be unable to continue to provide all or part of the services you have requested.
(ii) When required by law
The type of information we are legally required to disclose usually relates to government tax reporting requirements. In some cases, however, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.
(iii) When permitted by law
The legislation has provided certain situations where Mullin Commercial Mortgages is legally permitted to disclose Personal Information without your consent. Examples include situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.
With whom we may share your information
(i) Mullin Commercial Mortgages employees
(ii) Mullin Commercial Mortgages’ affiliates
In order to better meet your needs, we may share some of your Personal Information with our affiliates. We will only do this with your express consent and you may withdraw this consent at any time. The procedure for withdrawing consent is outlined below under the section “Opting Out.”
(iii) MullinCommercial Mortgages’ third-party suppliers
(iv) Sale of business
We may transfer your personally identifiable information to a third party in connection with a sale, merger, or other disposition (whether of assets, stock, or otherwise) of our business.
How we safeguard information
Mullin Commercial Mortgages has extensive controls in place to maintain the security of its information and information systems. Client and independent broker files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and data processing procedures. Physical access to areas where Personal Information is gathered, processed, or stored is limited to authorized employees.
When you telephone a Mullin Commercial Mortgages employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
Accessing and amending your information
As a client or Mullin Commercial Mortgages broker, you have the right to access the Personal Information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the Personal Information held in your file, please make a written request to the Privacy Officer at the address listed below, under “Questions, Concerns, and Complaints”. We will respond to your request as efficiently as possible.
To make a change, please make a similar request in writing to the Privacy Officer.
In order to provide you with our services and products,Mullin Commercial Mortgages will, with your consent, share your personal information with other Mullin Commercial Mortgages’ affiliates. Should you not want to receive promotional materials from or have your Personal Information shared with these companies please contact the Privacy Officer at the address, phone number, or e-mail address provided at the end of this document.
Anonymous information and “cookies”
Mullin Commercial Mortgages may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our Web servers may record certain information automatically when you visit Pemberton Holmes Ltd. websites. This information is collected using “cookies” and might include the pages you visited, your IP (Internet protocol) address and other site usage statistics. This anonymous information is used for research and analytical purposes only (like evaluating how many visitors our Web sites receive or which pages they visit most often). It does not reveal any Personal Information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.
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Questions, concerns, and complaints
R. Mike Mullin, CPA, CGA