CANADIAN PRIVACY NOTICE
Last updated: February 2, 2023
The Carson Dunlop group of companies, which is made up of Carson, Dunlop & Associates Ltd., Carson, Dunlop, Weldon & Associates Ltd. and GPI Franchise Corp. (collectively, “Carson Dunlop”, “we”, “us”, our“) is committed to protecting the privacy of customers (including prospective customers) of its various products, services and benefits, as described below, as well as visitors to its websites https://www.carsondunlop.com, https://www.carsondunlop.ca and https://www.cdwengineering.com (the “Sites”). Carson Dunlop makes every effort to ensure that these individuals understand the nature, purposes and consequences of the collection, use, and disclosure of their personal information, which we explain in this Privacy Notice. For the purposes of this Privacy Notice, “personal information” means any information that can reasonably be used, either alone or in combination with other information, to identify an individual. However, it excludes information that is used for the purpose of communicating with an individual in relation to their employment, business or profession such as their name, position name or title, work address, work telephone number, work fax number or work email address.

1. When does this Privacy Notice apply?
This Privacy Notice explains how we collect, use, and disclose your personal information anytime you communicate or interact with us in connection with the provision of Carson Dunlop’s products, services and benefits, i.e.: (i) Horizon Inspection Software by Carson Dunlop (“Horizon”); (ii), Home Reference Book®; (iii) Carson Dunlop’s home and commercial inspection and related training programs; (iv) the Carson Dunlop Homeowners’ Association Programs; (iv) Carson Dunlop’s property inspection business; and and (v) Carson Dunlop’s Canadian home inspection franchise business. This Privacy Notice also applies to your interactions with the Site.


2. What personal information does Carson Dunlop collect and how does it collect it?
We may collect personal information directly from you in connection with our property inspection business. Depending on the type of inspection we perform, we may collect the following information:


• Contact information such as your name, home address, email address and phone number;
• Information about your home or property such as photos of your home and property and information about your home’s age and condition (including its structure as well as electrical, heating, cooling and plumbing systems) as well as significant renovations and/or upgrades and environmental and geographic data in respect of the home or property;
• Payment information such as credit card or banking information (as describe below, we do not retain this information and use payments service providers to process your payments as described below); and
• Your IP address, when we send you the final inspection report.

If you send us an email, phone us or otherwise contact us through the Site, we may collect personal information you provide to us during those communications, such as the content of your comments, complaints, feedback or inquiries.

If you don’t want your calls recorded, you can communicate with us in writing instead.

We may automatically collect certain technical information from any device that you use to access the Site or interact with us online. Please see ‘Automated Collection’ below for more information.


3. Why does Carson Dunlop collect my personal information?
We may collect your personal information and use it to:


• Provide you with our products, services and benefits;
• Communicate with you regarding product and software updates or changes to our terms, conditions, and policies;
• Consider if there are other products, services or benefits that you might be interested in and send you information about them;
• Process payments for our products, services and benefits;
• Respond to your requests, complaints, comments and questions by establishing a record of information you provide, take or verify your instructions and confirm your identity;
• Maintain your account information;
• Improve the performance and functionality of our systems, including Horizon;
• To provide you with opportunities to participate in our surveys and provide you with Carson Dunlop’s e-newsletter;
• Investigate and settle any claims or security incidents;
• Prevent and detect fraud;
• Train our employees and monitor for quality assurance;
• Enforce our legal rights with respect to any agreement you may have with us, including to collect a debt or enforce an obligation owed to us by you;
• Better understand how visitors interact with our Site, and improve the Site;
• Detect and prevent security threats to the Site; and
• Otherwise act as required or as authorized by law


We may use your personal information for marketing purposes, including to educate current and potential customers about our products, identify customers who may be interested in purchasing our products and reach out to them. If you do not want your personal information to be used for marketing purposes, you can withdraw your consent at any time by contacting us at privacy@carsondunlop.com.

We may de-identify information collected in the course of our home inspection business such that it cannot be used to identify you and analyze and aggregate that de-identified information for the purposes of generating commercial insights for insurers and loan providers. These groups would use that de-identified information for the purposes of evaluating applications for credit and/or insurance products in relation to individual and/or groups of properties. Carson Dunlop would also use such de-identified data to improve the quality of its home inspection services.

If you would like to opt-out of the use and disclosure of this information for these purposes, please contact us at privacy@carsondunlop.com.


4. Automated Collection
We may use various third-party services to help us better understand how users interact with the Site. We may also use various third-party service providers to help us serve advertisements online. To do so, we may embed cookies, pixel tags or other similar technologies provided by those third parties and which may automatically collect the following information:


• Your device’s IP address, which may be used to estimate the general location of your device;
• Information about how you use the Site, Device ID, such as your device's advertising identifier or other device identifiers, which may be used for the purpose of third-party advertising and analytics;
• Advertising data, such as advertisements you have seen and clicked on, which may be used to power analytics and advertising features; and
• Other user interactions like app launch taps, and interaction information, such as how much time you spend on the Site and how you interact with it, the uniform resource locators (“URLs”) of other websites that you click to and from our Site (including the date and time clicked), length of visits to the Site, Site interaction information and methods used to browse away from the Site, all of which may be used to help us improve the Site, better understand our users and improve advertising performance.


We may use cookies to collect some of this information. A “cookie” is a unique numeric code that we transfer to your computer or device that identifies your browser to our server when you visit the Site. We use cookies to recognize you as a return visitor to the Site and save any information you have may entered into a form, as well as to save your screen display choices. Without some cookies, the features described there will not function properly. Any cookie sent to your computer by Carson Dunlop in connection with your use of the Site does not give us access to your computer.

We may also collect information related to emails that we send you, including the types of emails we send that you open and click.


5. Can I opt out of promotional emails?
If at any time you decide you no longer want to receive promotional emails from us, you can opt-out by clicking the ‘unsubscribe’ link located in the footer of the email or by contacting us at unsubscribe@carsondunlop.com. It may take up to 10 days for us to process your unsubscribe request. Please note that we may still send you emails concerning your account with us if you choose to unsubscribe from promotional communications.


6. How and why does Carson Dunlop share my personal information?
In some cases, we transfer your personal information to third parties who provide their services to us. In these cases, Carson Dunlop remains accountable for the personal information. For instance, to fulfill the purposes described above at Section 3 of this Privacy Notice, ‘Why does Carson Dunlop collect my personal information?’ we need to share your personal information with the following types of third-party service providers:


• Third-party data processors and data storage providers;
• Payment service providers, who process your payments for our products and services on our behalf;
• Our affiliates, who help us facilitate staffing for our property inspection business; and
• Marketing and email services that help us to manage and send promotional emails, surveys and other communications of interest to you.
When we allow a third-party service provider to access your personal information, we only allow them to do so for the sole purpose of carrying out the above services on our behalf. In our service agreements with these service providers, we require them to treat your personal information as securely as we do.

In other cases, and where we have your consent, we may disclose your personal information to third parties, for these third parties to use. For instance, we may disclose information contained in a property inspection report to insurance companies or other insurance intermediaries in connection with the provision of insurance products to those properties. We may also disclose the contents of your home inspection report to real estate agents involved in a transaction for that property. We may also disclose personal information you provide to us in connection with our Homeowners’ Association Programs to our partners in those programs.

When you give us permission to disclose your personal information to these third parties, the information we provide to them is then handled by them in accordance with their own privacy policy. If you have concerns about their handling of your personal information, you should contact them directly. In certain narrow circumstances, the law permits us to disclose your personal information without your consent. For instance, we may disclose your personal information to government, regulatory or law enforcement agencies as requested by these agencies, if we have a good faith belief that the disclosure is required or permitted by law. We may also disclose your personal information in order to enforce our legal rights; to detect, prevent or address fraud or security issues; in connection with a court or regulatory proceeding; and to enforce ours or others’ legal rights, property, or safety.

We may also transfer or assign your personal information to third parties because of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.

We do not trade, rent or sell your personal information.


7. How does Carson Dunlop keep my personal information safe?
Carson Dunlop uses reasonable technical, organizational and administrative measures to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

We restrict access to your personal information to only those Carson Dunlop employees, contractors and agents who require that information to carry out the purposes identified above at Section 3 of this Privacy Notice, ‘Why does Carson Dunlop collect my personal information?’ Anyone with access to your personal information is subject to strict confidentiality obligations. However, you should be aware that no safeguard is 100% secure, and despite our best efforts, we cannot guarantee that your information will be secure, particularly while it is in transit over the Internet.

We only retain your personal information for as long as necessary to fulfill the purposes described in Section 3 of this Privacy Notice, ‘Why does Carson Dunlop collect my personal information?’ or as otherwise required by applicable law. For Carson Dunlop’s home inspection clients, we keep reports for a minimum of seven years, unless you request otherwise. One or more of our service providers or affiliates, as well as our Horizon platform, are located in the United States. This means that your personal information may be transferred to, stored, or processed in the United States, and may be accessible to regulatory authorities in accordance with the laws of the United States.


8. What rights do I have over my personal information?
At any time, you may withdraw your consent for us to collect, use or disclose your personal information. However, this may affect our ability to offer you some of our products, services and/or benefits.

At your written request, we will let you know what information Carson Dunlop has about you, what it is being used for, and with whom it has been shared. If you notice any inaccuracies or wish to update any of your personal information, we will make those changes if you request us to do so. If we disagree with your request, we will note that.

At your written request, we will also provide you with access to your personal information that is in our control, subject to certain exceptions. These include where:


• Personal information about another person might be revealed and the other person’s personal information cannot be separated from yours;
• Commercially confidential information might be revealed and the confidential information cannot be severed from yours;
• The requested information is subject to solicitor and client privilege;
• Someone's life or security might be threatened as a result of giving you access and the personal information about the other person cannot be separated from yours; and
• The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.


The way in which we will give you access to your personal information may vary, depending on the format in which we hold it and the amount of information. We may provide your information in physical or electronic format. In the case of an exceptionally large file, we may provide you a summary of the personal information.

To make a request to withdraw your consent, or access or correct your personal information, contact Carson Dunlop’s Privacy Officer at privacy@carsondunlop.com.


9. CONTACT US
If you have any questions or concerns about this Privacy Notice, you can contact Carson Dunlop’s Privacy Officer:

Chief Privacy Officer
Carson, Dunlop & Associates Ltd.
120 Carlton Street, Suite 407
Toronto, ON, Canada


Tel: 416-964-9415
Fax: 416-964-0683
E-mail: privacy@carsondunlop.com