Global Privacy Notice

FRAME will protect your privacy and safeguard your personal information.

FRAME’s privacy management practices comply with relevant laws and regulations, including data protection.

FRAME pledges to apply these Privacy Principles to all our interactions with you as you reach for the future you deserve.

Designed for Accountability and Privacy

FRAME is dedicated to protecting any personal information entrusted to us, from our first interaction onward. Privacy is fundamental to the way we do business.

FRAME has a privacy officer, who is responsible for overall privacy governance and data protection. All FRAME employees are trained on how to maintain your privacy and to answer any of your privacy questions or concerns.

If you have questions regarding privacy, please reach out.

• General Questions on privacy or security matters specific to your FRAME relationship.
• Make a Complaint if you have problems or concerns.
• Concerns can also be escalated to the FRAME CEO: Tammy Williams
• You also retain the right to contact relevant regulatory or data protection authorities if you have concerns with FRAME’s adherence to privacy rules.

When FRAME uses your information

FRAME can only use your personal information where we have the legal basis to do so. This includes sharing information outside of FRAME. We are legally able (or required) to use your personal information:

•   To fulfill a contract with you to provide services within your account agreement
•   To comply with legal and regulatory obligations
•   To prevent, suppress or detect fraud and crime
•   When we are processing information based on your consent
•   For legitimate business purposes
•   For the establishment, exercise or defence of legal claims or proceedings

Sharing your information

Under certain circumstances, FRAME may share your personal information with our parent organization or third parties.

AREA Real Estate Services Corporation

FRAME Employees

Only authorized FRAME employees with a legitimate business purpose may access your personal information. For example, when you call or email FRAME, designated employees will access your information to confirm your identity and assist you.

All FRAME employees are strictly prohibited from unauthorized use or disclosure of personal information. Failure to maintain FRAME’s privacy policies will result in disciplinary measures that may include dismissal.

Third-Party Service Suppliers

FRAME may use service providers in the regular performance of business, such as data processing, cheque-printing, research or marketing. These service providers may, at times, be responsible for processing or handling personal information. When this is the case, FRAME’s service providers are only given the information necessary to perform the services and are required by contract to adhere to FRAME’s privacy and security best practices.

Other Third Parties

FRAME only shares your personal information with other third parties as noted in your account agreement and accepted terms and conditions, or:

•   To comply with valid, authorized information requests from domestic and international authorities
•   As permitted or required by law, to comply with laws, regulations, subpoena or court order
•   To prevent, suppress or detect fraud or crime
•   To protect the personal safety of FRAME employees, clients or other third parties on FRAME property.

Your information stays in Canada

FRAME servers and services are operated out of Canada. This means your personal information is transmitted, stored or processed within your home country and is bound by the privacy and security laws and regulations of Canada.

Your rights to your personal information

Through your FRAME account, you will have access to transaction activity records via secure online sites, mailings or verified telephone inquiries.

For access to any personal information we may hold about you beyond what can be accessed in the channels noted above, you may submit a written request via [insert email]. To avoid delays, please provide detail enough to identify you and what information you are requesting.

There may be instances where access is restricted as permitted or required by law. Should this occur, we will advise you of the reasons for restricting access, subject to any legal or regulatory limitations.

You may request restriction, portability or removal of the personal data FRAME processes about you at any time by sending a request to info@frameyourfuture.ca.

Please contact us with any questions about FRAME’s privacy policies.

Where FRAME collects information

FRAME collects personal information when you interact with us. These interactions include:

•   Apply for a service
•   Enter a contest
•   Communicate with us
•   Complete a survey

We also collect financial and other information about you from sources including:

•   References you have provided FRAME
•   Your transactions with FRAME
•   Credit bureaus
•   Other financial institutions

We may collect personal information about you from third parties, according to their respective terms and conditions or privacy policies with you. These third parties may include:

•   Third party verification services
•   Credit reporting agencies
•   Commercially available sources like mailing list providers
•   Publicly available sources like telephone directories, social media and public records

FRAME will ask you to provide information that allows us to fulfill your service request, provide better service or offer you products and services in which we believe you may be interested.

Your information

FRAME will seek the information essential to fulfilling your service requests, including information:

•   Establishing your identity, such as your name, address, phone number, title, brokerage name, email address, data of birth, social insurance number and account numbers
•   To authenticate your identity, such as your username and password, biometric information (i.e. signature), and device information (i.e. IP address, security cookie, approximate device location)
•   Related to transactions arising from your relationship with and through FRAME
•   You have provided on an application for FRAME services, such as place of employment, financial liabilities and transaction history
•   You provide FRAME on your goals and opinions, which may include family details and life events
•   Pertaining to your business as it relates to FRAME, such as MLS listing number, legal property description, commission owing [needs to be updated with actual ask]
•   FRAME may request to determine your eligibility for services we provide

Other Information

FRAME wants to consistently improve our service offerings. We routinely refer to aggregated, non-personal information available through surveys, public archives and website analytics to help us understand the interests of our current and future clients and to manage our risks and operations.

How your information is used

FRAME may use your personal information for the purposes included in your account agreement or communicated with you when that information was collected. These uses include:

•   To confirm your identity when you contact FRAME
•   To provide you with the FRAME services you have requested
•   To share with you information, benefits and features about the FRAME services you have with us
•   To understand your eligibility for the FRAME services we offer
•   To manage FRAME’s risks and operations
•   To meet regulatory and legal requirements

Additional Uses

FRAME may communicate with you through various channels, including telephone, email, social media or mobile applications, using the contact information you have provided.

FRAME may send you information on products and services, including FRAME services and related third party products and services, but only in accordance with the communication choices you have made.

FRAME may create aggregated reports, including statistical reports, analysis and predictive models, rules and insights using anonymized information about you and other FRAME clients. FRAME may share aggregated reports with third parties. The information in these reports is not personal and cannot be used to identify you.

FRAME will always seek your consent before proceeding to use your personal information in a way that differs from your original intent.

Please note that FRAME will never share or use sensitive information, such as health records, for a purpose other than that of the original intent.

Keeping Your Information Safe and Accurate

FRAME promises to do our best to ensure your information is accurate and complete and will keep your personal information for as long as required to comply with all business, legal and regulatory record keeping requirements and align with FRAME’s internal policies and retention schedules. This promise extends to FRAME’s online services and any new technologies we may employ.

We encourage you to keep your information with FRAME current because we make decisions based on the information we have available.

Contact FRAME at any time if you want to update or correct your personal information, or confirm its accuracy.