Privacy Policies

At CDC, we respect the privacy of our clients and we are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that CDC continues to meet its commitment to your privacy.

The following sections, read as a whole, comprise the CDC Privacy Policy:

1. Introduction
2. The Ten Principles of Privacy
3. Application of the Ten Principles
   
   
   • The kind of information we collect
   • How we use your information
   • When can we disclose your personal information?
   • Who we share your information with
   • How we safeguard your information
   • Accessing your personal information
   • Opting Out
   • Cookies

Introduction

CDC provides a variety of types of appraisals and services to mortgage lenders, Lawyers, Accountants, Brokers and the public. The services include, but are not limited to, providing real property appraisals and consulting.

In the course of providing these products and services, CDC may collect certain personal information about borrowers.

"Personal Information" means information about an identifiable individual client. This may include without limitation, the individual’s name, address, and other information about his or her property.

The CDC Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at http://www.privcom.gc.ca.

This Privacy Policy describes the ten principles that CDC follows to ensure that we protect our clients’ personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada. All of our employees and contractors who have access to personal information must adhere to the CDC Privacy Policy and related procedures.

The Ten Principles of Privacy

The following ten principles govern our actions as they relate to the use of our clients’ personal information:

Principle 1 - Accountability

CDC 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 our clients, contractors or employees.

Principle 2 - Identifying Purposes

CDC collects personal information supplied to it by financial institutions, lawyers and other clients that is required to permit CDC to provide the services requested. We are obligated to protect the confidentiality of your personal information, and we are prohibited from doing anything with this information that we have not been authorized to do by our clients. It is our policy to treat your personal information in a manner consistent with your financial institution’s privacy policy. CDC relies upon such financial institutions, all of whom are bound by PIPEDA, to obtain their customers’ consent or rely upon an exemption to PIPEDA, before providing CDC with their customers’ personal information. CDC informs its clients of the purposes for which it is collecting any personal information, before or at the time the information is collected.

Principle 3 - Consent

CDC will obtain consent from its clients before or when it collects, uses or discloses their personal information.

A client’s consent can be express, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. CDC, however, may collect, use or disclose personal information without the client’s 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 from the client will be limited to those details necessary for the purposes it has identified to the client. 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 the client and the individual forming the subject of the personal information has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfil the purpose for which it was collected or to fulfil contractual obligations with respect to record retention.

In certain exceptional circumstances, CDC have a legal duty or right to disclose personal information without client knowledge or consent with respect to matters that concern the company’s or the public’s interest.

Principle 6 - Accuracy

CDC will keep personal information as accurate, complete and current as necessary to fulfil the identified purposes for which it was collected. Clients 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. See "How We Safeguard Information" below.

Principle 8 - Openness

CDC will make information available to its clients and the general public about the policies and procedures CDC uses to manage personal information. Clients and the general public have access to this information through our web sites, or through alternate means if requested.

Principle 9 - Client Access

Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. CDC will respond to such requests as efficiently as possible. If CDC is prohibited from providing such access they will explain the reasons for the lack of access, except where prohibited by law.

Principle 10 - Addressing Client Complaints and Suggestions

Clients and members of the general public in respect of whom CDC has collected, used or disclosed personal information, may challenge CDC compliance with this Privacy Policy. CDC has policies and procedures to receive, investigate and respond to complaints and questions.

Application of the Ten Privacy Principles - How we treat your personal information:

The kind of information we collect

CDC gathers and uses personal information in order to provide its clients with the products and services they have requested. Providing us with personal information is a choice made by your financial institution, however, we may not be able to provide you or our financial institution clients with certain products or services if we are not provided with certain information. For example, we cannot provide appraisal or legal services if we do not know where you live. The nature of our client’s product or service request will determine the kind of personal information we might ask for.

Information that is typically required to provide our products and services includes:

• Name
• Address
• Phone number(s)
• Approximate market value of the property being purchased/re-financed/transferred
• Address of the property being purchased/re-financed/transferred
• Specific financing details related to potential loans are sometimes collected
• Documentation created and processed in connection with transactions that are stored as a disaster recovery service for law firms using certain of our software packages

CDC may keep a file with your contact history to be used for client inquiry or disaster recovery purposes. How Your Information Is Used

At CDC we use personal information for three general purposes:

1. To communicate with you in order to provide our products and services. Some services may be provided by third party suppliers (such as Appraisal Management Companies or lawyers) to better serve your needs.
2. Transactional information to monitor our level of service and report back to our clients to ensure satisfaction with the provision of such services.
3. Disaster recovery protection.

We will only use personal information for the purpose that we have disclosed to our clients. If we want to use your information for a different purpose, we will notify you and our clients and obtain consent first.

When Can We Disclose Your Personal Information?

CDC is obliged to keep your personal information confidential except under the following circumstances:

When Authorized by our Clients
Many of the services offered by CDC require us to obtain personal information about you in order to perform the services we have been engaged to provide. We will use this information to tailor programs to meet our clients’ needs and objectives. We will always obtain consent, and we will never use the information for purposes other than those we have told our clients about.

For example, if we are going to provide an appraisal on your home we will need to obtain information about your telephone number or address. You may withdraw your consent at any time, subject to any legal implications (which we will inform you or your financial institution about). If you withdraw your consent to use or disclose certain personal information CDC may be unable to continue to provide all or part of the services requested. When Required by Law

The type of information we are legally required to disclose usually relates to government tax reporting requirements. However in some cases, 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.

When Permitted by Law
The legislation has provided certain situations where CDC 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

CDC Employees and Contractors
In the course of daily operations, access to sensitive personal information is limited to those employees and contractors with a legitimate reason for accessing it. As a condition of their employment/contract, CDC employees and contractors are required to follow all applicable laws and regulations, including this Privacy Policy. Unauthorized use or disclosure of confidential client information by a CDC employee or contractor is prohibited and may result in disciplinary measures.

CDC Affiliates
In order to better serve our clients, 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".

CDC Third Party Suppliers
As you may know, we often engage and coordinate third party suppliers to provide certain services offered through CDC. We use third party suppliers to provide appraisals.

Such suppliers are only given the information that is needed to provide the specific service for which we contract them to provide. Suppliers are contractually bound to protect the confidentiality of your personal information, and they are prohibited from doing anything with this information that we have not authorized them to do. They are required to treat your personal information in a manner consistent with the CDC Privacy Policy.

How We Safeguard Information

CDC has extensive controls in place to maintain the security of its information and information systems. Client files are stored according to the sensitivity of the information contained therein.

CDC uses network security tools, such as firewalls to safeguard personal information. We also use unique identifiers to identify, authenticate and authorize any employees, who can access, view or handle your personal information.

Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees or contractors.

When you telephone a CDC employee or contractor 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, 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 or to make a change to that information, please make a written request by sending an e-mail to [email protected] . We will respond to your request as efficiently as possible.

To make a change, please make a similar request in writing to CDC.

Opting - Out

In order to provide you with our services and products, CDC will, with your consent, share your personal information with other CDC affiliates. Should you not want to receive promotional materials from or have your personal information shared with these companies please contact CDC at [email protected].

Anonymous Information and "Cookies"

CDC 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 CDC web sites. 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.

"Cookies"

"Cookies" are small text files that contain a unique identification number that allows our computers to identify your web browser (but not you) each time you visit one of our web sites that uses cookies. The information helps CDC improve the functionality of the site and enhance the navigation and security of your session. Cookies do not disclose the individual identity of a site user and cannot be used to collect sensitive information about your computer or data residing on your computer. Most major web sites use this technology and most browsers are set up to accept them.

You may configure your browser to notify you when you receive a cookie, and you may refuse to accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our site. For example, the cdcinc.ca web site requires cookies to recognize clients with valid access to the database. If your browser does not accept cookies, the site will not grant you access via the login and password.