eXp World Holdings, Inc. Supplemental
Privacy Policy and Data Processing Policy
(Canada)
Effective: May 5, 2023
eXp World Holdings, Inc. (“EXPI”) is a holding company for an ecosystem of companies, headquartered at 2219 Rimland Drive, Ste. 301, Bellingham, WA 98226. EXPI maintains the eXp World Holdings, Inc. Privacy Policy and Data Processing Policy (the “Privacy Policy”) which reflects the global privacy practices and standards for EXPI and those of its Listed Subsidiaries (as defined in the Privacy Policy).
EXPI operates in Canada through those of its Canadian subsidiaries listed here (hereinafter, “Canadian Subsidiaries,” “eXp Canada,” “us,” “our,” or “we”). This Supplemental Privacy Policy (this “Supplemental Policy”) supplements the Privacy Policy as it pertains only to the Canadian Subsidiaries, and sets out how we collect, use, and disclose Personally Identifiable Information that you provide to us through any eXp Sites, and through any Services. Defined terms used but not otherwise defined in this Supplemental Privacy Policy shall have the same meaning used in the Privacy Policy; defined terms that are defined in both this Supplemental Privacy Policy and the Privacy Policy shall have that meaning as ascribed in this Supplemental Privacy Policy. This Supplemental Privacy Policy as also available in French (Canada) here.
By using or accessing any of our eXp Sites and Services, you consent to the collection, use and disclosure of your Personal Information, by us in compliance with this Supplemental Policy. We reserve the right to update this Supplemental Policy at any time without notice. We ask that you periodically check the date and review this Supplemental Policy for the latest information on our privacy practices. The date at the top of this policy indicates when it was last updated. If you are not satisfied with any new terms, you may withdraw your consent. If you withdraw consent, we may not be able to provide certain access to any of the eXp Sites or Services.
You may opt out of any disclosure or use of your Personal Information for purposes for which you originally consented by notifying us by one of the methods at the end of this Supplemental Policy, or by following the procedures set forth in an electronic communication from us, if applicable.
We will undertake reasonable efforts to notify third parties with whom we have shared your Personal Information as permitted under this Supplemental Policy of your election to opt out. If you do not opt out, we may continue to collect, use, and disclose your Personal Information as set forth in this Supplemental Policy. There are some uses from which you cannot opt out, such as to provide Services that you have requested from us.
By accessing any eXp Sites, you are agreeing to the Terms and Conditions.
Our Terms of Use, Privacy Policy, and this Supplemental Privacy Policy are each available in French.
Defined Terms
How We Communicate With You
When you use our Services or set up a User Account, eXp Canada may send you electronic messages as permitted under Canada’s Anti-Spam Legislation (CASL) for communicating about the Services you requested, providing information about additional Services we can provide, verifying, authenticating, and securing your account, and marketing communications. You may opt out of marketing communications at any time by utilizing the links to unsubscribe contained in such communications or by sending a request to privacy@expworldholdings.com.
Marketing
We may send you information about existing and new Services, and special offers available by email, telephone, mail, or by means of any other contact details you provide to us, to eXp, to our Affiliates, and/or to Third-party Service Providers that you have authorized to share your information with us.
eXp and its Affiliates may provide special virtual events and in-person events. We may send you information about previous and upcoming events.
Each advertising email communication we send includes an unsubscribe link allowing you to stop delivery of that type of communication. If you elect to unsubscribe, we will remove you from the relevant list within ten (10) business days unless Applicable Law dictates a shorter timeline.
Transactional
We may provide notifications and other similar communications for certain activities relating to your use of the Services. Examples of transactional communications include sending you an email when you register with us, set/change a password, complete or submit an online form, or when we provide you with updates relating to ongoing quotes or Services. Please note that you may receive these transactional communications from both us and our Agents. For example, if you request to work with an Agent, the Agent will contact you with respect to your request.
This Notice Is Effective For Canada
We are committed to protecting the privacy and security of your Personal Information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian provincial privacy legislation. You acknowledge and agree that the eXp Sites and some Services are provided via the Internet and that your Personal Information may be transferred across national borders and stored or processed in accordance with this Supplemental Policy.
What Personal Information Do We Collect?
The types of Personal Information we collect, use and disclose depends on who you are and how we interact with you. Generally, Personal Information is defined as information that identifies you or that makes you identifiable and could include Usage Information (as defined below). It includes data that could be used to identify, locate, track or contact you.
eXp Canada, eXp, and its or their Affiliates (inclusive of any third party we engage for the purpose of administering, operating, hosting, configuring, designing, maintaining, and providing internal support for the eXp Sites and Services), may collect Personal Information and Usage Information when you use the eXp Sites and Services.
Usage Information Collected from You
The types of usage information we collect when you visit the eXp Sites include the following categories of information (collectively, “Usage Information”):
How Do We Collect Usage Information?
Unique Identifier
We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the eXp Sites and some of the electronic communications you receive from us. We keep this information for our internal use, and this information is not shared with others.
Personal Information Collected Directly from You
Clients and Site visitors | Agents | Employees and Consultants | Potential Employees |
When you use the eXp Sites and Services, we may collect Personal Information about you. The types of information we may ask for depends on the nature of the service you request. This information includes: | When you apply as an eXp Canada Agent and during your engagement as an independent contractor, we may collect or receive the following Personal Information: | If you are employed by us, have applied for employment, are a Consultant or applied to be a Consultant, or are a former Employee of eXp Canada, we may collect the following Personal Information about you in order to fulfill our obligations to you: | When you apply to eXp Canada for employment we may collect the following Personal Information: |
Contact information such as name, title, company or organization name, email address, screen name, password, telephone and facsimile numbers, postal address, social media account username;
Demographic information, such as date of birth, nationality and country of residence, which allows us to determine your eligibility under certain regulations to receive certain information; Government issued identification such as your Social Insurance Number (SIN), a valid passport or driver’s license, as well as other documents or means of confirming your identity; Transactional information such as property description, the purchase or rental price of your property; records of personal property, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; Financial information such as bank account details, financial transactions, and credit/debit card numbers. |
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Educational and employment history such as academic background, degrees, certificates earned, transcripts, past employment history (including length of time employed, and position), compensation history, professional certifications and licenses, and any other Personal Information you include on the application or resume; and Additional information provided such as information provided on your CV/resume, job application, information we may collect from references provided, information collected during interviews or information you may choose to submit that we do not request. |
Personal Information We Collect or Receive from Third Parties
Depending on who you are and how we interact with you we may collect Personal Information from sources internal to eXp Canada, eXp, Affiliates or external third parties. This collection may be required or permitted by law. Please note that your consent may be explicit or implied from your actions. For example, using a social media account to create or sign-in to account with us, Facebook or Google (as applicable) will share certain Personal Information (e.g., name, email address, profile picture) to facilitate account creation or sign-in. We may collect Personal Information from the following categories of third parties or public sources:
Personal Information We Collect at eXp Events
eXp works with its Affiliates and Third-party Service Providers to provide special virtual events and in-person events to which you may register to attend. eXp Events may be sponsored by one or more Affiliates, Third-party Service Providers, and/or organizations with which you may or may not be employed, contracted with as an independent contractor, enrolled as a student, or otherwise affiliated. We may collect Personal Information about you if you register and attend an eXp Event. eXp Canada may share your Personal Information with sponsors of any eXp Events, as well as its or their licensees in connection with eXp Events, but you may opt-out of such sharing at the time of registration, if applicable.
Why Do We Collect Personal Information?
We collect, use and disclose your Personal Information where permitted or required by Applicable Laws for the following purposes:
If you provide any comments, information, or feedback regarding the eXp Sites, Services, or other products, you grant us a license to use that information for any purpose not inconsistent with this Supplemental Policy, including but not limited to display on the eXp Sites or marketing materials, without notice or compensation to you.
The purposes for which we collect, use and disclose your Personal Information may vary depending on your relationship or interactions with us. Please note that you can interact with us in more than one way. In addition to the above, we may collect, use and disclose your Personal Information for the additional purposes described in the following section:
Clients and Site visitors | Agents | Employees and Consultants | Potential Employees |
We collect Personal Information about you to manage, maintain, and develop our real estate operations. We may use your Personal Information for the following purposes: | We use the Personal Information we collect about you in order to consider, approve and maintain your affiliation with us. We may use your Personal Information for the following purposes: | As an eXp Canada Employee or Consultant we may use your Personal Information for the following purposes: | As an individual applying for employment with eXp Canada, we may use your Personal Information for the following purposes: |
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How Do We Collect Personal Information?
How we collect Personal Information from you depends on how you interact with us. Please note that you can interact with us in more than one way.
Clients
If you are a Client accessing the eXp Sites or using our Services, we may collect Personal Information about you in the following manner:
Agents
As an Agent we may collect Personal Information when you apply as an independent contractor and during your engagement as an Agent with eXp Canada.
Employees and Consultants
If you are an Employee or Consultant or are a former Employee or Consultant of eXp Canada, we may collect Personal Information about you during employment or contract, as applicable, with eXp Canada, for example, through onboarding forms completed by you following acceptance of an employment offer or Consultant role.
Potential Employees
As a Potential Employee of eXp Canada, we may collect Personal Information about when you submit an application form, resume, or CV.
How We Share Your Personal Information?
We may transfer Personal Information that we collect about you outside of Canada, including to the United States, for the purposes set out above and in the Privacy Policy, including for processing by eXp and/or our Affiliates and Third-party Service Providers in connection with those purposes. eXp and/or our Affiliates and Third-party Service Providers may perform processing activities outside of Canada.
We, eXp, and our Affiliates and our Third-party Service Providers may be required to disclose your Personal Information to the courts, government authorities, law enforcement or regulatory authorities of the country where Personal Information is being stored in response to a valid demand or request in accordance with Applicable Laws.
We require all our Third-party Service Providers and Affiliates to implement and maintain technical and organizational measures to protect your Personal Information in a manner consistent with this Supplemental Privacy Policy.
Where Is Your Information Stored and For How Long?
Your Personal Information will be retained by eXp Canada only for as long as necessary to accomplish the identified purpose for which it was collected, or as required by law, whichever is longer. If you choose to delete your User Account, or your User Account becomes inactive, information associated with your User Account may remain stored on our servers for a period of time that can vary subject to our data retention policies and legal obligations. When we are no longer required to retain your Personal Information, we will destroy it or render it anonymous.
The Personal Information that we collect from you may be stored and processed outside of Canada, including the United States, at eXp’s, and/or our Affiliates’ and Third-party Service Providers’ servers.
How Do We Protect Your Personal Information?
Commitment to Security: eXp Canada intends to protect your Personal Information and to maintain its quality. We use commercially reasonable technical, administrative, and physical safeguards and security measures designed to protect your Personal Information from unauthorized access, use, disclosure, loss, misuse, alteration, or destruction. We limit access to your Personal Information to those who have a genuine business need to access it and in accordance with the identified Purposes. We have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. eXp Canada uses encryption when transmitting certain sensitive information. All User Account pages are protected with Secure Socket Layer (“SSL”) encryption.
Security of Username/Password: You are ultimately responsible for ensuring the security of your username, password, and User Account information from unauthorized access, use or disclosure to others. When using the Services, you are not permitted to circumvent the Services’ security features. You agree to: (a) immediately notify us of any unauthorized use of your username, password and/or User Account, and/or any other breach of security; and (b) ensure that you log out from your User Account at the end of each session.
No Liability for Acts of Third Parties: We will exercise all reasonable efforts to safeguard the confidentiality of user Personal Information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure, and we do not represent or warrant that those transmissions will be free from delay, interruption, interception, or error.
Links to Other Sites
The eXp Sites may now or in the future contain links to other sites such as our Affiliates, professional organizations, and Third-party Service Providers that advertise on the eXp Sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites. This Supplemental Policy applies only to the eXp Sites and Services and our collection and use of your Personal Information. We are not responsible for the information collection practices of other organizations that link to the Services, or to which the Services link. Please refer to the privacy policies of those websites in order to determine their usage of your Personal Information and your rights.
How Can You Update Your Personal Information?
You can make a request to update your Personal Information collected through the eXp Sites or Services by completing our Contact Us Form or, if you have a User Account, by accessing and reviewing your Personal Information in your User Account. You may also send a request to our Privacy Officer:
eXp World Holdings, Inc.
Privacy Officer
2219 Rimland Drive, Ste. 301
Bellingham, WA 98226
We may take steps to verify your identity before providing you access to your Personal Information. You can help us to maintain the accuracy of your information by notifying us of any change to your mailing address, phone number, or email address.
How Can You Access Your Personal Information?
You have the right to access Personal Information we hold about you. You can access some information we hold about you through your User Account. You can also ask us for a copy of some or all by contacting us at:
eXp World Holdings, Inc.
Privacy Officer
2219 Rimland Drive, Ste.
Bellingham, WA 98226
You may put your request in writing using our Contact Us Form. We ask that you provide us with enough specific details to help us understand your request and conduct our search for your information. We will need you to verify your identity before searching for, or providing you with, access to your information. We will let you know in advance whether there will be a fee to provide access to your information. We may also ask you for additional information to confirm the scope of your request, or a specific description of the information you are seeking to access.
Once we receive your written request, verify your identity, and understand the scope of your request, we will provide a written response to your access request within the time frame set by the applicable privacy law.
There may be limits on your right to access your information, for example, if the information is subject to legal privilege, contains confidential commercial information, relates to an investigation of a breach of an agreement or law, or contains information of other individuals that cannot be separated.
We are committed to making our eXp Sites and our Services accessible for all our users. You may request your information in an alternative format. If we already have this format, we will provide it. Otherwise, we will convert the information into the requested format if it is reasonable and in accordance with the applicable privacy law to enable access.
Children
The eXp Sites and Services are not intended for or designed to attract children under the age of thirteen (13), nor do we knowingly collect Personal Information of anyone under the age of thirteen (13). If we discover we have collected Personal Information of an individual under the age of thirteen (13), we will immediately delete such Personal Information. If you are the parent or legal guardian of a child under the age of 13 and you believe we are in possession of Personal Information of that child, please contact our Privacy Officer using the contact information provided herein or our Contact Us Form.
By using the Services, you affirm that you are at least eighteen (18) years of age or the age of majority in your jurisdiction, or an emancipated minor, or possess parental or legal guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Supplemental Policy, and to abide by and comply with this Supplemental Policy.
What If You Have A Privacy Concern?
Your privacy is important to us, if you have any further privacy concerns or questions, please do not hesitate to contact our Privacy Officer.
eXp World Holdings, Inc.
Privacy Officer
2219 Rimland Drive, Ste. 301
Bellingham, WA 98226
If your privacy concern remains unresolved, you may consider contacting the Office of the Privacy Commissioner of Canada (OPC).
Telephone:1-800-282-1376
Website: priv.gc.ca
Write to: 30 Victoria Street, Gatineau, Quebec K1A 1H3
Copyright © 2023 eXp World Holdings, Inc. | All Rights Reserved.