This policy statement (the “Policy”) sets out the privacy policies and practices for Arya Corporation and its subsidiaries and affiliates (collectively, “Arya Corp”) with respect to the collection, use and disclosure of personal information that we gather from individuals accessing Arya Corp website and social media platforms, including Instagram, Twitter, and Facebook (collectively, “Platforms”). This policy may be updated by Arya Corp giving reasonable notice of the revised Policy (including by e-mail or by posting at Arya Corp’s website at www.aryacorp.ca), and this Policy may be supplemented or modified by agreements entered into between Arya Corp and an individual from time to time.
1. Collection, Use And Disclosure Purposes
We interpret the term “Personal Information” in accordance with applicable law as referring to information that may be used to identify, contact, or locate a specific person. Except where otherwise required or permitted by law, Arya Corp will inform individuals of the purposes for the collection, use or disclosure of the individual’s personal information, prior to collecting, using or disclosing that personal information.
Arya Corp collects personal information from customers and potential customers through various means including guest registration sign-up sheets, campaign registrations, web-form registrations, purchase and sale agreements and customer survey responses. The type of information collected will vary depending on the means through which an individual submits his/her personal information. The type of information collected may include an individual’s name, residential address, e-mail address, home phone number, occupation, employment status, age group, current residential ownership details, whether first time buyer, financial and credit information, real estate investment purposes and preferences, preferred marketing mediums and specific comments. For security reasons, Arya Corp may also utilize video surveillance to monitor its premises from time to time.
We do not disclose Personal Information to third-parties other than service providers who process Personal Information on our behalf or as may be required by applicable law.
We do not regard Personal Information that has been anonymized or aggregated to prevent the identification of a specific individual to continue to be Personal Information.
Arya Corp uses personal information collected from customers and potential customers to provide products or services, to respond to requests for information regarding Arya Corp’s products and services, for input on preferred features for future developments, mailing contacts for Arya Corp publications and newsletters, special events marketing and other marketing research activities, and for additional purposes that may be identified at or before the time that the information is collected. Arya Corp also uses personal information from purchasers for accounting and transaction completion purposes. Arya Corp may disclose personal information to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.
Requirements for consent to collection, use, or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, Arya Corp will take into account both the sensitivity of the personal information at issue and the purposes for which Arya Corp will use the information. Consent may be express, implied (including through use of “opt-out” consent where appropriate), or deemed. For example, if an individual provides his/her mailing address and requests information regarding a particular product, consent to use the address to mail product information to the individual is implied.
On giving reasonable written notice to Arya Corp, an individual may withdraw consent to the collection, use or disclosure of his or her personal information. Upon receipt of this withdrawal, Arya Corp will notify the individual of the likely consequences of withdrawing his or her consent. Except where otherwise required or permitted by law, Arya Corp will then stop collecting, using or disclosing the individual’s personal information.
Usage Information collected is used to compile overall statistics and is not recorded at an individual level. The statistics help us decide which products and services best serve our website visitors and other customers and for the maintenance and improvement of our Platforms.
The Usage Information we may access, collect, and/or monitor can include location data, such as geographic information regarding the location of the accessing device. Location data may help us understand where our Platforms are being used. Location data, however, is only displayed and shared in accordance with the privacy settings in each user’s device or browser software.
We also use Google Analytics for tracking visitors and aggregating information about the traffic to our Platforms. The Google Analytics Privacy Statement can be found here: https://policies.google.com/privacy. You can learn more about how to opt-out of tracking in Google Analytics here: https://tools.google.com/dlpage/gaoptout/.
By using our Platforms, you are authorizing us to process Personal Information and Usage Information as described in this Policy.
2. Limits To The Collection Of Personal Information
Except where required or permitted by law, Arya Corp will limit the collection of personal information to that which is necessary to fulfill the purposes for which it is collected. Personal information will be collected by fair and lawful means.
3. Use, Disclosure And Retention
Arya Corp will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Once the information is no longer required to fulfill its intended purposes, and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed, erased or made anonymous.
By “opting-in” the individual has given express consent to Arya Corp sending mail, emails or text messages through the information provided, promotional messages such as newsletters, announcements, press releases and event invitations regarding their current and future products and services.
By “opting-in” the individual consents to receiving calls or text messages by the selected means of contact by or on behalf of members of Arya Corp at that number to discuss their current and future products and services.
Before a licensed realtor registers on behalf of his or her client, the licensed realtor must seeks prior consent from the client of such registration including consent to Arya Corp sending marketing materials regarding current and future products and services.
Arya Corp will make reasonable efforts to ensure that any personal information collected by it, or on its behalf, is accurate and complete if the personal information is likely to be used by Arya Corp to make a decision that affects the individual to whom the personal information relates or if the information is likely to be disclosed to a third party.
Individuals may withdraw your consent at any time.
Arya Corp may be reached by email at email@example.com, or at the following mailing address: Arya Corp 220 Duncan Mill Rd, Ste 401 Toronto ON M3B 3J5, Attention: Marketing.
Arya Corp may disclose certain personal information to third party service providers and to affiliated entities in order to carry out work on behalf of Arya Corp. Prior to making this disclosure, Arya Corp will take appropriate steps to ensure that such recipients safeguard the personal information and use the information only for authorized purposes.
Arya Corp will protect personal information with security safeguards appropriate to the sensitivity of the information. Security safeguards are employed to protect personal information against loss, theft and unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. The nature of these safeguards will vary depending on the sensitivity of the personal information that has been collected. The methods of safeguards include:
- Physical security measures such as locked filing cabinets and areas
- Security clearances and limiting access on a “need to know” basis
- Technological measures such as the use of passwords
Upon request, Arya Corp will make information available about its personal information policies and practices, and its complaint process.
7. Individual Access
Upon written request, with sufficient detail to enable Arya Corp to identify the individual and the personal information being sought, Arya Corp will inform an individual of the existence, use and disclosure of his or her personal information under Arya Corp’s control and will provide access to that information, unless otherwise prohibited or permitted by law. Arya Corp will respond to all requests within 30 days. Arya Corp may extend the time limit for a further 30 days, or, for a longer period, with the Privacy Commissioner’s permission or as otherwise permitted by law.
Upon written request, an individual may request Arya Corp to correct an error or omission in the personal information that is under Arya Corp’s control. If Arya Corp is satisfied on reasonable grounds that a correction should be made, it will amend the information as requested as soon as reasonably possible, and it will send the corrected information to each organization to which it has disclosed that information during the year prior to the date of correction.
8. Challenging Compliance
An individual may direct a complaint concerning compliance with the Policy to Arya Corp’s Privacy Officer.
The complaint must be in writing. Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the compliant. The format of this investigation will vary depending on the circumstances and may or may not involve an interview of the complainant and/or Arya Corp employees conduct by the Privacy Officer.
Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, that the complaint is either: (a) denied (if, in the Privacy Officer’s opinion, it has no merit): or (b) allowed (if, in the Privacy Officer’s opinion, the complaint is valid)
If the Privacy Officer allows the complaint, Arya Corp will take appropriate measure necessary to rectify the source of the complaint.