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Homes to Zero Privacy Policy 

Last updated: September 1, 2022 

 

OUR COMMITMENT TO PRIVACY 

 

Homes to Zero Inc (“Homes to Zero”) is committed to your privacy and protecting it through our compliance with this privacy policy (“Privacy Policy”). Homes to Zero has developed this Privacy Policy in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other relevant privacy laws.  This Privacy Policy explains how Homes to Zero (“us”, “our”, and “we”) gathers and uses your information and applies to all who use our website, or other electronic services, or any individual, business-partner-specific, merchant-specific, city-specific, or other area-specific websites we offer that link to or reference this Privacy Policy (collectively, the “Site”), including in the event you receive electronic communications from us. 

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Please read this Privacy Policy carefully and review it periodically for the latest information about our privacy practices. By visiting and/or using the Site, you expressly consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your Personal Information or interact with the Site. 

 

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I. SCOPE 

 

This Privacy Policy applies to all Personal Information collected, used or disclosed by Homes to Zero from users of our Site (“Users”), including you.  “Personal Information” is any information in any form that identifies or can identify an individual or could be combined other information to identify an individual. 

 

This Privacy Policy also describes how we use information collected by Homes to Zero that is aggregated, anonymized, or otherwise cannot be linked with any individual. 

 

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II. ACCOUNTABILITY 

 

Homes to Zero is responsible for the Personal Information under its possession and control.  Homes to Zero has designated a Privacy Officer to be responsible for its compliance with this Privacy Policy and applicable privacy legislation. 

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Homes to Zero shall make known, upon request, the title of the person or persons designated to oversee our compliance with this Privacy Policy.

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Homes to Zero is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. Homes to Zero shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party. 

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Homes to Zero shall implement policies and practices to give effect to these principles, including: 

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  • Implementing procedures to protect Personal Information; 

  • Establishing procedures to receive and respond to complaints and inquiries; 

  • Training staff and communicating to staff information about the organization’s policies and practices; and 

  • Developing information to explain the organization’s policies and procedures. 

 

 

III. THE INFORMATION WE COLLECT 

 

Personal Information 

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Homes to Zero collects your Personal Information when you voluntarily provide it to us by using our Site. Personal Information that we collect includes, but is not limited to:

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  • Identification Information: information that you provide us through our contact form or by email, including your name, email address and address including post code. 

  • Questionnaire Information: information about your home and its energy consumption, including HVAC sources and age of your home. 

  • Other Information: other information that you may provide us, including information about your home and/or with respect to questions about our service. 

 

Non-Personal Information 

 

Homes to Zero collects non-Personal Information (“NPI”) about Users when they interact with the Site or use our services. For instance, NPI may include, but is not limited to, browser name, type of computer or device, and technical information about a User’s means of connecting to the Site, such as operating system. See the section below entitled “How does Homes to Zero collect, use and share NPI?” for more information. 

 

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to you or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information. 

 

 

IV. HOW DO WE USE PERSONAL INFORMATION 

 

Homes to Zero collects Personal Information for the following purposes: 

 

  • to respond to your questions about Homes to Zero and/or our services that you send us through our Site or by email; 

  • to analyze your home’s energy consumption and provide recommendations for your home to become net zero 

  • to support our business functions, such as internal business processes and/or marketing; 

  • to administer the relationship between you and us establish and maintain commercial relations with you; 

  • to understand, research and improve our services;  

  • to meet any legal or regulatory requirements;  

  • to comply with applicable laws; and 

  • for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied. 

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V.  HOW DOES HOMES TO ZERO COLLECT, USE AND SHARE NPI?   

 

Homes to Zero uses NPI in an ongoing effort to better understand and serve our customers and to improve the content and functionality of our Site.  This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.  For instance, Homes to Zero uses NPI to monitor traffic and to collect statistical data. 

 

 

VI. CONSENT 

 

Homes to Zero respects your privacy and, unless otherwise required by law, Homes to Zero will not collect, use or disclose your Personal Information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions.  For example, providing Homes to Zero your Personal Information with respect to a project, is implied consent to contact you and provide further information about our services and recommendations for becoming net zero. 

 

Where appropriate, Homes to Zero will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Homes to Zero wants to use information for a purpose other than those identified above).  In obtaining consent, Homes to Zero will use reasonable efforts to ensure that a User is advised of the identified purposes for which Personal Information collected will be used or disclosed. 

 

The form of consent sought by Homes to Zero may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Homes to Zero shall take into account the sensitivity of the Personal Information and the reasonable expectations of Homes to Zero’s Users.  Homes to Zero will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.  

 

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, you must provide notice to Homes to Zero in writing.    

 

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VII.  LIMITING USE, DISCLOSURE AND RETENTION 

 

As noted above, Homes to Zero does not disclose your Personal Information to third parties, except as provided for in this Privacy Policy.   

 

Subject to the foregoing, only Homes to Zero’s employees, agents, contractors, service providers (and their employees and contractors) with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about you. All such employees and contractors will be required as a condition of employment to contractually respect the confidentiality of Homes to Zero’s Users’ Personal Information. 

 

Homes to Zero will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Homes to Zero. 

 

Homes to Zero will disclose Personal Information without your knowledge or consent if Homes to Zero receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator, or other person with jurisdiction to compel disclosure of your Personal Information. If Homes to Zero receives a written request from a police officer or other law enforcement agency with authority to request access to your Personal Information in the course of an actual or potential investigation into a breach of a law, Homes to Zero’s policy is to provide the requested information. 

 

 

VII. COOKIES & OPT-OUT 

 

Homes to Zero uses cookies to enhance Users’ experiences.  Users’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them.   Cookies help Homes to Zero accurately understand how many consumers are visiting Homes to Zero’s Site, how often Users visit the Site, what content Users are most interested in, and how they prefer to interact with Content on the Site.  For example, a cookie will allow Homes to Zero to remember certain things like your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), your login information, the time and duration of your visits, how you navigated through Homes to Zero’s content and where you exited the Site. To save you the time of re-entering your login information every time you come back to the Site, Homes to Zero may link information contained in a cookie to your email address.  Homes to Zero does not use cookies to retrieve information from your device that Homes to Zero did not originally send in a cookie.  

 

You may disable cookies using your browser's settings. Please consult your browser's help function for information on how to disable cookies.  Note that if you disable cookies, certain features of Homes to Zero’s Site may not function to its fullest potential. 

 

 

VIII. HOW CAN I ACCESS MY PERSONAL INFORMATION 

 

Upon request, Homes to Zero will provide you information regarding the existence, use and disclosure of your Personal Information and you will be given access to that information.  Homes to Zero will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate. 

 

NOTE: In certain circumstances, Homes to Zero may not be able to provide access to all of your Personal Information that it holds.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Homes to Zero will provide the reasons for denying access upon request. 

 

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IX. SAFEGUARDS 

 

Homes to Zero protects your Personal Information by security safeguards appropriate to the sensitivity of the information.  We maintain technical, physical, and administrative security safeguards to safeguard your Personal Information against loss, theft, misuse, unauthorized disclosure and unauthorized access.  This includes limiting access of employees to, and the use of, your Personal Information through the use of passwords and graduated levels of clearance. We take physical precautions to ensure that the computer servers on which your Personal Information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require any third party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them. 

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Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your Personal Information, we cannot ensure or warrant the security of any information you provide to us. 

 

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X. INQUIRIES; CHALLENGING COMPLIANCE 

 

An individual will be able to make inquiries and/or address a challenge concerning compliance with this Privacy Policy to Homes to Zero's Privacy Officer. 

 

Homes to Zero will maintain procedures for addressing and responding to all inquiries or complaints about Homes to Zero's handling of Personal Information. Homes to Zero shall investigate all complaints. All inquiries or complaints involving Homes to Zero’s handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to Homes to Zero's Privacy Officer.  

 

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.  The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If Homes to Zero finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.  

 

For more information, please contact Homes to Zero’s Privacy Office as follows:  

 

E-mail: info@homestozero.ca 

 

Mail: 

Homes to Zero 

Privacy Officer 
10A Busy Street 

Toronto, ON 

M4M 1N8 

 

 

XI. STORAGE OUTSIDE OF CANADA 

 

Your Personal Information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your Personal Information. However, if your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.   

 

 

XII. CHILDREN AND MINORS 

 

The Site is not directed to children under the age of 18 years.  Homes to Zero will not knowingly collect Personal Information about a child under the age of 18.  Homes to Zero does not allow minors (persons who are under the age of majority in their place of residence) to use the services provided on the Site. 

 

 

XIII. EMAIL COMMUNICATIONS 

 

We comply with Canada’s anti-spam legislation (generally called “CASL”), and we will not send you electronic communications in contravention of this law.   We will ensure that each email includes an opt-out feature and instructions on how to unsubscribe if you no longer wish to receive future emails from us. You can unsubscribe if you no longer wish to receive future emails from us. You can unsubscribe using the link included in the email or by using the contact information set forth in the Inquiries section. If you do not expressly consent to receiving commercial electronic communications, we will only communicate with you for the limited purposes permitted under CASL. 

 

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XIV. GENERAL 

 

Homes to Zero maintains the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to the Site..  Any such amendment(s) will be posted on the Site and will be effective as of the date of posting.  If we make any material changes we will notify you by e-mail (sent to the e-mail address specified in your account, if any). You can determine when this Privacy Policy was last revised by referring to the date it was “Last Updated” above. 

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