Last Updated/Effective Date: May 2024

NRT Technology Corp. and its affiliated companies, including TNS Smart Network Inc. (collectively, “NRT Technology”, “we,” “us,” or “our”) respect your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, or other platforms that link to this Privacy Notice (collectively, the “Site”), and in connection with providing our products and services (our “Services”). It also describes your choices about the collection, sharing, and use of your Personal Information.

We may modify this Privacy Notice at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.

1. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry or provide information on our Site, we may collect your contact information. This may include your name, email address, demographic information, and phone number.
• Financial Information – If you make any purchases through our Site or over the telephone, we will collect your financial information, including your name, billing and shipping address, e-mail address, and payment information.
• Location Data – While navigating our Site your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
• Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information.
• Professional or Employment-Related Information – If you apply for employment with us, we will collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
• Communication Information – We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect.

2. How We Collect Your Personal Information

• We May Collect Your Personal Information Directly From You – For example, if you request information or purchase Services from us.
• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

• Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Site. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

  Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

  Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy notice of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

  Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.

  We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

  To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

• Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

3. How We Use Personal Information

To the extent permitted by applicable law, we may use Personal Information to:

• operate the Site and provide support to our business functions;
• fulfill customer requests, such as complete customer purchases;
• protect against criminal activity, claims and other liabilities;
• send you information about our company, products, services, and promotions;
• respond to reviews, comments, or other feedback provided to us;
• support and personalize the Site and our advertising efforts;
• protect the security and integrity of the Site;
• provide customer support;
• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
• meet our contractual requirements;
• comply with applicable legal or regulatory requirements and our policies;
• respond to inquiries related to employment opportunities;
• market, advertise, and provide the Site and our services; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.

4. Sharing of Personal Information

We may share your Personal Information in the following circumstances:

• To Service Providers – When we hire a service provider to help operate the Site or our business, we may give access to Personal Information as necessary to perform the service for NRT Technology. This may include service providers that operate our Site, send our communications, or run our promotions.
• To Business Partners – We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.
• For Legal Obligations – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Service, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of NRT Technology, its users, or the public against harm.
• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.

5. How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law. If you are a California resident, please see the section below titled California Residents for additional information about how long we retain your Personal Information.

6. How We Protect Your Personal Information

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

7. Your Choices and Controls
Depending on where you live (including, where applicable, Canada), you may have the following rights

with respect to your Personal Information.

• Access: You may have the right to know what Personal Information we have collected about you and to access such data.
• Data portability: You may have the right to receive a copy of your information in a portable and readily usable format.
• Deletion: You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
• Correction: You may have the right to correct inaccuracies in your Personal Information.
• Opt out of certain processing: You may have the right to opt out of the processing of your Personal Information for purposes of (a) targeted advertising, (b), the sale of your Personal Information; or (c) profiling in furtherance of decisions that produce legal or similarly significant effect concerning you.
• Withdrawal of consent: You may have the right to withdraw your consent to the processing of your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before its withdrawal. If you refrain from providing your Personal Information or withdraw your consent to processing, some features of our Services may not be available.

  To exercise any of these rights available to you, see Section 13 below.

  To opt out of marketing emails, please email us at privacyofficer@nrttech.com or by following the instructions included in the email or text correspondence. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.

8. International Use of the Site

This Site is hosted in Canada. As a result, the Personal Information that we collect and generate about you may be transferred, stored, or accessed in a destination outside of the province or country from which you access the Site, and such destination may have less strict, or no, data protection laws, when compared to the laws in your country or province, as applicable. Any transfers of Personal Information outside your local province and/or country will be conducted in compliance with the international data transfer restrictions that apply under applicable data protection laws.

9. Children’s Privacy

We do not knowingly target our Services to collect or solicit any Personal Information from children under the age of 18. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacyofficer@nrttech.com or contact us using the information listed in Section 13.

10. Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice.

11. California Residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CCPA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 13.

A. Categories of Personal Information Collected, Used, and Shared

We have collected the following categories of Personal Information for a business or commercial purpose from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in Section 2 above. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. We do not knowingly sell or share Personal Information.

Data Retention: We will retain each category of your Personal Information only for as long as necessary to fulfill the purposes described in the “How We Use Personal Information” section above, unless otherwise required by applicable laws. We consider the following criteria to determine how long we will retain your Personal Information including whether: we need your Personal Information to provide you with the Services you requested; we continue to have a business relationship with you; you have requested information or Services from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; we have an interest in providing you with information about our Services; and we have another business purpose for retaining your Personal Information.

B. Your California Privacy Rights

If you are a resident of California, you may have the following rights:

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Other California Privacy Rights. Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

12. Canadian Residents

This Section 12 applies to our collection and use of Personal Information if you are a resident of Canada, as required by applicable Canadian federal and provincial laws regulating the collection, use and disclosure of Personal Information, including PIPEDA. For a description of what Personal Information NRT collects, how NRT uses your Personal Information, sources from which NRT has collected Personal Information, whether or not NRT shares Personal Information, and NRT protects Personal Information, please see the above sections of this Privacy Notice.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to NRT’s use, storage or disclosure of your Personal Information for certain of the identified purposes at any time by contacting us via the information set forth in Section 15. If you refuse to consent or withdraw your consent, we may not be able to provide to you, or continue to provide to you, certain Services or information.

Under Canadian law, you have the right to access your Personal Information and withdraw your consent at any time. To exercise any of your rights under Canadian law, please contact us using the information provided below in Section 13.

13. Exercising Your Individual Privacy Rights

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

To exercise any of the privacy rights afforded to you under applicable data protection law, please submit a request to us by one of the following methods:

• Calling us at [PHONE]
• E-mailing us at privacyofficer@nrttech.com

  Verification: We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

  We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. We will deliver our written response electronically via e-mail. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes

Appeals: If you not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

14. Changes to this Privacy Notice

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with an updated Privacy Notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.

15. Contact Us

NRT Technology has appointed the Privacy Officer to oversee compliance with this Privacy Notice and applicable privacy laws. If you have any questions about our practices or this Privacy Notice, please contact us at privacyofficer@nrttech.com. You may also write to us at:

NRT Technology Corp.
c/o Privacy Officer
10 Compass Court
Toronto, ON M1S 5R3