What personal information do we collect?
- We collect information directly from Users, including name, phone number, property address, approximate property value, device tokens, email address and passwords. Users may also provide additional information, such as when they choose to give a Testimonial.
- We collect information directly from Agents, including name, real estate license number, device tokens, email address, photo, biography, services they offer, locations where they operate, and payment information if the Agent chooses a paid service.
- The Application also collects location information, if permission is granted by the User or Agent.
Why do we collect personal information and how is it used?
- Information provided to us by Users and Agents is collected and used to facilitate connections between them.
- We also use information provided by Agents to verify identity and licensing.
- We use email addresses to send Notifications to Users and to contact Agents.
- The information that we collect about devices and use of the Application is used in aggregate and de-identified form to evaluate and improve our services, as well as to send send push notifications.
Is personal information shared or disclosed?
- Agents’ names, license numbers, photos, biographies, service descriptions and locations of operation are available to all Users, so that Users can select an Agent who they want to connect with.
- Property addresses and approximate property values provided by Users are available to all Agents. If a User decides to connect with an Agent, the User’s name and phone number will also be provided to that Agent.
- Users may provide additional information to Agents directly. Although we recommend best practices, we cannot control the collection, use or disclosure of such information.
- We also use certain Service Providers who may have access to the information we collect, and we may disclose certain information in the event of a Business Transaction.
How do we protect personal information?
- We have implemented Safeguards to protect personal information under our control, including using appropriate authentication procedures, limiting administrative privileges, and transferring all data over HTTPS.
What are the risks?
- Although we take steps to safeguard the personal information under our control, “perfect security” does not exist online. We cannot guarantee the security of information posted or transmitted using the Application. It is possible that third parties may unlawfully intercept or access such information.
What are your choices?
- Users can delete the Application from their device at any time. Users and Agents may advise us, at any time, that they no longer want their information displayed through the Application. We may keep the information (but not display it) for a certain period of time to protect our rights and interests.
- Users and Agents can also turn off location tracking and notifications.
What else should you know?
- We use cloud Service Providers to store the information that we collect. This means that your information may be transferred to, or stored in, another country and accessible to foreign courts, law enforcement and national security authorities.
- You can contact us with questions, complaints or to access your personal information.
Personal information is any information that directly or indirectly identifies you. It does not include information that is publicly available, as defined by applicable laws.
Who Are We?
Nobul offers, among other things, an online marketplace connecting real estate agents and consumers, including related online services. Such connections are facilitated through our website, online service and/or mobile application (collectively, the “Application”).
What Personal Information Do We Collect?
The information collected by us depends upon whether you are a real estate agent looking to connect with potential clients (“Agents”) or a person who is looking to buy or sell real estate (“Users”). However, the Application automatically collects certain usage and device information about both Agents and Users.
- Information about Users
When Users register for the Application, they are required to provide their name, phone number and email address, as well as create a password to access their account. Users who are looking to sell their property are also required to provide the address for the property and the approximate property value.
Some Users may choose to provide additional information. For example, Users can upload pictures of their property, contact customer support with questions or concerns, and provide feedback on Agents including rating individual Agents (“Testimonials”).
- Information about Agents
When Agents register for the Application, they are required to provide their name, license number, and email address.
Agents may also choose to upload additional information, including their photograph and biography, as well as information about the services the Agent offers and the locations the Agent operates in. In addition, if an Agent chooses to sign up for a paid service, the Agent will be required to provide a billing address and credit card information.
- Usage and Device Information
Information respecting device location is collected by the Application, if permission is granted by the User or Agent, as applicable (“Location Information”). Collection of Location Information is optional. The User or Agent can choose not to grant permission to access Location Information and still use other features of the Application. Collection of Location Information can be turned off at any time.
Certain information about how Agents and Users use the Application is also collected automatically. This includes:
- How Users and Agents are using the Application, including people and links you interact with, as well as content you access or view and features you use. For example, we collect data related to which properties each Agent views, and which Agent profiles each User views.
- Information respecting which Users connect with which Agents.
- Log data that your browser sends whenever you visit a website or mobile application, including (as applicable) your Internet Protocol (IP) address, the address of the web page that you visited before using the Application, your browser type and settings, navigation history and pages requested, the date and time of your use of the Application, information about your browser configuration and plug-ins, language preferences and cookie data.
- Information about the device that you are using the Application on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, device tokens, and crash data.
Why Do We Collect Personal Information and How Is It Used?
We collect the personal information that is needed to facilitate and enhance the functioning of our Application. More specifically:
- User Personal Information
Property addresses and approximate property values provided by Users are used to allow Agents to see the types of properties that Users have posted on the Application. The User’s name and contact information is not posted with the property address and value, and is only provided to an Agent if the User chooses to connect with him/her, as described below.
Property address may also be used by Nobul to determine which properties will be displayed to specific Agents.
User email addresses will also be used to notify Users of changes to the Application, service information (such as security and fraud notices), and information that may be relevant to them such as changes in market conditions that indicate it may be a good time to sell their property (“Notifications”). Users can choose not to receive email Notifications, or can change their mind at any time by “unsubscribing”, except for service notices.
Additional information that Users chose to provide is used only for the purposes that it is collected. For example, information provided by Users who contact customer support will be used to respond the User’s questions or concerns.
Testimonials will be used to assess User satisfaction with individual Agents, and may also be used to identify improper activities by any Agents. Ratings provided by Users may be aggregated or analyzed to create an overall “score” for each Agent.
- Agent Personal Information
Agent Personal Information is collected and used for the purpose of allowing Users to evaluate the services that the Agents are offering and select Agents who they want to connect with.
Nobul also uses the identity information and license numbers provided by Agents to verify their identity and confirm that they are properly registered and licensed to sell real estate in the relevant jurisdiction. This verification is done by checking the information provided by the agent against publically available databases.
Nobul also uses Agents’ email addresses to contact the Agents, including to provide information respecting changes to the Application and any new features or services that are added to the Application. Agents can choose not to receive such emails, or can change their mind at any time by “unsubscribing”. Email addresses will also be used to send service-related notices such as security and fraud notices.
If an Agent subscribes for a paid service, the information provided by the Agent will be used to process payments and for invoicing purposes (if applicable).
- Usage and Device Information
The usage and device information described above is collected, aggregated or de-identified, and then used by us to evaluate how and where Users and Agents are using the Application, and determine what features are most and least popular. We analyze this data to determine how we can improve the functioning of the Application.
We may also use this information to tailor the content delivered to Users and Agents. For example, if an Agent only (or primarily) views properties in a certain neighborhood, the Application may primarily deliver content related to properties in that neighborhood. Location information is also used to tailor the content that is delivered to the User or Agent, based upon relevance to the person.
Usage and device information is also used for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use.
To the extent that our website or the Application contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.
Is Personal Information Shared or Disclosed?
Your personal information may be accessed by or disclosed to employees of Nobul who have a need to know such information. Such employees may include executives, communications and marketing staff, and our development team, depending upon the information they each require to perform their job duties.
In addition, in order for the Application to function:
- Property addresses and approximate property values posted by Users can be accessed by all Agents.
- Agents’ names, license numbers, photos, biographies, services offered, and location(s) the Agent services are available to all Users, so that Users can select an Agent who they want to connect with.
- If a User decides to connect with one or more Agents, the User’s name and phone number will be provided to such Agent(s).
Nobul does not permit Agents to use the User information obtained by them through the Application for any purpose except to connect with the User as contemplated by the Application.
We do not sell your personal information, or disclose it to any third party marketers. However, information may be shared or disclosed to third parties in the following circumstances:
- Service Providers
There are certain services supplied to us by third parties. Currently, the only service providers used by Nobul, who may have access to or possession of the personal information that we collect, store and process, are:
- Firebase/Google for Realtime Database, Hosting, Authentication, Cloud Storage, Cloud Messaging and Cloud Functions; and
- Intercom for data analytics.
Please note that, given the nature of cloud services, personal information of Users and Agents may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored. As our business grows and the functions of the Application develop, we may choose to use other service providers in Canada or elsewhere.
When we engage a third party service provider to do work for us, we confirm that its privacy and security standards meet our requirements and use appropriate contractual measures to protect any personal information that is shared with such persons.
We may be involved, from time to time, in transactions to sell all or part of our business or assets or merge with other businesses. Certain information may be relevant to such transactions, in which case we may disclose this information to other parties involved in the transaction. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure.
There are circumstances where we may collect, use or disclose personal information without notice or consent when required by law or lawful authority. For example, from time to time, we may be compelled by legal action to release information (e.g., statutory reporting obligation, search warrant, court order, bankruptcy or insolvency proceedings etc.). In certain circumstances, we may also be permitted by law to collect, use or disclose information without the consent of the individual concerned. For example, we may disclose personal information without consent to investigate a potential breach of law or contract, to collect on a debt, or in certain emergency situations that threaten the life, health or security of an individual.
How Do We Protect Personal Information
We protect the personal information of Agents and Users using physical, technological and organizational safeguards, including but not limited to:
- validation that all requests are made by authenticated users;
- limiting administrative privileges to those who require such privileges to perform authorized duties/services;
- all connections to the Application are encrypted using SSL;
- servers are protected by firewalls;
- all data is transferred over HTTPS;
- no caching of personal information on device by Application when the Application is not in use; and
- our employees receive training respecting secure and confidential handling of personal information.
Also, the Application data is stored on Firebase/Google. Firebase’s terms are available here (broken down by product): https://firebase.google.com/terms/ . Nobul currently uses the following Firebase products: Realtime Database, Hosting, Authentication, Cloud Storage, Cloud Messaging and Cloud Functions.
Although we take the steps outlined above to safeguard the personal information under our control, “perfect security” does not exist online. We cannot guarantee the security of information posted or transmitted via the Application. It is possible that third parties may unlawfully intercept or access such information. If you think someone is impersonating Nobul, that there has been a breach of your privacy, or you believe that you are the victim of fraud, please contact us as soon as possible.
Retention of Personal Information
We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for legal purposes. More specifically:
- Agent Information.
Information provided by Agents is generally retained until the Agent notifies us that s/he no longer wants to be registered on the Application. After Nobul receives such notification, we will promptly (and no longer than 30 days after receiving the notification) ensure that the Agent’s information is no longer displayed or accessible to Users. However, we may retain the Agent’s information for up to three years for legal purposes, including for the protection of Nobul’s rights and interests.
- User Information.
Information provided by Users is generally retained until Nobul becomes aware that the property listed by the User has sold. However, if a User’s account is inactive for 120 consecutive days, Nobul may deactivate the account so that we are not unnecessarily retaining excessive personal information.
Users can also delete the Application or notify us that they no longer want their personal information to be used or displayed on the Application, at any time. After Nobul receives such notification, we will promptly (and no longer than 30 days after receiving the notification) ensure that the User’s information is no longer displayed or accessible to Agents.
We may retain a User’s information for up to three years after it is no longer used or displayed on the Application, for legal purposes, including for the protection of Nobul’s rights and interests.
Users and Agents can contact us at any time, for reasons such as:
- To access, correct or update their personal information;
- To obtain additional information about Nobul’s use of service providers outside Canada;
- To withdraw consent to receiving Notifications; or
- To withdraw consent to continued use and disclosure of personal information.
You can contact us by email at firstname.lastname@example.org, or by mail sent to:Nobul Corporation
Suite 100 – 379 Adelaide St. W.,
Toronto, ON, Canada
Attention: “Legal Counsel”