Privacy
At NAS, we respect the privacy of our clients and we are
committed to keeping your personal information accurate, confidential, secure
and private. We have adopted the following Privacy Policy to ensure
that NAS continues to meet its commitment to your privacy.
The following sections, read as a whole, comprise the
NAS Privacy Policy:
Introduction
NAS provides a variety of products and services to
appraisers and mortgage lenders and the public, including, but not limited to,
providing real property appraisal and software development and web-based
technology products to mortgage lenders, brokers and appraisers.
In the course of providing these products and
services, NAS may collect certain personal information about its
clients and its customers, with their consent.
"Personal Information" means information about an
identifiable individual client. This may include without limitation, the
individual's name, home address, or other financial information, credit card
information, personal preferences and other information about his or her
family. Personal Information does not include the name, title or business
address, or telephone number of an employee of an organization.
The NAS Privacy Policy is based on, and
complies with, Canada's Personal Information Protection and Electronic
Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in
the Canadian Standards Association Model Code for the Protection of Personal
Privacy. For more information about this legislation, please visit the official
web site of the Privacy Commission of Canada at https://www.priv.gc.ca/en/
This Privacy Policy describes the ten principles that NAS
follows to ensure that we protect your Personal Information when we collect,
use, or disclose it in the course of carrying on commercial activities in
Canada. All of our employees who have access to Personal Information must
adhere to the NAS Privacy Policy and related procedures.
The ten
principles of privacy
The following ten principles govern our actions as they
relate to the use of Personal Information:
Principle 1
- Accountability
NAS is accountable for all Personal Information in
its possession or custody, including Personal Information disclosed to third
parties for purposes of providing services requested by our clients, employees,
or you.
Principle 2
- Identifying Purposes
NAS collects personal information supplied to it by
its clients, including financial institutions, brokers, lawyers, among others,
that is required to permit NAS to provide the services requested. We are
obligated to protect the confidentiality of your Personal Information, and we
are prohibited from doing anything with your Personal Information that we have
not been authorized to do by our clients or you, and it is our policy to treat
your personal information in a manner consistent with your financial
institution's privacy policy.
NAS relies upon such financial institutions, all of
whom are bound by PIPEDA, to obtain their customers' consent or rely upon an
exemption to PIPEDA, before providing NAS with their customers' personal
information. NAS informs its clients of the purposes for which it is
collecting any personal information, before or at the time the information is
collected.
Principle 3
- Consent
NAS will obtain consent from its clients or you before or
when it collects, uses, or discloses your Personal Information.
Consent can be express, implied, or given through an
authorized representative. A client or you can withdraw consent at any time,
with certain exceptions. NAS, however, may collect, use or disclose Personal
Information without the client's knowledge or your consent in exceptional
circumstances where such collection, use, or disclosure is permitted or
required by law.
Principle 4
- Limiting Collection
The information collected by NAS will be limited to those
details necessary for the purposes it has identified to the client, to you, or
to perform the requested services. Information will be collected by fair and lawful
means.
Principle 5
- Limiting Use, Disclosure and Retention
Personal Information will only be used or disclosed for
the purpose for which it was collected unless the client or you have otherwise
consented, or when it is required or permitted by law. Personal Information may
only be retained for the amount of time needed to fulfil the purpose for which
it was collected or to fulfil contractual obligations with respect to record
retention.
In certain exceptional circumstances, NAS may have
a legal duty or right to disclose Personal Information without knowledge or
consent from our client or you with respect to matters that concern the
company's or the public's interest.
Principle 6
- Accuracy
NAS will keep Personal Information as accurate,
complete, and current as necessary to fulfil the identified purposes for which
it was collected. Clients or you may have this information amended where it is
found to be inaccurate or incomplete.
Principle 7
- Safeguarding Personal Information
Personal Information is safeguarded using measures
appropriate to the sensitivity of the information.
Principle 8
- Openness
NAS will make information available to its clients
and the general public about the policies and procedures NAS uses to
manage Personal Information. Clients and the general public have access to this
information through our web sites, or through alternate means if requested.
Principle 9
-Access
Upon written request, you will be informed of the
existence, use and disclosure of your Personal Information, and will be given
access to it, upon notification to our client of your
request. NAS will respond to such requests as efficiently as
possible. If NAS is prohibited from providing such access we will explain
the reasons for the lack of access, except where prohibited by law.
Principle 10
- Addressing Complaints and Suggestions
Clients and members of the general public in respect of
whom NAS has collected, used or disclosed personal information may
challenge NAS' compliance with this Privacy Policy. NAS has
policies and procedures to receive, investigate, and respond to complaints and
questions regarding this Privacy Policy and our collection, use, and disclosure
of Personal Information. You may contact NAS Privacy to express any concerns or
to request access to your Personal Information. The contact information is
provided at the end of this document.
Application
of the Ten Privacy Principles - How we treat your personal information:
The kind of information we collect:
NAS gathers and uses Personal Information in order to
provide its clients or you with the products and services requested, namely:
Credit card information for the purpose of
processing payment for appraisal requests is accessed only by authorized employees
and is used only for the appraisal request you are submitting. NAS
does not retain or store your credit card information on any of our systems or
databases. Online payments are
passed via a secure socket layer to a payment processor where your information
is tokenized (whereby a random number is generated to represent your payment).
The payment processor is PCI compliant which ensures that your information is
being handled in accordance with industry security standards.
All information that you do provide us with is securely
maintained and kept strictly confidential. This Privacy Policy does not apply
to aggregated data from which it is not possible to determine the identity of a
specific individual. NAS reserves the right to use aggregated data in any way
that it determines appropriate.
How Your
Information Is Used At NAS Personal Information is used for three
general purposes: 1.
To communicate with you in
order to provide you or your representative with our products and services. 2.
Transactional information to
monitor our level of service and report back to our clients to ensure
satisfaction with the provision of such services. 3.
We will only use Personal
Information for the purpose that we have disclosed. If we want to use your
information for a different purpose, we will notify you and our clients to
obtain consent. We do not share, swap or sell any mailing lists or
personal information files to any third parties. When Can We
Disclose Your Personal Information? NAS is obliged to keep your Personal Information
confidential except under the following circumstances:
i.
When Authorized by our Clients
Many of the
services offered by NAS require us to obtain Personal Information
about you in order to perform the services we have been engaged to provide. We
will always obtain consent, and we will never use the Personal Information for
purposes other than those we have told our clients about. You may
withdraw your consent at any time, subject to any legal implications (which we
will inform you or your financial institution about). If you withdraw your
consent to use or disclose certain Personal Information, we may be unable
to continue to provide all or part of the requested services.
ii.
When Required by Law The type of
information we are legally required to disclose usually relates to government
tax reporting requirements. In some cases, however, such as under a court
order, we may be required to disclose certain information to persons specified
in the court order. We will only provide the specific information requested and
only upon being satisfied that the authorities have legitimate grounds to
request the information.
iii.
When Permitted by Law The
legislation has provided certain situations where NAS is legally permitted to
disclose Personal Information without your consent. Examples include situations
involving the collection of debt in arrears, medical emergencies, or suspicion
of illegal activities. With Whom We
May Share Your Information
i.
NAS Employees In the
course of daily operations, access to sensitive Personal Information is limited
to those employees with a legitimate reason for accessing it. As a condition of
their employment, NAS employees are required to follow all applicable laws and
regulations, including this Privacy Policy. Unauthorized
use or disclosure of confidential client information by
a NAS employee is prohibited and may result in disciplinary measures.
ii.
NAS Affiliates In order to
better serve our clients, we may share some of your Personal Information with our
affiliates. We will only do this with your express consent and you may withdraw
this consent at any time. The procedure for withdrawing consent is outlined
below under the section "Opting Out".
iii.
NAS Third-Party Suppliers As you may
know, we may engage and coordinate third-party suppliers to provide certain
services offered through NAS. Such
suppliers are only given the information that is needed to provide the specific
service for which we contract them to provide. Suppliers are obliged to protect
the confidentiality of your Personal Information, and they are prohibited from
doing anything with this information that we have not authorized them to do.
They are required to treat your Personal Information in a manner consistent
with the NAS Privacy Policy.
iv.
Sale of business We may
transfer your personally identifiable information to a third party in
connection with a sale, merger, or other disposition (whether of assets, stock,
or otherwise) of our business. How We
Safeguard Information NAS has extensive controls in place to maintain the
security of its information and information systems. Client files are stored
according to the sensitivity of the information contained therein. NAS uses network security tools, such as firewalls to
safeguard personal information. We also use unique identifiers to identify,
authenticate and authorize any employees, who can access, view or handle your
personal information. We use a minimum of 256-bit encryption to store
information when required and we encrypt data thru HTTPS/TLS1.2 when we
transport or communicate information on open communication channels to another
party. Physical access to areas where personal information is
gathered, processed or stored is limited to authorized employees. When you telephone a NAS employee to speak about your
file, you may be asked for some personally identifying information. This type
of safeguard is designed to ensure that only you, or someone authorized by you,
has access to your file. Website
Security In order to serve you better, NAS offers clients access
to certain information through its websites. www.nationwideappraisals.com
provides general information about NAS and the products and services it offers. Accessing
and Amending Your Information As a client, you have the right to access the Personal
Information we keep in your file and you have the right to verify or amend the
information if it is shown to be inaccurate. If you would like to view the
personal information held in your file or to make a change to that information,
please make a written request by sending an e-mail to appsupport@nationwideappraisals.com Anonymous
Information and "Cookies" NAS may collect anonymous information about you. This
means that the information collected cannot be traced back to a specific
person. For example, our web servers may record certain information
automatically when you visit NAS web sites. This information is collected using
"cookies" and might include the pages you visited, your IP (Internet Protocol)
address and other site usage statistics. This anonymous information is used for
research and analytical purposes only (like evaluating how many visitors our
web sites receive or which pages they visit most often). It does not reveal any
Personal Information about you, the user. This aggregate data may be disclosed
to third parties, but never with personally identifying information. "Cookies" "Cookies" are small text files that contain a unique
identification number that allows our computers to identify your web browser
(but not you) each time you visit one of our web sites that uses cookies. The
information helps NAS improve the functionality of the site and enhance
the navigation and security of your session. Most major web sites use this technology and most
browsers are set up to accept them. You may configure your browser to notify you when you
receive a cookie, and you may refuse to accept them entirely. However, if you
refuse to accept cookies, you may limit the functionality that we can provide
to you when you visit our site.