PAUL DAVIS RESTORATION INC.
Last updated: September 15, 2023
This Policy applies to information we collect from you in any way, including through our website, by email and other electronic messages, when you contact us by telephone, when you submit your information to any of our representatives in person, and when you interact with our advertising and applications on third-party websites and services, if those applications or advertising direct you to this policy.
This Policy does not apply to any information that is anonymous or does not allow an individual to be identified.
This Policy does not apply to Personal Information about Paul Davis employees, employment candidates, contractors, applicants, or consultants.
a) What Is Personal Information?
This Policy applies to information that identifies a person or could be reasonably associated with them.
“Personal Information” is any information that identifies you or could be reasonably associated with you. Personal Information can include contact information such as your name, email address, home address, country of residence and contact phone numbers, information provided to us in connection with our products and/or information collected automatically when you interact with us online, through our website, social media or otherwise.
Personal Information does not include “business contact information” such as a person’s name, job title, business address, or business telephone number, which are used in the context of their work within an organization. It does not include de-identified or aggregate information or certain publicly available information.
b) Personal Information of Children
Our website is not intended for anyone under the age of majority. We will remove any information about a minor if we become aware of it.
Our products, services, websites, and activities are not directed to anyone under the age of majority (18 years in most jurisdictions), and we do not knowingly collect, maintain, or use Personal Information from children. If we become aware that we have collected the Personal Information of children, we will promptly take steps to delete such Personal Information. If you discover your child has provided us Personal Information without your consent, please contact us.
3. How we collect Personal Information
We collect the information we need in order to fulfill the purposes for which it is collected. We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users.
Information is collected directly from you and through tracking technologies, and may also be obtained from third parties.
We limit the collection of Personal Information to what is reasonably required to fulfill the purposes for which it was collected.
We collect Personal Information in a variety of ways, from and about users of our website, including:
- information by which you may be personally identified, such as name, address, e-mail address, telephone number, banking or financial account information, credit or debit card number;
- information that is about you but individually does not identify you, such as insurance information, property information, traffic data, location data, logs, referring/exit pages, date and time of your visit to our website, error information, clickstream data, and other communication data and the resources that you access and use on the website; and/or
- information about your internet connection, the equipment you use to access our website and usage details, including IP address, mobile network, operating system, and browser.
This information is collected:
- directly from you when you provide it to us, for example through our website, when you are interacting with us through social media, when you contact us through call centers or other support and communication channels, when you have direct in-person contact with our representatives, or when you purchase products or services;
- automatically as you navigate through the website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
- from others, for example, our affiliates or franchisees, service providers, customers or insurance companies, which may enter your Personal Information.
As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
- Usage and Equipment Information: Information about your equipment, browsing actions, and patterns, for example, details of your visits to our website, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our website, error information, clickstream data, and other communication data and the resources that you access and use on the website.
- Device Information: Information about your computer, mobile device, and Internet connection, specifically your IP address, domain names, operating system, browser type, and application version information.
- Location Information. Location information of your device.
Automatic Tracking Technologies
The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our website and to deliver a better and more personalized service by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences; and
- recognize you when you return to our website.
We may send text files (e.g., “cookies” or other cached files) or images to your web browser. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customize your experience on this website and to monitor use of this website.
We may also use other technologies to receive and store certain types of information whenever you interact with our website through your computer or mobile device.
The website may make use of "per session" and "persistent" cookie technology. Per session cookies track information during an open session and are stored only temporarily in your computer's memory. Persistent cookies are deposited on a visitor's computer until they expire or until the visitor deletes the cookies. Information from these cookies help Paul Davis analyze traffic patterns to the website, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers and operating systems that the website's visitors use. Paul Davis uses this information to facilitate and enhance your online visits.
In addition, Paul Davis may use non-Personal Information to create aggregate tracking information reports regarding website user demographics and website traffic patterns, including for example Facebook Pixels and LinkedIn. If any such information is linked with website users' Personal Information, preferences, behaviour or characteristics, all of the linked information is treated as Personal Information and will be used and disclosed only in accordance with this Policy and applicable law.
4. How we use Personal Information
We use your personal information for various authorized purposes, including to:
- provide our website and its contents to you;
- provide you with information;
- provide you with products and services;
- fulfill our contractual obligations and enforce our rights arising from contracts;
- notify you about changes;
- maintain and improve our website, products and services;
- respond to your inquiries and complaints; and
- any other purpose with your consent or as described when you provided the information.
We use Personal Information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law.
We use information that we collect about you or that you provide to us, including Personal Information:
- to present our website and its contents to you;
- to provide you with information or services that you request from us or as requested by a third party on your behalf or otherwise with your consent;
- to provide you with information, products, or services that you request from us or that may be of interest to you;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- to notify you about changes to our website or any products or services we offer or provide though them;
- to maintain, secure, or improve our website, products and services;
- to respond to your questions, inquiries or complaints;
- to personalize and generally enhance your customer experience with us;
- in any other way we may describe when you provide the information;
- for any other purpose with your consent; and
- otherwise as may be permitted or required by law.
- to provide you with information or services that you request from us or as requested by a third party on your behalf or otherwise with your consent;
Your Personal Information is accessed and used only by those who require access to it in order to fulfill the foregoing purposes. Those who have access to it within our organization have a specific role to perform in respect of such purposes, and are made aware of the responsibilities applicable to them in their handling of Personal Information.
The chart below outlines the some of the specific categories of Personal Information we may collect, and describes categories of sources from which we may obtain it, explains the main purposes for collecting it, and identifies third parties with whom we may share this information.
|Categories of Personal Information we may collect||Categories of Sources||Purpose(s) for Collection of Personal Information||Categories of Third Parties with Which Personal Information is Shared|
|Personal Identifiers – such as name, postal address, Internet Protocol address, email address, social insurance numbers, emergency contact information, or other similar identifiers||Franchises; Individuals directly||Providing products and services Responding to consumer inquiries Marketing Security processes||Service providers (vendors that provide services to us in connection with the operation of our business, and can include vendors that process payments, verify customer information, manage customer information, job cost estimator and job tracking tools, provide security services, cloud-based data storage, host our webpage and assist with other IT-related functions, advertising and marketing our products and services and those of our affiliates, provide analytics information, facilitate conferencing, legal and accounting services, among other business functions). Franchises; Insurance companies that retain us on behalf of their policyholders.|
|Professional or Employment information- such as information about past employers, work history, skills, educational background, and references||Referral sources: Individuals who submit franchise applications.||Recruiting Evaluation of franchise applications.||Service providers|
|Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Franchises; Individuals interacting with our website and mobile apps||Providing products and services Internet marketing||Franchises Insurance companies that retain us on behalf of their policyholders Service providers|
|Internet or other electronic network activity information, including browsing and search history||Individuals interacting with our website and mobile apps||Security processes Providing products and services Internet marketing|
|Education information||Individuals who submit franchise applications Referral sources||Evaluation of franchise application||Service providers|
|Audio information||Individuals who call our customer service line||Quality assurance and training|
5. Canada’s Anti-Spam Law (CASL)
We take measures to ensure we only communicate with you in ways you have accepted.
If we have your consent to send you communications, we will use your contact information to do so, unless you withdraw your consent.
If you have withdrawn your consent, we may continue to communicate with you in relation to products or services you have purchased, or as may be otherwise necessary in the context of our relationship with you.
We take appropriate measures to ensure we only communicate with you in the manner that you have accepted. As such, we may request your express consent to communicate with you about our offers, promotions, products, services and opportunities that may be of interest to you.
If we have your consent to send you communications by email, text message or other means, we will use the contact information you have provided for these purposes in order to send them to you.
You can withdraw your consent to receive commercial electronic messages from us at any time by following the unsubscribe process described in any communication you receive from us. Your request will be honoured promptly and in accordance with applicable law. You can also adjust your preferences where applicable.
If you have withdrawn your consent to receive our communications through any particular means or with respect to any category of subject matter, we may continue to communicate with you in relation to products or services you have purchased, or in relation to your account or otherwise as may be required or permitted in the context of our relationship with you.
6. How we share Personal Information
We do not share, sell, or otherwise disclose your personal information except as outlined in this Policy and otherwise permitted or required by law.
We disclose your personal information to our affiliates.
We also disclose your personal information to a few third parties, including:
- our third-party service providers that we use to support our business;
- to comply with our legal obligations; and
- to enforce our rights.
We share Personal Information as described at the time of collection, or as otherwise permitted or required by applicable law.
Otherwise, we do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Policy.
We may disclose Personal Information to our affiliates and to contractors, service providers and other third parties we use to support our business. These entities may provide IT and infrastructure support services, customer service, advertising, marketing, analytics and payment processing services.
We may disclose aggregated information about our users, publicly available information, and information that does not identify any individual, without restriction.
Privacy law permits or requires the collection, use and disclosure of Personal Information without the knowledge or consent of the individual in certain circumstances. We reserve the right to collect, use and disclose your Personal Information in these circumstances without your knowledge or consent, including in one or more of the following circumstances: in order to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business or others.
a) Transfers to Affiliates and Service Providers
We may share your personal information within our group of companies or with third party service providers. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your personal information.
We may share your Personal Information within the FirstService group of companies or with our service providers (companies operating on our behalf) for the purposes described in this Policy and in accordance with applicable law. We are committed to not selling your Personal Information to any organization or person.
When we may disclose or transfer your Personal Information to an affiliate or a third party to provide any services or fulfill a contractual obligation, we use appropriate measures, such as including relevant contractual provisions, to ensure that such parties will limit the use of your Personal Information.
Many of the services of Paul Davis Restoration are provided through independently-owned and operated franchises as well as through company-owned outlets. In that regard, we provide a number of services to support our franchises and company-owned outlets. As such we may use your Personal Information in order to provide that assistance.
c) Transfers outside Quebec and Canada
We may process your personal information outside of your home province or country, including in the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your personal information.
We are sometimes required to use service providers to store, handle or process Personal Information who may be located in the United States of America or elsewhere outside of the Province of Quebec or Canada. Accordingly, your Personal Information may be transferred throughout Canada or outside of Canada. The laws of those other places will then apply to that information, including laws that may permit or require disclosing that information to government, courts and law enforcement. In such cases, our policy is to require those parties to at all times provide adequate privacy protection to the information, by contractual or other means.
By using and accessing our website, you agree and consent to the transfer, processing, and storage of your Personal Information on servers which may be located outside of the province in which you reside.
7. Your consent
We obtain your consent before collecting, using or disclosing your personal information, for specific purposes relating to the expected uses of the information.
Your consent may be withdrawn at any time.
We assume all information you submit is about you. Please do not submit Personal Information other than your own.
We obtain your consent before collecting, using, or disclosing your Personal Information, either in writing or verbally. In certain cases, your consent may be implied through your conduct. Express consent would arise if you specifically consented to a particular dealing in your Personal Information. Express consent can be given orally, electronically or in writing.
Implied consent can be inferred from the circumstances and, in particular, where the uses and disclosures are readily apparent at the time we collect the Personal Information. For example, if you send us an email requesting certain information, we will use the email address in your email to send you the requested information without asking you if we can use the email address for that purpose, your consent will be implied in those circumstances. As well, we will assume your consent to the collection, use and disclosure of your Personal Information for a particular purpose if you voluntarily provide the information for that purpose.
By submitting Personal Information to us, you are providing your consent to the collection, use and disclosure of Personal Information for the purpose for which it is collected and as set out in this Policy, and as may be disclosed to you when the information is collected.
If you do not consent to the collection, use and disclosure of your Personal Information in accordance with this Policy, do not provide your Personal Information to Paul Davis.
Certain functionalities, products and services may not be accessible to you if you do not provide the required Personal Information.
Your consent may be withdrawn at any time, by contacting our Privacy Officer, subject to any legal and contractual requirements and reasonable notice.
If you provide Personal Information of another person, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Policy.
8. Choices about how we handle your Personal Information
You can make certain choices about the way your personal information is used by us, and with respect to tracking technologies.
You can make certain adjustments to privacy settings on your browser and devices, as described below; however, they may impact your ability to use some of the features on our website.
You can also withdraw your consent to our use of your Personal Information at any time, by contacting the Privacy Officer.
You can opt-out of the use of Google Analytics by clicking on the following link: https://tools.google.com/dlpage/gaoptout.
You may delete or disable certain settings of website tracking technologies at any time using your browser or device.
9. Data Storage
We store your data in a secure manner.
Data may be stored outside your province of residence where such storage is permitted by law.
We hold the information we collect in electronic and/or paper form. Personal Information is maintained at our offices or on our servers (or those of our service providers) and is accessible by authorized employees, representatives and agents who require access for the purposes described in this Policy.
Your Personal Information is stored in secured locations and on servers controlled by Paul Davis, located either at our offices or at the offices of our service providers or in the cloud, as applicable. Your Personal Information may be processed, accessed and/or stored in Quebec, elsewhere in Canada or in another jurisdiction, and will be subject to the laws of that jurisdiction. Please see item 6.c) above for more information in this regard.
10. Data Security
We implement appropriate safeguards to ensure the protection of your personal information.
Information transmitted over the internet is not completely secure, but we do our best to protect your personal information.
We take the security of your Personal Information very seriously and are committed to protecting your privacy by employing security safeguards that are appropriate to the sensitivity of the information.
We have implemented and maintain administrative, technological and physical measures intended to safeguard Personal Information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. These measures include: restricting access to files containing Personal Information, firewalls, encryption, and other security software, password protection and organizational security policies. Our security program is implemented and maintained in accordance with applicable law and relevant standards.
The safety and security of your information also depends on you. Where you have chosen a username and password or other authentication credentials for access to certain parts of our website, you are responsible for keeping this information confidential. We ask you not to share this information with anyone.
Please note, however, that we cannot absolutely guarantee the security of any information transmitted to us or stored by us or on our behalf; you provide it at your own risk. While we take appropriate measures to protect Personal Information, there is always a risk that it may be lost, intercepted or misused, including by destructive programs.
11. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected. We may also keep it to comply with other legal requirements.
We retain information for as long as necessary to fulfill the purposes for which we collected it.
We may also retain your Personal Information otherwise as permitted or required by applicable law, including for purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
Under some circumstances we may de-identify or anonymize your Personal Information so that it can no longer be associated with you. We may use de-identified or such anonymous data for any legitimate business purpose without further notice to you or your consent, including by aggregating it with other data.
We delete information securely as soon as reasonably practical after a valid deletion request, or after the end of the retention period described above.
12. User Generated Content
When you submit content that can be accessed publicly, it may be used by others; we are not responsible for any such use.
Our services may, from time to time, contain interactive areas where you may submit comments or other content (including information about the user that might be displayed in the user’s public profile within an online community) that may be visible to others. Users should be aware that when they voluntarily disclose Personal Information in content submitted for posting or publication, the information can be read and used by others. This may result in unsolicited messages from other parties. We make no representations and undertake no obligations as to the security or use of information you voluntarily include when submitting content.
13. Third Party Websites and Social Media Platforms
When you access third party websites through links on our website, their privacy policies will apply to any personal information made available to the operators of such websites; we are not responsible for privacy in this context.
When using social media platforms linked to our website, content and privacy matters are subject to the terms those platforms, and are not within our control or responsibility.
We make available on our website various social media plug-ins, including Facebook, Instagram, Pinterest and YouTube. You should be aware that any information you disclose while using these applications can be viewed, collected and used by other users of those social media platforms. We have no control over the information shared through these applications and therefore we are not responsible for the use, misuse or misappropriation by another user of any Personal Information you disclose while using these applications. For more information about social media plug-in policies and impact on your privacy rights, please consult the appropriate social media website’s policies.
14. Requests for Access to Personal Information
You are allowed access to your personal information upon request via the Contact Form.
It is your responsibility to ensure that the personal information we have about you is accurate and up-to-date.
In accordance with applicable privacy laws, you have the right to access any Personal Information we hold about you, subject to any legal restrictions. Upon submission of a request via the Contact Form, we will verify your identity or authority to make the request by a two-step verification process, and provide you with access to your Personal Information within a reasonable timeframe, in compliance with applicable laws.
On your written request we will provide you with:
- access to your Personal Information (if any) under our custody or control;
- information about the purposes for which your Personal Information under our custody or control has been and is being used by us; and
- the names of third parties to which, and the circumstances in which, your Personal Information has been and is being disclosed by us.
All requests may be subject to reasonable fees and disbursements. If any fees apply to providing you with extracts of our records of your Personal Information, you will be notified in advance. Where permitted by applicable law, we may require advance payment of a deposit or the entire costs of responding to a request for access to Personal Information.
It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your Personal Information or need to update it, please let us know by contacting our Privacy Officer as outlined below.
15. Requests for Correction of Personal Information
On request by you, we will correct errors or omissions in your Personal Information where that information is in our custody or control. Upon submission of a request via the Contact Form, we will verify your identity or authority to make the request by a two-step verification process,
If you make such a request, we will either:
- correct the Personal Information and, if reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect information; or
- decide not to correct the Personal Information if the information on record is correct, but we will retain a record that a correction was requested but not made.
Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
We will post any changes to our Policy on our website. If we make material changes, we may notify you of such changes through your contact information and invite you to review the changes.
We may from time to time modify this Policy. We will promptly make any changes available on the website. If we make material changes to how we treat Personal Information, we will notify our customers for whom we have an email address. These notifications may be sent by email and/or displayed on the home page of our website.
By continuing to use our website, you accept the changes that are made to the Policy. It is your responsibility to ensure that you read, understand, and agree to the latest version of the Policy. The date at the top of the Policy indicates when it was last updated.
Please periodically visit our website and this Policy to check for any changes (and, where applicable, ensure we have an up-to-date email address for you).
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at (904) 899-6160.
18. Contact Information
You may contact our Privacy Officer at the contact information below.
Our Privacy Officer is responsible for overseeing our privacy program and ensuring compliance with applicable privacy laws and regulations.
If you have any concerns or complaints about how we handle your Personal Information or any privacy-related questions or requests, please contact our Privacy Officer:
Paul Davis Restoration, Inc.
7251Salisbury Rd., Ste. 6
Jacksonville, FL 32256
Attention: Privacy Officer – Shawn Clark
4863-1839-0647, v. 6