— Privacy
Privacy policy
Lucero Commercial Group (“we”, “us”) is a commercial real estate brokerage operating in Ontario and Alberta. This policy explains what personal information we collect through this website, why we collect it, who we share it with, and how you can access or correct it.
1. The law we follow
We handle personal information in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA), and we send commercial email in accordance with Canada’s Anti-Spam Legislation (CASL). Where we act as a real estate brokerage, we are also subject to the Trust in Real Estate Services Act, 2002 and the rules of the Real Estate Council of Ontario.
2. What we collect, and when
Enquiry and submission forms
Our contact, valuation, property-submission and acquisition-criteria forms collect your name, email address, and optionally your phone number, company and the message you write. We collect this only when you submit a form.
Insights subscription
If you subscribe to our market reports we store your email address and, if you provide it, your name. Subscription is double opt-in: we send a confirmation link and record nothing as an active subscription until you click it. Every email we send includes a one-click unsubscribe link, and we record when you unsubscribe so we do not contact you again.
Documents you sign on this site
Four kinds of document can be signed here: non-disclosure agreements, buyer and tenant representation agreements, mutual releases and cancellation forms. For each we collect your full legal name, email address, phone number, the entity you represent and your title if you give them, and a mailing address for legal notices. The address is required because the document directs formal notices to it.
Because an electronic signature has to be defensible, we also record evidence of the signing event itself: the time your email address was confirmed, when you opened the document, when you reached the end of it, when you signed, your IP address, your browser’s user-agent string, and the exact consent wording shown to you. This information is reproduced on a certificate page attached to the executed PDF, so you receive a copy of everything we hold about your signature.
A mutual release is signed by two parties. Each party sees the other’s name and the details their signature block carries, because those appear on the document itself, and only after confirming their own email address.
Client portal
If we open a client portal account for you we store your name, email address and organisation. Signing in uses a one-time link sent to your email rather than a password. When you open a document we record which document, when, your IP address and your user-agent, a confidentiality control on material shared with a limited number of people.
Website analytics and cookies
Our analytics measure aggregate page traffic without cookies and without building a profile of you or following you across other sites.
The only cookie this site sets is the client portal session cookie described in section 8, and it is set only when you sign in to the portal. There are no advertising or tracking cookies, which is why the site does not ask you to accept any.
3. Why we use it
- To answer your enquiry and provide the brokerage services you asked about.
- To perform and enforce agreements you enter into with us, including confidentiality agreements.
- To send the market reports you subscribed to, until you unsubscribe.
- To keep records we are required to keep as a registered brokerage.
- To secure confidential material and detect misuse of it.
We record enquiries and executed agreements in our client relationship management system so we can follow up on the transaction you contacted us about. We do not sell personal information, and we do not share it for anyone else’s marketing.
We never add you to our Insights mailing list because you contacted us. That list is opt-in only: you have to tick the box offered on our forms, and we then email you a confirmation link that you have to click before we send anything. An enquiry, a property submission or a signed confidentiality agreement on its own never results in marketing email.
4. Consent
We collect personal information when you choose to give it, by submitting a form, subscribing, or signing an agreement. You can withdraw consent at any time, subject to legal and contractual restrictions: we cannot delete an executed agreement or the record of how it was signed, because those are the evidence that the agreement exists.
5. Who we share it with
We use service providers who process personal information on our behalf and only on our instructions:
- Our database provider — the database itself, hosted in Canada.
- Our hosting and security provider — serving this site, protecting it from abuse, and storing documents including executed agreements.
- Our email provider — delivery of the emails we send you.
- Our client records system — keeping track of enquiries and engagements.
We will name any of these on request: write to us through the contact form.
Some of these providers operate outside Canada, so your information may be stored or processed in another country and may be accessible to that country’s courts and law enforcement under its laws. We otherwise disclose personal information only where the law requires it.
6. How long we keep it
- Executed documents: 7 years from signature, after which the signed PDF is deleted and the personal details on the record are erased. We keep a non-identifying record (dates, document hashes and the version of the document) as proof that it existed.
- Enquiries that do not become engagements: two years from your last contact with us, after which they are deleted.
- Client records, engagements and portal documents: six years after the engagement ends. Registered brokerages are required to keep transaction records, and tax rules require business records over a comparable period; we do not keep them longer than those obligations require.
- Subscription records: for as long as you are subscribed. If you unsubscribe we keep a record of that, because it is how we make sure we do not email you again.
Where a longer period is required by law, for example a regulatory investigation or a legal claim, we keep the relevant records until that obligation ends.
7. Your rights
You may ask us what personal information we hold about you, ask us to correct it if it is wrong, and ask us to stop using it. Write to us at the address below and we will respond within 30 days, as PIPEDA requires. We may need to verify your identity first, and we will explain in writing if we cannot act on part of a request.
8. Security
Confidential documents and executed agreements are stored privately and are reachable only through short-lived links we generate for a specific person. Administrative access to this site sits behind a separate identity check, with no password kept on this site. Portal sessions use a signed cookie (lucero_client_session) that identifies your session and nothing else. No safeguard is perfect, and we do not claim otherwise.
9. Contact
Questions, access requests and complaints go to the Privacy Officer of Lucero Commercial Group. Send them through the contact form, marking your message for the Privacy Officer, and we will reply with whatever the request needs. Our terms of use cover the rest of your relationship with this site.
If you are not satisfied with our response you may complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca.
10. Changes
If we change how we handle personal information we will update this page and the date above. Material changes affecting information we already hold will be notified directly where we are able to reach you.