Opendoor Operations Canada Inc. (“Opendoor Canada”) is committed to maintaining the accuracy, confidentiality and security of your personal information. This Employee, Job Applicant, and Contractor Privacy Notice (the “Notice”) sets out the manner in which Opendoor Canada collects, uses, discloses, and otherwise manages personal information about our personnel.
What is Personal Information?
For the purposes of this Notice, “personal information” refers to information about potential, current or former Opendoor Canada personnel that is reasonably required by Opendoor Canada to establish or manage the working relationship, or to manage the post-working relationship.
Purposes of Collecting, Using and Disclosing Personal Information
Opendoor Canada’s goal is to help ensure that all personal information collected, used and disclosed has a clear and legitimate purpose that relates to the working relationship. The personal information required to administer the working relationship varies with each individual employee. The length of the working relationship, career choices, and individual performance are among the factors that will influence the nature and extent of the personal information that may become relevant. Personnel can reasonably expect that Opendoor Canada requires personal information for purposes including:
- To Recruit, including to conduct employment-related background screening and checks.
- To Administer Benefits, such as medical, dental, optical, commuter, and retirement benefits, including recording and processing eligibility of dependents (including maintaining their contact and identifier information as required), absence and leave monitoring, insurance and accident management and provision of online total reward information and statements.
- To Pay and Reimburse for Expenses, including salary administration, payroll management, payment of expenses, to administer other compensation related payments, including assigning amounts of bonus payments to individuals, administration of departmental bonus pools and administration of stock option payments.
- To Conduct Performance-Related Reviews, including performance appraisals, career planning, skills monitoring, job moves, promotions and staff restructuring.
- To Monitor Work-Related Licenses and Credentials, including provisioning software licenses for use in the course of your responsibilities, ensuring compliance, training, examination and other requirements are met with applicable regulatory bodies.
- To Provide Human Resources Management Services, including providing employee data maintenance and support services, administration of separation of employment, approvals and authorization procedures, administration and handling of employee claims, and travel administration.
- To Administer International Assignments, including relocation services, documenting assignment terms and conditions, obtaining relevant immigration documents, initiating vendor services, fulfilling home/host country tax administration and filing obligations, addressing health requirements.
- To Maintain Your Contact Information, including altering your details across relevant entities within the Opendoor group of companies (for example personal, other employment and transferring roles).
- To Assist You in Case of Emergency, including maintenance of contact details for you, emergency contacts and your dependents in case of personal or business emergency.
- To Conduct Healthcare-Related Services, including conducting pre-employment and employment-related medical screenings for return-to-work processes and medical case management needs; determining medical suitability for particular tasks; identifying health needs to plan and provide appropriate services, including operation of sickness policies and procedures; and providing guidance on fitness for travel and fitness for expatriation.
- To Facilitate Better Working Environment, which includes conducting staff surveys, providing senior management information, and conducting training.
- To Ensure a Safe and Efficient Working Environment, which includes Opendoor actions relating to disciplinary actions, and code of conduct processes and investigations.
- To Maintain Security on Opendoor Websites and Internet Connected Assets, which includes hosting and maintenance of computer systems and infrastructure; management of Opendoor’s software and hardware computer assets; systems testing, such as development of new systems and end-user testing of computer systems; training; and monitoring email and Internet access.
- To Comply with Applicable Law or Regulatory Requirements, such as legal (state/provincial and federal) and internal company reporting obligations, including headcount, management information, demographic and Health, Safety, Security and Environmental reporting.
- To Maintain Security and Safety of its people, properties and assets.
The type of personal information that Opendoor Canada may collect about personnel and their beneficiaries for the purposes set out above includes, but is not limited to the following:
- Contact and identity information such as name, home address, personal email address and phone number, age/date of birth, gender or gender identity, military or veteran status, marital and family status, driver’s licence number or other photo-identification, and emergency contact information;
- Employment information including employee ID number, start date, end date, employee type, role, location, and department;
- Application information such as resume, CV, or related employment or contract application materials, previous work history, educational background, references, language and other job-related skills, and interview notes;
- Letters of offer or acceptance of employment or contract opportunities;
- Citizenship, immigration, or employment eligibility status, passport, visa information, Nexus card or other enhanced entry document;
- Union affiliation, if any;
- Offer letters, acceptance of employment, employment contracts, and policy acknowledgements;
- Performance data such as training and certification completion, performance evaluations and reviews, promotion/demotion, service (including breaks in service), attendance, and disciplinary records;
- Background check information and information respecting fitness for work, such as work history, education, credit, and, where lawful, criminal background history;
- Financial, tax, and payroll information such as Social Insurance Number, wages, salary, bonus, direct deposit information, tax elections, and equity ownership;
- Health, welfare, and disability information related to disability accommodations, accident investigations, workers’ compensation claims, and leave benefits;
- Vacation and leaves of absence;
- Pension, benefit and insurance information, including employee health and welfare benefits, short- and long-term disability, life insurance, optional life insurance, accidental death & dismemberment, medical and dental care, and necessary dependents information; and
- Information regarding use of company resources, such as technical information including device identifiers, IP addresses, cookies or similar online tracking technology, metadata generated when working on Opendoor systems, and geolocation data.
- Photographs or video
Sharing of Personal Information
Opendoor Canada will not transfer or disclose personal information to a third party without the individual’s consent, except as set forth herein.
We may transfer or disclose your personal information for the purposes described in this Notice, to establish, manage or terminate your working relationship with Opendoor Canada, and/or to manage your post-working relationship with Opendoor Canada, or as otherwise permitted or required by applicable laws.
We may share your personal information with our affiliates (including Opendoor Labs Inc.) consultants and other third parties, that require such information to assist us with managing our working relationship with you, including: third parties that provide services to us or on our behalf and third parties that assist Opendoor Canada in the establishment and management of your working relationship (e.g., external payroll processing, human resources administration, recruitment, technology and data processing services, etc.). In the course of providing these services, personal information may be accessed, collected, stored and processed in the United States or other foreign jurisdictions by Opendoor Canada affiliates or its third-party service providers.
Opendoor Canada, its affiliates and third-party service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order or as otherwise required or permitted by Canadian, U.S., or other law (which may include disclosure to U.S. and foreign courts, law enforcement or governmental authorities). In addition, personal information may be disclosed or transferred to another party (including to self-regulatory agencies or other regulatory authorities) during the course of, or completion of, a business transaction, including in a sale of assets, merger, or other corporate restructuring.
In the case of a transfer of personal information to Opendoor Canada affiliates or third-party service providers that process or store personal information on Opendoor Canada’s behalf, Opendoor Canada will require that such affiliates and/or third parties have agreed to safeguard personal information and use the information only for the purpose(s) for which it has been provided.
Security of Personal Information
Opendoor Canada maintains reasonable physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Opendoor Canada has taken steps to help ensure that your personal information is only accessed by personnel and third-party service providers on a “need-to-know” basis.
Retention of Personal Information
Opendoor Canada will retain personal information of personnel as long as necessary to fulfill the purposes for which it was collected or as required by law.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes by contacting the appropriate department within Opendoor Canada or your HR representative.
Access to Your Personal Information
You may submit a written request to our Privacy Officer to access your personal information. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
If you have any questions about this Notice, or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing, or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address any concerns.
The contact information for our Privacy Officer is as follows:
Opendoor, c/o Legal/Privacy Officer
410 N. Scottsdale Rd., Suite 1600
Tempe, AZ 85281
Revisions to this Notice
From time to time, we may make changes to this Notice to reflect changes in its legal or regulatory obligations or in the manner in which we manage your personal information. We encourage you to refer back to it on a regular basis. This Notice was last updated on July 8, 2021.