Privacy Policy

Personal Information Protection and Electronic Documents Act (PIPEDA)

Purpose
Privacy of personal information is an important principle to Sifton Properties Limited. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for providing the quality goods and services of our business to our customers. We also endeavour to be open and transparent as to how we handle personal information. This document describes our privacy policies.

What is Personal Information?
Personal information is any information that can be used to identify an individual. This information includes information that relates to an individual’s personal data or characteristics, their health or their activities and views. In most circumstances, personal information does not include information that might appear on a business card, or information that is available in public records.

Who We Are
Sifton Properties Limited provides a variety of quality goods and services in the following areas:

• Office, retail, land and industrial leasing, property management services and construction
• New home construction and sales
• Development of land for the purposes of building communities, including new homes, recreation, shopping and commercial services
• Management of gated community and recreational amenities
• Rentals of apartments and townhomes
• Accommodation and provision of care in retirement residences and long term care homes

To provide these goods and services, we hire employees and use a number of contractors, sub-contractors, consultants and agencies that may, in the course of their duties, have access to personal information we hold.

The Ten Privacy Principles
We follow 10 principles when collecting, using and disclosing your personal information:

• We are accountable for personal information under our control.
• The purpose for collecting personal information is identified at or before the time it is collected.
• We obtain your consent before, collecting, using or disclosing your personal information, except where otherwise permitted or required by law.
• We limit the personal information we collect to that which is necessary for us to conduct business.
• The personal information we collect is only used, disclosed or retained for its original intended purpose (unless you provide your consent to a different use or disclosure) and we retain it only as long as necessary for those purposes.
• We take care to ensure that the information we have is accurate.
• We safeguard the privacy of your personal information through security measures.
• We are open with you about our policies and practices related to managing your personal information.
• Upon request, we provide you with access to your personal information, subject to any limitations imposed by law.
• We address your concerns. If you have questions or concerns regarding your privacy or this policy please contact us.

Your Consent
By providing us with your personal information, you consent to the collection, use and disclosure of that information. We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the products or services requested. The form of the consent that we will seek before collecting, using or disclosing personal information will vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent or opt-out consent. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given.

It would be rare for us to collect any personal information without the customer’s, tenant’s or resident’s express consent, but this might occur in a case of urgency where we believe the individual would consent if asked and it is impractical to obtain consent, appropriate public sources or if it is necessary to investigate a breach of the customer’s agreement or a contravention of the law, or enforce an agreement you have with us.

You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its’ purpose to the company. We will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude us from providing the services or other consideration requested.

Collection of Personal Information
We collect, use and disclose personal information in order to serve our customers, tenants and residents. For most of our customers, the primary purposes for collecting personal information as per PIPEDA are:

• To ensure our customers have access to the premises, equipment, accommodation, care, goods and services that we have agreed to provide
• To ensure the safety, security and reasonable enjoyment of our customers and that of others
• To communicate and promote information regarding our goods and services
• To determine eligibility for purchase, leasing, or rental of properties
• To collect payments, rents and other fees for care, products and services
• To carry out quality assurance activities to help make us better
• To comply with legal and regulatory requirements

Examples of the type of information we collect may include the following:

• Names of occupants of the premises
• Business and emergency contact information
• Use and intended uses of the property
• Compliance with the customer or tenancy agreement and/or rules and regulations related to the accommodation, new home financing requirements and construction, and/or other goods and services provided
• Credit information and history
• Payment, banking and other financial information
• Tenant information on behalf of third party commercial property management services
• Any special needs of tenants or residents, such as disability information or health history
• Social insurance number

How is your information used?

New Home Purchasers
Purchasers of new homes complete a written consent which details the collection, use and disclosure of personal information to financial institutions, marketing, insurance, trades/suppliers, solicitors, government agencies and any other third parties involved in Sifton new home sales and construction process.

Golf Community
Residents of the golf community and club members are advised of the requirements for the collection, use and disclosure of personal information within the gated community as it pertains to security, membership, fitness services, involvement and promotion of committees, special events and other activities, website access and available web services, fee collection, account information review and use of other products and services provided within the community. We may also require digital photos for identification and security purposes.

Public Directories
As a service and convenience for tenants, residents, club members or other customers, we may maintain public directories such as front door directories, phone listings or membership directories. If you do not wish to be listed in any directories or wish to be described in a particular way, please let us know.

General Public Information
For members of the general public, our primary purpose for collecting personal information is to promote the safety of customers, tenants and residents and the enhance the security of the property. For example we, or our clients, may operate security cameras, restrict entry, record license plate numbers, or monitor the presence of vehicles. Security cameras may also monitor the movement and conduct of visitors and others on and about our various properties. We believe that the collection of this information is necessary to support the provision of services and security of the properties and that of our residents, tenants and customers.

Secondly, we may gather personal information in the course of marketing and promoting our property or services to prospective customers, tenants or residents. This information is collected either from appropriate public sources including telephone or service directories, or directly from the individuals, with their consent.

Government Agencies
Various government agencies have the authority to review our files and interview our staff as a part of their mandates.

If a tenant’s or resident’s rent or fees are paid for by a third party such as an employer, trustee or government agency, we may be asked to provide them with certain information. These third party payers often have consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate entitlement to and responsible use of this funding.

Website Information
On our website, we only collect, with the exception of cookies (electronic markers identifying computers that have previously visited our website), the personal information you provide and we only use that information for the purpose for which you provided it to us. Cookies are only used to help you navigate our website, and to allow us to facilitate and enhance your online visits.

Suppliers and Contractors
We often deal with agents, suppliers, contractors and sub-contractors who provide goods, care and services to our customers and assist with maintaining the properties we manage. We monitor their performance, including their promptness, reliability, quality and value of services.

The consultants we use have restricted access to any personal information we hold. We also have their assurance that they follow appropriate privacy principles.

We may disclose limited personal information to suppliers of various services, such as telecommunications service providers, so that they can make available their services to new and existing customers, tenants and residents.

We may also disclose personal information to insurers, lenders, or prospective purchasers of properties we own or manage.

Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic hardware containing personal information is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or encrypted.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• Seniors’ Living staff and volunteers are required to sign confidentiality agreements
• External consultants and agencies with access to personal information must provide us with appropriate privacy assurances.

Retention and Destruction of Personal Information
We need to retain personal information for some time to ensure that we can answer any questions regarding the goods or services provided and for our own accountability to external regulatory bodies.

Tenants, residents, clients or other individuals we deal with may have questions about the goods and services they received. We also provide ongoing services for many tenants, customers and clients over a period of months or years for which the retention of service records is necessary.

We retain information for as long as it is needed for the purposes for which it was collected. We may also be subject to legislative requirements regarding the length of time for retention of certain types of information.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed or completely reformatted.

Access to Your Personal Information
With some exceptions, you have the right to see what personal information we hold about you. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand. We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are wrong. Where we agree, we will make the correction.

Changes to This Privacy Policy
Sifton Properties Limited reserves the right to change this Privacy Policy from time to time. We recommend that you periodically review this Privacy Policy, which is posted on our website at www.sifton.com, so that you are aware of any changes. Any amendments to the Sifton privacy Policy will be effective from the date that it is posted on the Sifton web site. Your continued reading of the policy and use of our site following the posting of any changes to this Privacy Policy shall constitute your acceptance of these changes.

Do You Have A Question?
If you have any questions or concerns about how we collect and share your information, please contact the senior manager at your local Sifton office.

Our Corporate Privacy Information Officer can be reached at:

Sifton Properties Limited
800-195 Dufferin Avenue
London, ON N6A 1K7
Phone: (519) 434-1000
Fax: (519) 434-1009

If you have any questions about this policy and the company’s handling of your personal information, please contact us. We will investigate and respond to your concerns.

This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes.

The Information and Privacy Commissioner can be reached at:

112 Kent Street
Ottawa, ON K1A 1H3
Phone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax: (613) 947-6850
TTY: (613) 992-9190
www.privcom.gc.ca