Empire Citi Properties Ltd. CASL and Privacy Statement

Empire Citi Properties Ltd. respects your privacy.  This CASL and Privacy Statement informs you of our privacy practices, and how personal information is collected, used and disclosed by any website administered or operated by us. In this CASL and Privacy Statement, we describe the key elements of our privacy program: what personal information is being collected, with which third parties is the personal information being shared, and the purposes for which the personal information is collected, used and disclosed. In our capacity as owner and manager for real estate properties, it is necessary to collect and use certain information about residents and tenants to ensure timely communication about the properties including: safety and security matters, to identify owners and residents when they contact us, to inform owners and residents about products and services that may be beneficial; and for the assessment and collection of fees. Some of the information collected will be personal information including: names, addresses, telephone numbers, emails, and banking and credit information, and information required under Alberta regulations or property by-laws.  We do not provide any personal information to third parties except where you have consented, or as required by law. From time to time, we may use third parties to carry out certain services and this may require providing personal information to them.  This includes providing banking and credit information to third party financial or other payment processing institutions, which may be resident in countries outside Canada. We require third parties that we worked with to have adequate security as it relates to the safeguarding personal information, and policies around data privacy in line with the industries in which they operate. We have security protocols that are line with common industry practices, as well local and regional regulations.  No security protocols are foolproof and there are risks involved in sharing personal information.

Protecting your privacy

Provincial and federal government privacy legislation protects personal information. It is our policy that information collected from our clients is used for the management of your business and is not disclosed to third parties without your knowledge and consent. Online and email application and reservation forms are voluntary, and used as a tool to answer your inquiries, and process your application, property reservation, or hold fees. Any information you share is confidential, and we will not sell, lease or disclose personal information to third parties unless required by law or in the ordinary course of business including: provide property and other services, refinancing or sale of the property, and dealings with utility providers and other services. For greater certainty, you agree we may use personal information that you supply to establish and serve you as our customer; determine whether any of our products or services are suitable for you, or when required by law. You consent to us sharing your personal information with our third party business providers, including, but not limited to, providers of utilities, banks, credit bureaus, lenders and potential purchasers of our property or assets. YOU EXPLICITY CONSENT TO OUR COLLECTION OF YOUR PERSONAL INFORMATION FROM THIRD PARTIES, INCLUDING THROUGH A BANK OR CREDIT CHECK, CONFIRMATION OF EMPLOYMENT, AND LANDLORD OR CHARACTER REFERENCES; AND TO VERIFY THE PERSONAL INFORMATION YOU HAVE PROVIDED TO US. YOU AUTHORIZE THOSE THIRD PARTIES TO DISLCOSE YOUR PERSONAL INFORMATION TO US. YOU ALSO AGREE, UNDERSTAND AND ACKNOWLEDGE THAT ANY HOLD FEE PROVIDED BY YOU UNDER ANY APPLICATION FOR ANY PROPERTY, INCLUDING A RESERVATION FOR ANY PROPERTY, IS NON-REFUNDABLE AS SOON AS THAT APPLICATION IS SUBMITTED BY YOU AND APPROVED BY US

Collection and use of information

The CASL and Privacy Statement applies to our websites, and email, internet, and website-based online applications, reservations and transactions where personal information may be collected from residents and tenants from properties we manage.  It applies to all personal information received in any format including electronic, email, paper, orally, telephone or videoconferencing.  We will share any personal information with third parties only as disclosed here. The websites may contain links to third party sites for your convenience and information.  If you access those links, you will leave our websites and be re-directed to a third party site.  We do not control the privacy practices of third party sites, which may differ significantly from our privacy practices.  We do not endorse or make any representations about third party websites, and the personal data you choose to provide to third party websites is not covered by the CASL and Privacy Statement.  We encourage you to review the privacy policy of any third party website or business before submitting to it your personal information online. Our privacy management program is responsible for ensuring our compliance. Our employees have been trained to deal with the private use of your information and ensure that the company is compliant with all federal and provincial privacy requirements. Currently, we use and disclose your personal information to provide you with the information and services. Although we do not share your personal information without your consent, we may nonetheless disclose your personal information if we are required to do so by law or believe that this action is necessary to: (i) comply with the law or legal process; (ii) protect and defend the our contracts, rights and property; (iii) protect against misuse or unauthorized use of our websites; or  (iv)  protect the personal safety or property of you or the public. This means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions. We may hire third parties to perform functions including removing repetitive information from our customer and residential listings, advertising, analyzing data, providing marketing assistance, distributing emails, newsletters, and providing customer service.  These third parties have access to your personal information to the extent necessary to provide the services, and are restricted from using the information for any other purposes. In addition, we may use your personal information in the aggregate and de-identified manner for research, to create case studies, or to determine audiences, demographics and preferences. If you no longer wish to use or access any of our websites or use any online applications or services, please contact the Privacy Management Program and notify them of your desire to cease using the websites, online applications and our services.  We reserve the right to maintain an archival copy of your personal information for a period not to exceed seven years after the date we longer need it to provide you with our services. In the event that any or all of our assets are acquired or transferred, your personal information may be one of the transferred assets.  It is our practice to seek appropriate protection for information in these transactions.  Personal information means information about an identifiable individual and includes any information that identifies, or could reasonably be used to identify, you. Personal information does not include information that is encoded or encrypted, and it does not include publicly available information.  Similarly, information that is provided in the aggregate and in a de-identified manner is not personal information. Personal information may include your first and last name, your email address, your physical address, and your contact telephone number.  Personal information may come from a variety of sources, including information obtained from partners and affiliates, and information you provide to us. As described here, the knowledge and consent of our clients is required for the collection, use and disclosure of their personal information. Consent clauses also appear in online applications, reservations and transactions; lease agreements; employment agreements; and modify any other form or process that information is transmitted whether orally, by telephone and video conferencing, or any other electronic communication. We limit the collection of personal information to that which is necessary for the purpose of our business. Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law.

Protection safeguards for your information

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Security of the information shall be monitored and controlled us. To help prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of your personal information, we use physical, organizational and technological measures to safeguard the information we collect. Our website may automatically collect certain non-identifiable information regarding users of a website, such as the Internet Protocol address of your computer and your internet service provider, the date and time you access the website, the internet address of the website from which you linked directly to the website, the operating system you are using, the sections of the website you visited, the website pages read and images viewed, and the materials you post to or download from the website. This non-identifiable information is used for website and system administration purposes and to improve the website. Your non-identifiable information may be disclosed to others and permanently archived for future use. We also use firewalls and restricted access methods to help ensure the security of the information we collect. We limit access to your personal information and data to employees and agents of the company that have a specific business purpose for maintaining and processing such information.  Employees and agents who have access to your personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information, and have a contractual obligation with the company to do so. However, no method of transmitting or storing information is completely secure. While we take appropriate measures to protect your personal information, there is always a risk that it may be lost, intercepted or misused. The  website may use cookies, a technology that installs information on a user’s computer to permit the website to recognize future visits using that computer. Cookies enhance the convenience and use of the website. The use of cookie technology is common on the internet, and many internet browsers are initially set to accept cookies automatically. If you would prefer not to accept cookies, you can set your internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. Information from these cookies help us analyze traffic patterns to the website, including the total number of visitors, the geographical location of the visitor, and the types of internet browsers (e.g., Google Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) of the website user. We use this information to facilitate and enhance your online visits. The website may use Google Analytics to collect information, in an anonymous form, about how visitors use the website, including the number of visitors to the website and the pages they have visited, and we use this information to compile reports and to help it improve the website.   The website may also use third party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie, which allows us to market services to those who have shown interest in us.

Your right to access your information

Upon request to our Privacy Management Program, you shall be informed of the existence, use and disclosure of their personal information, and shall be given access to that information. You may challenge the accuracy and completeness of the information and have it amended as appropriate. In the event that you suspect that your personal information has been collected, used or disclosed contrary to the legislation and regulation, please contact our Privacy Management Program.  You have the right to review and correct their information, as described below. To protect your privacy and security, we may take reasonable steps to verify your identity, before we permit any changes to be made to personal information in our database.

Third party services

From time to time, we may offer certain third party services through the websites may be helpful or relevant to you. Third party services may include, but are not limited to, banking, credit and financial services; insurance-related services; payment processing services and property management-related services. When you click on a link for a third party service, your web browser will be re-directed to the third party provider of the third party service that you selected.  Third party providers may have privacy policies that are different than our policies, and you should read carefully the privacy policies of those third parties prior to releasing any of your personal information to them. Third party services may also require you to agree to certain terms and conditions of use before using or accessing those services.   Often, third party conditions describe and govern how third-party providers use your personal information, so you should read carefully all conditions prior to releasing any of your information to such third party providers. We do not endorse, warrant or guaranty the nature, scope, quantity, availability or quality of any third party services. If you have any questions, comments or concerns, you should contact directly the third party providing that service to you.

Protecting privacy of children

The website is designed to accommodate the needs of residents and tenants, and  not children.  We do not intentionally collect or request information from children. To protect their privacy, children under the age of 18 are prohibited from using any website.

Where We Store Your Personal Information

The personal information we collect from you may be transferred to, stored at, and processed by recipients located in destinations outside of Canada, including the United States of America.  These countries may have privacy and data protection standards that are different than those in Canada.

Changes to This Policy

Privacy laws are rapidly evolving and, as a result, we reserve the right to change this policy without notice and at any time. We reserve the right, at our sole discretion, to modify or replace these CASL and Privacy Statement by posting the updated terms on the website. Your continued use of the website after any such changes constitutes your acceptance. Please review this statement periodically for changes. The most current version is posted on the website, and was last updated and is effective as of May 12, 2021.

CANADIAN ANTI-SPAM LEGISLATION POLICY (CASL)

By checking the Privacy Statement and CASL Policy Box on our website and submitting your request to us, you are authorizing the company and our affiliates, partners, nominees, service providers, and any independent third party to communicate with you via email, social media, text message, telephone, and fax or any other form of electronic and internet-based. We may send messages to our customers in relation to the company’s services, programs, programs, offers, promotions or those of our affiliates, partners, nominees, service providers or independent third parties. You are welcome to unsubscribe anytime by either clicking the Unsubscribe button on any of our emails, by directly contacting us by phone, mail or email, or reasonable notice by any other means:
Privacy Management Program,
Empire Citi Properties Ltd.
Suite 1000, 940 6 Avenue SW, Calgary, Alberta, T2P 3T1
Phone: 403-279-2646