Privacy Policy



Effective August 19, 2022

Overview

Colonia Treuhand Limited and its affiliates ("CT", "we", "us", "our") are committed to respecting your privacy and protecting your personal information. In this privacy policy ("Privacy Policy"), we describe our privacy practices, including the types of personal information we collect, why we collect it, how we use it, how we manage it and under what circumstances we share it with third parties. This Privacy Policy also describes the rights you have with respect to your personal information.

This Privacy Policy applies to personal information you provide us, such as when using our products or services, our website found at coloniatreuhand.com, including our investor and tenant portals (collectively, the "Website"), our payment application and when using any of our social media pages such as LinkedIn. This policy also applies to any information we collect from you on behalf of our clients.

By submitting your personal information to us or by otherwise using our Website, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

We only collect, use or disclose your personal information in accordance with applicable laws, regulations and this Privacy Policy. Depending on the context, we may request your consent in writing, accept your oral consent, or imply your consent through your conduct, including your acceptance and use of our products or services in certain instances. If you provide us with personal information of another individual, you confirm that you have all necessary authority and/or have obtained all necessary consents from such person to allow us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

Information We Collect and How We Collect It

We may collect the following information from you by phone, fax, email, in person, through our Website and by other means in the following contexts:

Directly From You

When you provide your personal information to us (including on behalf of our clients) for any purpose, such as accessing our products or services, uploading or submitting information through the Website, making a compliant, or contacting us to obtain our products or services, including over the phone, by fax and/or email, you may voluntarily provide us with certain personal information. For example, if you apply to become a tenant, information we may request in our application forms to determine your suitability for a lease includes your first and last name, date of birth, address, phone number, e-mail address, social insurance number, annual income, employment details, credit history, whether you have any dependents or pets, banking information, references and emergency contacts.

Surveys

Occasionally, we may ask you to complete an optional survey where you may be asked to submit certain personal information for identification purposes and to better understand your feedback.

Automated Collection

Our Website uses cookies, web beacons and other automatic data collection technologies to analyze and collect certain information about users equipment, browsing actions, and patterns. Cookies allow us to analyze trends and understand more about how our users interact with our Website so that we can enhance user experiences. This information is not personally identifiable on its own and can be used for aggregate website traffic and trend analysis. Such information may include domain names and internet protocol (IP) addresses, usage statistics (e.g., types of web browsers and operating systems used) and browsing history. For additional information, see “Our Use of Cookies on the Website”, below.

Electronic Communications

If you provide us with your contact information for communication purposes, we may use this information to communicate with you through electronic means, such as by sending you e-mails.

Support Services

If you e-mail, fax, write to us, or otherwise contact us, we may collect your name and contact information.

Why We Collect, Use and Disclose Your Personal Information

We collect, use and disclose your personal information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including, for the following purposes:

  • to understand your suitability for a property and to manage the ongoing administration of your lease;
  • to verify your information if requesting to lease a property, including confirming your income, requesting a credit check from a credit reporting agency, or contacting your employer or references;
  • to provide you with our products or services (for example, the preparation of a lease relating to a property);
  • to understand and respond to your needs and preferences and to assist us with providing you secure access to our Website and a positive experience;
  • to communicate with you for the purposes you indicate when you sign up for our services or to access and use the Website;
  • to provide you with details about new products or services and other important information, including any matters relevant to your tenancy, and to advertise and promote our products and services to you;
  • to provide you with customer support services and to respond to any emergencies;
  • to manage and administer our business and to address problems with and to improve our Website, including its design and offerings;
  • to carry out our obligations or enforce our legal rights or the rights of those who interact with us, including those obligations and rights arising from any agreements we may have with you;
  • to comply with legal or regulatory requirements or to protect our safety, your safety or the safety of others;
  • to identify, prevent and respond to fraud and other illegal activity;
  • to fulfill the purposes for which you provided the personal information or that were described when it was collected; and
  • to act in accordance with any other purpose with your consent.

If we intend on using any collected personal information for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is required by law, consent will be obtained before the information is used for that purpose.

Information Sharing

We only share your personal information when we have a legitimate reason to do so. We do not sell any of your personal information to other parties. We may disclose your personal information with:

  • our financial, insurance, legal, accounting or other advisors that provide professional services to us; and
  • third parties, including service providers that provide us administrative and other services, such as hosting our Website, data processing services, and marketing.

We may also disclose your personal information to a third party if, in our judgment, doing so is required to comply with laws, regulations or a government request; to establish or exercise our legal rights or defend against legal claims; investigate, detect, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the safety of any person; or as otherwise required by law.

If we are to be sold, merged or amalgamated (including in the event of a partial sale) or substantially all of our assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction. If such a sale, merger, acquisition, or disposal is completed, the purchaser may use and disclose your personal information only in the manner described in this Privacy Policy.

We may disclose your information in any other way we may describe to you when you provide the information, or for any other purpose with your consent.

To the extent we enter into arrangements with service providers to store, handle or otherwise deal with personal information on its behalf, such as for data processing, document storage software support and office services, we require such parties to provide comparable privacy protection while the information is processed or handled by them. We use appropriate contractual and other means to ensure that the third party will only use your personal information to perform the services we have specified.

Storage of Your Personal Information

Your personal information is stored in secured locations and on servers controlled by either us or our service providers. Our service providers may perform activities outside of Canada. Accordingly, your personal information may be subject to the laws of a foreign jurisdiction, including the United States, and such jurisdiction may have legal requirements that require us or our service providers to disclose information to courts, law enforcement, or other governmental authorities.

Security of Your Personal Information

We have in place appropriate security measures to protect against the unauthorized collection, loss, misuse or alteration of information we retain, appropriate to the sensitivity of the information, including:

  • only authorized personnel on a “need-to-know” basis have access to personal information;
  • electronic data is protected by passwords and encryption; and
  • master user lists and rights are reviewed annually. We will continue to enhance security procedures to safeguard and protect personal information, however, please remember that no security measures are entirely foolproof, especially in respect of Internet or email communications and we encourage visitors to our Website to exercise care with the information that they provide through the Internet or by email.

Your Rights and Choices

Ensuring your personal information is accurate and current is important to us, and we respect the rights you have with respect to your personal information. At any time you may contact us to:  

  • request access to your personal information and to obtain a copy of it;
  • unsubscribe from our email communications;
  • request a correction of your personal information in the event we hold incomplete or inaccurate information about you; or
  • withdraw your consent for our use and disclosure of your personal information.

While you are generally permitted to withdraw your consent on reasonable notice to us, legal or contractual restrictions may require us to use or retain your personal information for a certain period of time. We will advise you if this is the case.

When you make a request, we may require you to provide sufficient personal information to allow us to identify you. If you are unable to provide proof of your identity, we reserve the right to refuse to send you any personal information. If you contact us about your personal information, we will respond to your request within a reasonable time.

Being Denied Access to Your Personal Information

Your rights to access your personal information are not absolute. We may deny access when:

  • denial of access is required or authorized by law;
  • information relates to existing or anticipated legal proceedings against you;
  • granting you access would have an unreasonable impact on other people's privacy;
  • protecting our rights and property; and
  • your request is frivolous or vexatious.

We will inform you if we deny access to you for any of the foregoing reasons.

The Website may contain links to other websites. We are not responsible for the activities of the operators of any third-party websites that the Website may link to and visiting these third-party websites is at your own risk. We recommend that you review the privacy policies of any third party websites our Website may connect you to, before providing them with your personal information.

Personal Information of Children

Our Website and marketing activities are not directed to children under the age of 16, 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.

Retention of Personal Information

We generally keep personal information for as long as necessary to fulfill the purposes we collected it for and to satisfy any legal, accounting, or reporting requirements. Personal information that is no longer required is securely destroyed.

Use of Cookies

As mentioned, we collect some information by automated means when you visit our Website. Cookies are small text files that a website saves on your computer or mobile device when you visit it. When we use the term "cookies", we refer to other technologies that accomplish similar tasks or help cookies function, such as web beacons, which allow third parties to obtain information such as IP address, the URL of the page on which the beacon appears, timestamps and browser type. 

We use cookies to fulfil many different purposes such as improving your experience on our Website; recognizing when a user returns to our Website; keeping track of activity on our Website; remembering what a user has clicked on or viewed; understanding the number of visitors to our Website; identifying what problems may exist on our Website, if any; and studying how a user navigates through our Website so that we can improve the design, content, usability and functionality of our Website. This information is used in aggregate and is not linked to any personally identifiable information. We may share this non-identifiable information with our service providers. The types of cookies we may use include:

  • Strictly necessary cookies. These are cookies required for the operation of our Website. Without these cookies, certain functions of our Website cannot be provided. This category of cookies should not be disabled.
  • Functional cookies. These cookies collect and store information about your preferences as well as your navigation to, from, and on our Website. They allow us to provide enhanced and more personal features on our Website.
  • Analytical cookies. These cookies allow us to recognize and count visitors to our Website and to see how visitors move around our Website when they are using it, and if they encounter issues. This helps us improve our Website functionality, for example, by ensuring users are finding what they are looking for easily.

We may also use browser "log files" which record certain information when you visit a website, including your IP address. Web browsers are typically set up to accept cookies, however, if you wish to amend your cookie preferences, you can do this through your browser settings. Note, however, that disabling cookies may reduce functionality of our Website.

Changes to this Policy

We reserve the right to amend this Privacy Policy at any time by posting an updated version. We recommend that you check the Website periodically to review our current Privacy Policy. You can tell if this Privacy Policy has changed by checking the effective date that appears at the top of this Privacy Policy. Depending on the circumstances, we may also send you a notice electronically that the Privacy Policy was changed. If you continue to access or use the Website or our products or services after this Privacy Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.

Contact

If you have questions regarding our Privacy Policy, please contact our Privacy Officer at:

Address: 411 Richmond Street East, Suite 302, Toronto, ON M5A 3S5, Canada
Email Address: info@coloniatreuhand.com

If after contacting us you do not feel that we have adequately addressed your concerns, you may contact:

The Office of the Privacy Commissioner of Canada
Call: 1-800-282-1376
Visit: www.priv.gc.ca