TENANT AND SUPPLIER PRIVACY POLICY

 

Your privacy is important to us. Polaris Realty (Canada) Limited (“Polaris”, “us”, “we”) is committed to maintaining the accuracy, security and privacy of the personal information it collects, uses and discloses in accordance with applicable legislation. This privacy policy (the “Privacy Policy”) is a statement of principles and guidelines concerning the protection of personal information of our tenants, suppliers and other individuals (“you”).

CONSENT

By submitting personal information to Polaris or its agents, you agree that we may collect, use and disclose such personal information in accordance with this privacy policy, the privacy preferences you have made known to us and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us as set forth below. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information that may be of value to you.

1. Who are we?

   Polaris is a property manager providing a range of services including property management, development and leasing, with first class developments in Vancouver, Toronto and Montreal.

2. What personal information do we collect?

   Canadian privacy legislation defines personal information broadly as information about an “identifiable individual” or as information that allows an individual to be identified. The types of personal information that we may collect from you from time to time include: (for tenants, as individuals) your name, address, telephone numbers (office, home, cell, pager), email addresses, credit check information, financial statements, banking information, insurance policy number and other information regarding insurance, photograph for access card purposes; (for suppliers, as individuals): your name, address, telephone numbers (office, cell, pager), email addresses, tax numbers, CCQ number.

3. Why do we collect your personal information?

   We collect your personal information for the purposes listed below:

   1. For tenants

      If you are a tenant in one of our buildings, we use your personal information in order (i) to evaluate your creditworthiness as a tenant, (ii) to evaluate and process your application for tenancy, (iii) to prepare the lease, (iv) when the lease is executed, to provide you with relevant information and services throughout the term of the lease (including specialized services and memberships, such as for parking and fitness facilities); (v) for emergency, security or incident reporting involving video, swipe card and other surveillance method, (vi) for insurance, security and risk management purposes; and (vii) generally speaking, to establish, manage and terminate our business relationship.

   2. For suppliers

      We use the personal information provided to us by our suppliers in order (i) to evaluate and select your company, (ii) initiate orders, (iii) process payment and (iv) maintain our business relationship.

   3. Other purposes

      In addition, from time to time, we may use your personal information for the following purposes:

      • to detect and protect Polaris and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with Polaris policies and contractual obligations;
      • to understand and respond to tenant, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
      • to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Polaris;
      • to meet legal and regulatory requirements;
      • for any other purpose we may indicate to you from time to time.

4. To whom do we disclose your personal information?

   In order to fulfill any of the purposes set forth in section 3 above, we may disclose your personal information to the following third parties in the following circumstances:

   1. Disclosure to Service Providers

      (For tenants) We may disclose your personal information on a need-to-know basis to other companies that provide services on our behalf, including lawyers, building managers or maintenance, cleaning companies, call centre operations, security agents, label printers, invoice printers, auditors, data processing, document management and office services. In addition, we may disclose your personal information to an organization or individual retained by Polaris to evaluate your creditworthiness or to collect debts outstanding on an account or to our auditors. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose.

   2. Disclosure to Affiliates

      We may disclose your personal information to any of the business entities that have ownership or management interests in the property in order to serve you better and to provide you with information about our affiliates’ products and services.

   3. Disclosure in Business Transfers

      Polaris may be involved in the sale or transfer of some or all of its business. As part of that sale or transfer, Polaris may disclose your personal information to the acquiring organization (including as part of the due diligence process), but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

   4. Law Enforcement and Legal Disclosure

      Polaris may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Polaris has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to Polaris’ legal counsel.

5. Control of your personal information

   At Polaris, we want you to be able to maintain control over how we use your personal information. In particular:

   • You always have the option to instruct us not to use your personal information beyond providing you with the service or information you requested (see "Contact Us" below).
   • E-mail communications (such as building operating notices) from Polaris to you will always include an identification of the sender and an "Unsubscribe" option.
   • You have the right to access and rectify your personal information that we have on file, as discussed below in Section 7.

   In order to specify your privacy preferences, please contact our Privacy Officer at the address below. As mentioned above, we may not be able to provide you with our services or information if you withdraw your consent to our use of your personal information.

6. Where is your personal information stored?

   Your personal information is stored in secured locations and on servers controlled by Polaris, located either at our offices or at the offices of our service providers. For access to your personal information, please contact our Privacy Officer (see "Contact Us" below).

7. How can you access your personal information?

   Upon written request, subject to certain exceptions, Polaris will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. We keep your information for the time we are providing you with a service and for a reasonable time thereafter (generally, one year) in the event that you wish to resume service, or such longer time as may be required by law. Access requests should be sent to our Privacy Officer, using the contact information in the "Contact Us" section below.

8. How do we protect your personal information?

   We make commercially reasonable efforts to protect against the loss, misuse, and alteration of personal information under our control. Our security policies are periodically reviewed and enhanced as necessary.

   We employ administrative, contractual and technological safeguards to protect your information. For example, only authorized employees and suppliers have access to personal information of our tenants and suppliers. Where information is sent to a third party for processing, we make sure, through our contracts with them, that such service providers may only use the information for the limited purposes for which it was disclosed and are required to keep the information secure. Moreover, we operate secure data networks protected by industry standard firewall and password protection systems.

9. Privacy and online communications

   Polaris sometimes collects personal information through its website and online communications. In this section, we provide you with additional information regarding such collection.

   Cookies - When an individual visitor accesses the Polaris websites, we may use a browser feature called a ‘cookie’ to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the websites from which the visitor came, date and duration of the visit, number of visits, average time spent on our websites, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our websites are visited. Unless a visitor specifically informs us (e.g. by enrolling for our services or sending us correspondence from the websites), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with which we have a commercial relationship to measure the use of our websites and to improve the functionality and content of the websites. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our websites.

   E-Communications - Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of Polaris and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if recipients decide they do not want to receive any future marketing or promotional e-mails from Polaris. If you send us an email message or correspond with us through our website, we may retain that message and your address, as well as any response we send you.

   Links - Our websites may contain links to other websites that are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Polaris, and Polaris has no responsibility for such third party websites.

10. Changes to the Privacy Policy

    Polaris reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will notify you by such means as publishing the revised policy on our website at www.polarisrealty.com. In addition, Polaris will make such revised policy and changes available upon request to the Polaris Privacy Officer. However, Polaris will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s personal information for purposes other than those to which consent is obtained unless otherwise required or permitted by law.

11. Contact Us

    Polaris has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws. For information on Polaris’ privacy practices, please contact the Regional* Polaris Privacy Officer at:

    Polaris Realty (Canada) Limited
    Privacy Officer
    Suite 101, Box 58, West Tower
    2700 Matheson Blvd. East
    Mississauga, Ontario L4W 4V9

    e-mail: privacyofficer@polarisrealty.com
    phone: (905)-238-5009
    fax: (905)- 238-5054

    * (Out of Province requests will be forwarded to the appropriate regional office)