Privacy Policy - Choice Properties

1. Introduction

At Choice (collectively, “Choice,” “we,” “us,” and “our”), we respect your privacy and take great care to safeguard your personal information.

In this policy, we describe how we collect, use, share, and manage the personal information of individuals connected with our business, including tenants, contractors, employees, and website visitors. We will always strive to protect the privacy of personal information, subject to applicable laws and any consent an individual has provided for its collection, use, or disclosure.

2. Definitions

Personal information (PI) – any information about an identifiable individual. This includes anything that identifies or could be reasonably associated with an individual, including their background, financial, or social circumstances. Home address, personal email address, and personal telephone number all qualify as PI.

Non-personal information –information that cannot be used on its own to trace or identify a person (e.g. IP address, device ID, cookies). This policy does not apply to non-personal information; however, when we collect non-personal information and link it to an identifiable individual, that information becomes personal information and will be subject to this policy.

3. Overview

We are accountable for the personal information under our control.
We identify legitimate purposes for collecting, using, and disclosing PI at the time of collection.
We obtain valid, informed consent before, or at the time of, collection, use, and/or disclosure of your PI. We will obtain additional consent before using your PI for a new purpose.
We collect the minimum amount of PI needed to fulfill the stated purpose – and we collect this information lawfully.
We limit use, disclosure, and retention of your PI to what is reasonably required to fulfill the purpose stated at the time of collection. We require third parties to comply with our privacy requirements.
We are committed to ensuring the PI we store is accurate, complete, and up to date.
We follow information security protocols to prevent unauthorized access, misuse, disclosure, or modification of PI.
We are open about our privacy policies and procedures.
You have a right to access PI that Choice holds about you.
Contact Choice’s Privacy Officer (privacy@choicereit.ca) if you have any access/correction requests and/or privacy-related questions or complaints.j

4. Fair Information Principles

This Policy is built on the ten Fair Information Principles that are the basis for Canadian privacy legislation. The following section defines each principle in turn and describes Choice’s commitment to meeting its obligations regarding the PI it handles and stores.

Principle 1 – Accountability

Choice is responsible for the personal information under its control, including any personal information disclosed to third parties for handling or administrative purposes.

Choice has designated a Privacy Officer who is responsible, in addition to senior management, for Choice’s compliance with this policy and with privacy legislation.
Choice will use contractual or other means (including the examination of the third party’s practices regarding PI) to safeguard personal information while it is being processed by an authorized third party.
• Choice has implemented internal guidelines and practices to give effect to this policy, including:
- Establishing information security procedures to protect personal information
- Developing a breach response plan for suspected privacy breaches
- Establishing procedures to receive and respond to access and correction requests, complaints, and inquiries

Principle 2 – Identifying purposes

Choice collects personal information for the purposes of conducting and administering our business

We clearly identify the reason for collecting personal information at or before the time of collection.
Our use of personal information is limited to those purposes specified at or before the time of collection, or uses that would be reasonable in the circumstances, such as communicating with you and managing our business.

Principle 3 – Consent

Choice makes a reasonable effort to ensure that you understand how your personal information will be used.

Choice will not collect, use, or disclose your personal information without your knowledge and consent, except in certain limited circumstances permitted by law.
We will obtain consent for the use or disclosure of PI before or at the time that information is collected.
If we want to use the information for a purpose not identified when the PI was originally collected, we will seek additional consent from you.
As a condition of supplying a service, Choice does not require an individual to consent to the collection, use, or disclosure of personal information beyond what is required to fulfill the specified purposes.
Consent may be express or implied. Express consent is given either verbally or in writing. Consent is implied when it can be reasonably understood by the action or inaction of the individual. Consent may be given through a legally appointed representative or a legal guardian.
You may, subject to legal or contractual limitations, withdraw your consent at any time on sufficient notice to Choice. Withdrawal of consent may result in Choice becoming unable to provide or continue to provide you with certain services or benefits, and you will be given notice of the implications of withdrawing your consent.

Principle 4 – Limiting collection

We do not collect personal information indiscriminately.

We limit both the amount and the type of personal information collected to that which is necessary to fulfill the purposes identified. At all times, we collect PI only through fair and lawful means.
It is possible that Choice may, with your consent, collect and use information about you via a third party, for example to perform a credit check.

Principle 5 – Limiting use, disclosure, and retention

We use and disclose personal information in order to conduct and administer our business, with the purpose defined and consented to at the time of collection.

We limit the use and disclosure of PI to those purposes stated at the time of collection, unless you consent otherwise (e.g. marketing or analytics purposes), or where the use or disclosure is permitted or required by law.
We retain PI only as long as reasonably necessary to fulfil our legitimate business, employment, and administrative purposes, or as otherwise permitted or required by law.
Once no longer required, we dispose of or destroy personal information in a safe and secure manner.

Choice may share personal information within its group of companies and with third parties for employment-related and administrative purposes, including storage and processing.

Where PI is disclosed to third parties, we require that such parties only access and use PI to the extent required to provide their services. They must also comply with our privacy requirements (e.g. breach notification, retention, and secure destruction).
Choice will generally, but not necessarily, store, access, and use personal information in Canada. Subject to a legal or regulatory requirement to keep personal information in Canada, PI may also be stored, accessed, processed, or communicated in any country where Choice’s service providers are located or from which they provide services. Where personal information is stored or processed outside of Canada, it is subject to the laws of the jurisdiction where it is located.
Sale or transfer of business. From time to time, Choice may share/disclose your personal information in the context of a corporate transaction. If your personal information is required in connection with any such transactions, we will require that the parties involved, including affiliates, advisors, or other service providers, agree to protect your personal information with policies meeting standards equivalent to those set out in this policy both during and after completion of the transaction. Choice Properties does not sell, trade, or share personal information with third parties for financial or other benefits.

Principle 6 – Accuracy

Choice keeps personal information as accurate, complete, and up to date as necessary for the purposes for which it will be used.

We update personal information as it is made available.
You are responsible for providing accurate, complete, and up-to-date information about yourself.

Principle 7 – Safeguards

We protect personal information from collection through to destruction using security safeguards appropriate to the sensitivity of the information involved.

The methods of protection used by Choice will include, but are not limited to:
- Administrative safeguards, including policies, procedures, training, confidentiality and non-disclosure agreements, and risk assessments
- Physical safeguards, including restricted access to offices, and lockable offices and cabinets
- Technical safeguards, including role-based access controls based on a “need-to-know” basis, encryption of data, passwords, multi-factor authentication, logging, and monitoring
Where Choice employs third parties to store PI, we review the privacy and security safeguards they employ and confirm that they meet our standards.
Choice will ensure that its employees who handle or have access to personal information receive appropriate information security and privacy training. Employees are required to abide by this policy.

Principle 8 – Openness

Choice is open about its privacy policies and practices.

Information about our policies and practices relating to the management of personal information is readily available.

Principle 9 – Individual access

You have the right to request access to personal information that we hold about you, and to request corrections to that information if you believe there is an error or omission, with some exceptions.

You can request access to your personal information by contacting Choice’s Privacy Officer at 22 St. Clair Avenue East, Suite 700, Toronto, Ontario M4T 2S5, by phone at 1-888-663-6063, or by e-mail at privacy@choicereit.ca.
Choice will respond to requests for information within thirty (30) days of receipt of the request.
Access is not automatic and may be refused, if permitted or required by law. We may not respond to unreasonable requests based on how the information is to be used, the nature of the information, and the frequency of the requests. Furthermore, we reserve the right not to change PI that we believe to be accurate.

Principle 10 – Challenging compliance

You have the right to submit an inquiry or complaint regarding our privacy practices.

If you are concerned about how we treat your personal information, please contact Choice’s Privacy Officer.
You may also submit a privacy complaint on our information handling practices directly to the appropriate provincial Privacy Commissioner if you reside in Alberta, British Columbia, or Quebec, or to the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec, K1A 1H3, 1-800-282-1376. More information can be obtained at the Office of the Privacy Commissioner of Canada’s website: https://www.priv.gc.ca/
We will investigate any privacy complaints we receive, and if found to be justified, we will take appropriate measures to correct our information handling practices, including, if necessary, amending our policies and procedures.

5. Contact Us

Please submit any access/correction requests, complaints, or inquiries to Choice’s Privacy Officer at 22 St. Clair Avenue East, Suite 700, Toronto, Ontario M4T 2S5, by phone at 1-888-663-6063, or by e-mail at privacy@choicereit.ca.

6. Interpretation

Responsibility for the interpretation of this policy rests with the Privacy Officer.

7. Review

This policy will be reviewed by the Privacy Officer annually, or when there are changes to the laws and regulations. If substantially changed, it will be updated, approved, and posted, as required.