Last updated: May 9, 2024 3:00 PM

5.3 Where We Get This Information / Methods of Collection of Personal Information

1. General
   Personal Information may be collected by Edenshaw in a number of ways, including in person, our website, by mail, by email, from our applications or other software, and from third parties whom you have authorized to disclose Personal Information to us.
   If you provide information about a third-party or authorize a third-party to do so, we will assume you have taken proper measures to obtain informed consent. Any information submitted by a customer to us during our ordinary course of business may be collected.
2. Cookies and Web Beacons
   Edenshaw may collect Personal Information through cookies on our Website. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our Website again. This helps us to understand your preferences based on previous or current Website activity, allowing us to provide you with improved services, tailor our content to meet your needs and for advertising purposes. We also use cookies and navigational data to gather information regarding the date and time of your visit and the information for which you searched and viewed, or on which of the advertisements displayed on our Website you clicked.
3. Clickstream Data and Google Analytics
   When you visit the Edenshaw Website, we may also collect clickstream data (e.g. server address, domain name, device type, browsing software) which may be stored on the Website’ server. This information can be combined with information you have provided to us which will enable us to analyze and better customize your visits. We may use clickstream data for traffic analysis or e-commerce analysis of the Website, to determine which features of the Website are most or least effective or useful to you.
   Our Website uses Google Analytics to collect information about you and your behaviors which help us understand how our customers use the Website. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
4. Mobile and Location Information

   Edenshaw’s Website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you use mobile-enabled services provided by our Website, we may receive information about you from your mobile device. This may also include information about your precise location if you have enabled location-based services on your mobile device. Some devices may allow you to opt-out of this collection or access, and in those cases, you may be able to subsequently stop the collection or access. Please review your device settings for more information.[1]

   [1] NTD: When collecting Personal Information, any technological product must default to the highest level of confidentiality without any action on the part of the individual. To the extent your company has any control over the above privacy parameters, you must ensure access to certain device information is deactivated.

5. Processing Related to Residential and Commercial Real Estate Transactions
   To facilitate completion of transactions, such as purchase and sale of condominium and other real estate properties, other with post-closing and after-sales customer care purposes and/or for property management purposes we collect Personal Information from parties to the transaction, including prospective customers. Edenshaw may collect Personal Information from the following, including but not limited to a Vendor’s solicitor or Purchaser’s solicitor, the Teraview Electronic Registration System, condominium corporation(s), financial institutions, and regulatory authorities such as the Home Construction Regulatory Authority (HCRA) and Tarion Warranty Corporation.
6. Other
   Edenshaw may collect Personal Information when you interact with our Website, including when you access the Website, purchase goods or services, register or create or edit your account, sign up to receive newsletters and information, fill out online surveys or forms, send or respond to our emails, or otherwise communicate with us.

6. DISCLOSURE OF PERSONAL INFORMATION

6.1 Disclosure and Sharing Personal Information With Third Parties
Personal Information may be transferred or disclosed by Edenshaw to third parties for purposes consistent with terms of this Privacy Policy including, but are not limited to the following types of third parties:

1. Content management systems;
2. Customer management systems;
3. Email marketing vendors;
4. Email service providers;
5. Government or law enforcement entities;
6. Hosting providers;
7. Internet service providers;
8. Operating systems and platforms;
9. Parties that need to operate the Website;
10. Affiliates;
11. Data analytics providers;
12. Fraud prevention services vendors;
13. Social networks;
14. Financial transactions processors; and
15. Advertising networks.

6.2 Transfers and Disclosure of Personal Information to Other Third Parties Associated with Real Estate Transactions and Property Management
To facilitate completion of transactions, post-closing, and after-sales customer care purposes and/or for property management purposes, Edenshaw may disclose, transfer, or distribute Personal Information to third parties as reasonably necessary to complete the transactions. Such disclosure may include but is not limited to the following entities:

1. A third-party sales software supplier to facilitate electronic execution and delivery of all sales documentation and condominium disclosure documentation;
2. Companies or legal entities that are associated with, related to, or affiliated with the Vendor for the purposes of constructing the project, customer care and property management (including leasing the Dwelling Unit on behalf of the Purchaser);
3. Financial institutions providing mortgage financing, banking and/or other services to the Purchaser relating to the transactions (contact information only);
4. Lawyers providing legal services to the Purchaser relating to Agreement transactions (contact information only);
5. Insurance companies providing insurance coverage with respect to the Property (or any portion thereof) and/or the common elements of the Condominium, including without limitation, title insurance companies;
6. Trades/suppliers or sub-trades/suppliers who have been retained by or on behalf of the Vendor (or who are otherwise dealing with the Vendor) to facilitate the completion and finishing of the Unit and the installation of any extras or upgrades ordered or requested by the Purchaser;
7. Providers of cable television, telephone, telecommunication, hydro-electricity, chilled water/hot water, gas and/or other similar or related services to the Condominium and/or the Dwelling Unit;
8. Relevant governmental authorities or agencies including, without limitation, the Land Titles Office, the Ministry of Finance for the Province of Ontario (with respect to the Land Transfer Tax) and Canada Customs & Revenue Agency (CRA) (with respect to the Applicable Taxes); CRA, to whose attention the T-5 interest income tax information return and/or the NR4 non-resident withholding tax information return is submitted (where applicable), which will contain or refer to the Purchaser’s social insurance number or business registration number (as the case may be), as required by Regulation 201(1)(b)(ii) of the income Tax Act;
9. The Vendor’s solicitor or Purchaser’s solicitor to facilitate interim occupancy and/or final closing of agreement transaction, including the closing by electronic means via the Teraview Electronic Registration System and electronic delivery of documentation via the internet; and
10. The Condominium for purposes of facilitating the completion of the Condominium’s voting, leasing and/or other relevant records, and to the Condominium management/administration functions (contact information only).

6.3 Transfers and Disclosure of Personal Information to Other Third Parties associated with the Vendor Involved in Real Estate Projects and Property Management
Edenshaw may transfer and disclose Personal Information to companies or legal entities that are associated with, related to, or affiliated with the vendor for the purposes of constructing the project, customer care and property management (such as leasing a dwelling unit on behalf of a purchaser) including but not limited to:

1. Lawyers providing legal services to a purchaser relating to a transaction contemplated by an agreement (contact information only);
2. The Vendor’s construction lender, the project monitor;
3. The Vendor’s designated take-out lender;
4. Tarion Warranty Corporation;
5. Home Construction Regulatory Authority (HCRA) and/or any warranty bond provider and/or excess condominium deposit insurer engaged in connection with the development and/or construction financing of a condominium insurance companies providing insurance coverage with respect to the property (or any portion thereof) and/or the common elements of a condominium, including without limitation, title insurance companies;
6. Trades/suppliers or sub-trades/suppliers who have been retained by or on behalf of the Vendor to facilitate the completion and finishing of a unit and the installation of any extras or upgrades ordered or requested by a Purchaser;
7. Providers of cable television, telephone, telecommunication, hydro-electricity, chilled water/hot water, gas and/or other similar or related services to a condominium and/or dwelling unit (contact information only);
8. The Vendor’s solicitor or purchaser’s solicitor to facilitate interim occupancy and/or final closing of a transaction, including the closing by electronic means via the Teraview Electronic Registration System and electronic delivery of documentation via the internet; and;
9. The Condominium for purposes of facilitating the completion of the Condominium’s voting, leasing and/or other relevant records, and to the Condominium’s property manager for the purposes of facilitating the issuance of notices, the collection of common expenses and/or implementing other condominium management/administration functions (contact information only).

6.4 Reason(s) for Sharing Personal Information
Edenshaw may transfer and disclose personal information to third parties for purposes consistent with this Privacy Policy, including without limitation:

1. To manage our interactions with you;
2. To process transactions;
3. To enforce our Terms of Service;
4. To market to you via email;
5. To provide you with advertisements;
6. To prevent or investigate fraud;
7. To prevent or investigate criminal activity;
8. To analyze your interactions with us or our Website.

The chart below provides examples of the Purposes for which different types of Personal Information, and other information may be transferred and disclosed by Edenshaw:

Type of Information	Example of How We Use This Information
Name Postal/shipping address Billing address Phone number Email address Products or services purchased, obtained, or considered	Auditing compliance; Auditing transactions that the customer has entered into; Enforcing our Terms of Service; Marketing and advertising; Participation in surveys and contests; Performing services; Processing or fulfilling orders or transactions; Processing payments; Protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activities; Providing customer service; Resolving disputes; Undertaking activities to verify or maintain the quality or safety of our services or devices; Verifying customer information; To facilitate completion of transactions, post-closing, and after-sales customer care purposes and/or for property management purposes.
Social Insurance Number Driver’s license Province/Territorial ID card Passport number	Auditing compliance; Auditing transactions that the customer has entered into; To facilitate completion of transactions, post-closing, and after-sales customer care purposes and/or for property management purposes; Protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activities.
IP address Device identifier Browsing history Search history Information regarding your interaction with our Website or application Information regarding your interactions with advertisements	Analytics; Counting ad impressions to unique visitors; Debugging to identify and repair errors; Detecting security incidents; Marketing and advertising, including, targeted advertising Understanding the location of the individual; Verifying position and quality of ad impressions.
Inferences drawn from any other information to create a profile about the customer	Marketing and advertising, including targeted advertising

7.MANAGING YOUR PERSONAL INFORMATION

7.1 Limiting the Collection and Processing of Personal Information
Edenshaw takes care to ensure that Personal Information you provide to us is accessed internally only by individuals that require access to perform their tasks and duties, and externally only by service providers with a legitimate purpose for accessing it.

7.2 Accuracy of Personal Information
Edenshaw takes reasonable steps to keep your Personal Information as accurate, complete and up-to-date as necessary to fulfill the purpose for which your Personal Information has been collected. If desired, you may verify the accuracy and completeness of your Personal Information in our records with our Privacy Officer.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date Personal Information in your file, we will remedy any such errors on a timely basis. You may request correction of the Personal Information we hold about you, though we may need to verify the accuracy of the new information you provide to us. If inaccurate Personal Information is mistakenly sent to a third-party, we will communicate relevant changes to the third-party where appropriate.

7.3 Retention of Personal Information
Edenshaw will store your Personal Information only for as long as is reasonably necessary to fulfill the purpose for which the Personal Information was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once your Personal Information is no longer needed, we will securely and effectively dispose of it.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this anonymized information indefinitely without further notice to you.

7.4 Your Rights
Subject to certain legal and contractual restrictions, you have the following rights with regard to their Personal Information:

1. The right to access the Personal Information that we have collected about you;
2. The right to request that we amend any of the information that we have collected about you;
3. The right to withdraw your consent to the Processing of your data; and
4. The right to lodge a complaint regarding our collection, sharing and Processing of data with competent authorities in the proper jurisdiction.

7.5 Request for Access to Personal Information and Processing
You may request access to or correction of your Personal Information (subject to limited exceptions prescribed by law) by submitting a written request to the Privacy Officer (see “Accountability and Addressing Your Inquiries” below) (a “Privacy Request”). A Privacy Request enables you to receive a copy of the Personal Information we have collected from you and information about how we are Processing it. We may need to request specific information from you to help us confirm your identity and right to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. To verify your identity, you will need to provide us with the following information with your request:

1. Name;
2. Email address; and, in certain limited circumstances,
3. Drivers License.

Please note that we may be unable to process your Privacy Request if you do not provide us with the above information, as applicable.
We strive to respond to Privacy Request(s) within 30 days of receipt. However, some requests may take longer. We will notify you in writing if we need more time to respond. Edenshaw may not always be able to comply with your request for access to Personal Information for specific reasons such as certain exceptions in the law, which you will be notified of, if applicable, at the time of your request. If we do deny your Privacy Request(s), we will provide you with the reasons for such denials.

7.6 Request for Deletion or Removal of Personal Information
In some circumstances you have the right to request that we delete or remove your Personal Information where there is no good reason for us to continue Processing it. You may also ask us to delete or remove your Personal Information where you have successfully exercised your right to object to Processing, where we may have processed your information unlawfully or where we are required by law to erase your Personal Information. We may not always be able to comply with your request for deletion of Personal Information for specific legal reasons which you will be notified of, in writing, within thirty (30) days of the time of your request.

8.PROTECTING YOUR PERSONAL INFORMATION

8.1 Integrity and Security

Edenshaw uses industry standard measures, including administrative, organizational, technical, and physical safeguards, to help protect Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We implement measures and processes to help us to keep your Personal Information secure and to maintain its quality, such as keeping electronic files in a secured environment with restricted access and use. We further protect and safeguard your personal information by using SSL or other secure connection technologies when receiving or sending personal information beyond internal networks. We regularly review our security and related policies to adapt the technology as new threats evolve and monitor our systems to help ensure the highest level of availability. If you have any questions about the security of our Website, you can reach out to our privacy personnel. Contact information can be found at the end of this Privacy Policy document.[3]

Access to private, sensitive, and confidential information, including Personal Information, is restricted to authorized employees or contractors with legitimate business reasons. Edenshaw’s employees and contactors understand the importance of keeping your Personal Information private. All employees and contractors are expected to maintain the confidentiality of Personal Information.

[3] NTD: Please include details of any further measures which are used in the protection and security of collected Personal Information.

8.2 Risks
Despite the foregoing security measures and significant steps Edenshaw has taken to protect your Personal Information, no company can fully eliminate all security risks associated with the Processing of Personal Information. In the event there has been a breach of our security safeguards which involve your Personal Information, including the unauthorized access, use or disclosure of your Personal Information, loss of your Personal Information, or other breach.

9. WEBSITE AND APPLICATIONS GOVERNED BY THIS PRIVACY POLICY

Our Website and any of our applications available from our Website or third-party platforms[4] are governed by the provisions and practices stated in this Privacy Policy. Our Website and such applications may contain links to third-party sites or applications that are not governed by this Privacy Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Privacy Policy will no longer apply once you leave our Website or such applications, and that we are not responsible for the privacy practices of third-party sites or applications. We therefore suggest that you closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use, and disclose your Personal Information.

[4] NTD: Please confirm if Edenshaw has any applications that should be covered by this Privacy Policy. We have assumed that the “Purchaser Login” page leading to the EnBuilder platform is captured by this paragraph.

10. GOVERNING LAW

This Privacy Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.

11. PERSONAL INFORMATION OUTSIDE OF CANADA

Personal Information provided to us may be transferred outside of Canada, including the United States. You acknowledge and agree that, as a result, your Personal Information may be processed, used, stored, transferred, or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.[5]

We plan to transfer data to the United States. This means that your information may be processed in a country outside of Canada and it may be accessible to law enforcement authorities and national security authorities of that country and jurisdiction.

[5] NTD: If you are knowingly transferring or disclosing Personal Information outside of Canada, you must disclose the name of the individual or organization to whom you are transferring. In such cases, it may be necessary to include a provision in this Privacy Policy which relates specifically to the jurisdiction in which the individual or organization is located.

12. ACCOUNTABILITY AND ADDRESSING YOUR INQUIRIES

Your privacy is very important to us. We are happy to provide you with a copy of this Privacy Policy and to discuss any of its contents with you.
Edenshaw’s Privacy Officer is responsible for the implementation of this Privacy Policy and monitoring our adherence to its terms and all applicable laws. The Privacy Officer also handles questions and concerns about our Privacy Policy, as well as Personal Information access requests and complaints. The following person is the Privacy Officer accountable and responsible for our privacy practices and procedures and may be contacted at:

Brian Davis
Special Projects Manager[1]
Edenshaw Management Limited
905-990-3500
privacypolicy@edenshaw.com

You may submit a complaint to us by contacting the Privacy Officer at the contact information above. Residents of Quebec may submit a complaint with the Office of the Privacy Commissioner of Quebec by filling out this form or calling 1-888-528-7741. Residents of Canada may also lodge a complaint with the Office of the Privacy Commissioner of Canada by visiting this page or calling 1-800-282-1376.