2. Our Commitment to Your Privacy
H&R PML is responsible for all personal information under our control.
Contact information for our Chief Privacy Officer is set out below:
Chief Privacy Officer
H&R Developments and Lindvest Properties Limited
3625 Dufferin Street
Suite 500, Downsview
Ontario M3K 1N4
Tel: (416) 635-7520
Fax: (416) 635-9921
H&R PML is responsible for personal information in our possession or custody, including information that has been transferred to third parties for processing. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their possession or control.
4. Identifying Purposes
We will use reasonable efforts to clearly identify and document the purposes for which we may collect, use or disclose personal information at or before the time of collection. However, generally, as part of our business operations, we collect and use certain personal information strictly for the following purposes:
- in order to respond to requests for information that we receive via our websites or otherwise;
- in order to perform credit evaluations with respect to purchasers and guarantors;
- in order to collect on debts owed by an individual to H&R PML;
- to obtain purchaser feedback.
The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances.
If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose before such additional use. We will state the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.
If we have obtained your express consent (in writing or electronically) to do so, H&R PML may also use your personal information to provide you with further information about our new housing and condominium developments and our business.
5. Obtaining Consent
We will collect, use and disclose personal information only with the knowledge and consent of the individual, except in certain limited circumstances, as described below. However, in certain appropriate circumstances that involve the collection of less sensitive information, consent may be implied.
We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information has been collected, but before our use for that purpose.
We will not, as a condition of selling you a home or condominium, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary. In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by regulation; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.
You may choose not to provide us with some or all of your personal information. In addition, you may withdraw your consent with respect to a particular use or disclosure of your personal information at any time by sending written instructions to our Chief Privacy Officer at the address and/or email address set out in Section 3 above.
Where legal requirements permit, H&R PML will cease the use or disclosure of your personal information. Please note, however, that depending on the circumstances this may hamper our ability to provide you with certain services or conclude a transaction with you.
6. Limiting Collection
We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.
The types of personal information we collect from our customers includes, without limitation:
- home address;
- home phone number;
- e-mail address;
- financial information to determine credit worthiness.
7. Limiting Use, Disclosure and Retention
H&R PML does not use or disclose personal information for purposes other than those for which it is collected, except with the express consent of the individual or as required by law.
H&R PML will retain personal information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements. After such relevant time period has expired, our records are amended so that names are removed and the information can no longer be identified with an individual.
Any inaccuracies we discover will be corrected promptly. We will promptly correct your file with us upon receipt of any notice from you that any information we hold about you is inaccurate. In addition, to the extent your personal information has been disclosed to others, we will, as soon as practicable, advise them of any pertinent amendments to the information released to them.
Our methods of protection include, without limitation, physical measures (for example, locked filing cabinets and restricted access to offices), organization measures (for example, limiting access on a “need to know” basis), and technological measures (for example, the use of passwords and encryption).
When necessary, personal information may be stored on offsite computer servers or with networked online storage systems (“cloud storage”), provided, however, that such computer servers and/or cloud storage are located in controlled facilities where you personal information is in all material respects, protected in accordance with this policy.
We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.
Upon written request addressed to our Chief Privacy Officer, we will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.
We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide 6 the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.
If you feel that your personal information we hold is inaccurate or incomplete you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the personal information. Any such request must be in writing.
In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.
If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.
12. Challenging Compliance
If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376. #1922952 v1 | 4008907
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