Last Updated: September 12, 2025
Crown Realty Partners and its affiliates (together, “Crown”, “we”, “us”, or “our”) are an integrated commercial real estate investment and management firm. Crown’s realty related services include investment products, property, construction and asset management services (“Services”) and may be provided via our website, mobile applications, investor/tenant service portal, or technologies installed and used at our properties.
In this Privacy Policy (“Policy”), you will find information about the principles that guide us in how we collect, safeguard, use, transfer, access, dispose, disclose, and otherwise process Personal Information you provide to us in the course of interacting with us through our website, mobile applications and technologies installed on or used in our properties or Personal Information that you otherwise provide to us as you engage with us for our support, Services and otherwise, and your choices regarding our use of your Personal Information.
Crown has established this Policy to comply with applicable regulatory and legal requirements regarding the collection, use, disclosure and protection of Personal Information (as defined below) of investors in Crown managed investment funds (“Investors”) or clients to whom it provides various Services (collectively, “Clients”). Crown is committed to protecting Personal Information and our employees are responsible for and obligated to protect such information at all times.
We are committed to protecting Personal Information of Clients and Investors. We have established practices and procedures to ensure that this information is appropriately safeguarded and have appointed a Chief Privacy Officer to administer the process. All of our employees, contractors, consultants, agents and third-party service providers are bound to comply with this Policy.
This Policy is effective as of the date “Last Updated”, above, and will remain in effect except with respect to any of its provisions that are changed in the future. We reserve the right to change this Policy at any time. Changes, modifications, additions, or deletions will be effective immediately upon their posting to our websites or upon you being otherwise notified. Your continued use of our websites after we post any such modifications will constitute your acknowledgement of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “Last Updated” date found at the beginning of this Policy when we post changes to it.
A Client/Investor may withdraw all or part of their consent for the collection, use, disclosure or other processing of Personal Information at any time upon reasonable notice to Crown in writing, and subject to legal or contractual restrictions. The withdrawal of consent may affect or limit Crown’s ability to continue to provide Services, act on your behalf or engage with you as you would like. Any withdrawal of consent will apply thereafter and not to information handling practices that have been previously undertaken based on prior consent.
By accessing our Services, providing Personal Information to us, visiting the our websites and clicking “I Agree to Crown’s Privacy Policy”, or engaging with us otherwise, Clients and Investors accept the terms of this Policy and consent to the collection, use, disclosure, retention, and processing of Personal Information as described herein.
Crown will not knowingly obtain consent from those individuals who are minors under fourteen (14) years of age, seriously ill, or mentally incapacitated and we shall therefore obtain consent from a parent, legal guardian or person having power of attorney of such an individual.
If you are an individual under the age of fourteen (14) years, you must access or use our websites only with the permission and involvement of your parent or guardian.
“Personal Information” is information that identifies an individual directly or indirectly through reasonably available information and includes, but is not limited to, their name, email, address, age, marital status, race/nationality, financial records, religion, or social insurance number. It may also include information on how you use our websites, mobile applications, and your visits to our properties. Personal Information does not include business contact information that is used solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.
The Personal Information that Crown collects includes, but is not limited to:
Clients and Investors are requested to notify Crown as soon as possible of any changes, deletions or corrections to their Personal Information so that Crown may keep such information up-to-date.
We collect Personal Information for purposes that include, but are not limited to:
Crown may collect Personal Information in writing, electronically or verbally. We minimize our collection and use of Personal Information to what is needed for these purposes. Personal Information may be collected from the following sources:
Personal Information may be collected by Crown in a number of ways, including in person, our website, by mail, by fax, 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.
For the purpose of maintaining quality service, telephone calls to Crown’s customer services lines may be recorded. If your call is subject to a quality assurance program, you will be advised prior to speaking to a representative.
Crown may collect Personal Information through cookies on our websites. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our websites again. This helps us to understand your preferences based on previous or current activity on our websites, 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 websites you clicked.
Our websites may use retargeting ads to advertise online. Retargeting uses cookies from third-party vendors like Google to track visitors. This tracking enables the third-party vendors to display our ads to people on various sites across the internet based on their visits to our websites.
We may also use web beacons (small pieces of data that are embedded in images on the pages of our websites) and auditing software to track page views and entry and exit points to and from our websites. We may use web beacons, cookies, customized links and/or similar technologies to determine whether electronic messages and newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form and will not contain any Personal Information.
Some cookies are automatically deactivated upon your access and use of our websites. However, unless you activate cookies, you may be unable to fully utilize and access all areas and features of our websites. You may activate cookies by visiting our websites and clicking “Accept All Cookies”. Some third-party service providers may also place their own cookies on your browser. Note that this Policy only covers Crown’s use of cookies and does not include use of cookies by such third parties.
When you visit our websites, we may also collect clickstream data (e.g. server address, domain name, device type, browsing software) which may be stored on our website’s 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 of our websites, to determine which features of our websites are most or least effective or useful to you.
We may also use analytics tools such as heatmaps or session replay software to better understand how visitors interact with our websites. These tools collect aggregated information about clicks, taps, scrolling, and navigation patterns, which we use to improve site functionality and user experience. This information is not used to identify individual users.
The features on our websites 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.
If you post a review, make a comment, or otherwise submit Personal Information on a public forum such as social media accounts or public forums on our website or other applications, your communications may be viewable by the public. When voluntarily disclosing Personal Information about yourself with other Crown users or the general public, we are unable to control what may be done with that content. You should take all necessary precautions to protect your private information by not posting or publishing any information that you do not want in a public domain. While we strive to provide the highest level of confidentiality, you should review your personal privacy settings to further restrict any or all parts of your profile or other certain content or information.
Crown may collect Personal Information when you interact with our websites, including when you access our websites, 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.
Personal Information shall not be used or, disclosed or otherwise processed for purposes other than those for which it was collected. We may delegate our authority for processing of your Personal Information to third-party individuals and organizations who assist us with providing our Services and administering our business, and for such other purposes as set forth below, including:
If you believe that a third-party has inappropriately disclosed your Personal Information to us, please contact that third-party directly. If the third-party does not sufficiently respond to your inquiries, please let us know immediately.
The collection of Client Personal Information will be limited internally to those functions for which it is necessary for Crown to provide Services to a Client and Investors, and for third-party service providers to be able to provide services to Crown. Before Crown may use Personal Information for a purpose not previously identified to a Client, the new purpose shall be identified and consent will be obtained from the Client before the information is used for the new purpose, unless the use is required by law. Crown has established policies and procedures, including an employee Code of Conduct and attestation of compliance, to ensure Client and Investor confidentiality.
Our websites and any of our applications available from our websites or third-party platforms are governed by the provisions and practices stated in this Policy. Our websites and such applications may contain links to third-party sites or applications that are not governed by this Policy. Although we endeavour to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our websites 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.
For safety and security reasons, Crown may use video surveillance technologies at Crown managed properties to monitor the public areas of those properties. Video images of individuals that access these properties and/or vehicles and license plate numbers may be captured. We will post notices at the point of entry of any such areas where we may use this technology. If you do not wish to have your images captured by us, please do not enter those areas.
We may disclose video surveillance footage to law enforcement or other government agencies where we believe such disclosure is: (i) permitted or required by law; (ii) necessary to protect our properties, visitors, customers or employees; or (iii) reasonable in connection with a law enforcement investigation.
Crown maintains administrative, organizational, technical and physical, safeguards, including electronic and procedural controls consistent with regulatory standards, to protect Personal Information in its possession. Reasonable measures (such as systems access security controls, safeguards to detect and prevent security system failures, restricted access and employee training) have been implemented to help protect Personal Information from loss, misuse, theft, alteration, unauthorized access or disclosure.
Crown remains responsible for Personal Information while it is in the hands of third-parties and protects this information through contractual agreements to afford the same level of protection as given by Crown. Crown does not sell or lease Personal Information to third parties nor does it share Personal Information with third parties for their marketing purposes. It should be noted however, that security risks cannot be fully eliminated. Therefore, Clients and Investors are requested to:
Personal Information will be retained for at least seven years (unless there are legal requirements that require its further retention) after which all documentation will be destroyed in a manner commensurate with its sensitivity.
Access to private, sensitive and confidential information, including Personal Information, is restricted to authorized employees or contractors with legitimate business reasons. Crown’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.
Crown 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. We will not use or disclose any collected Personal Information outside of the purposes described in this Policy unless you have otherwise consented or it is required or permitted by law.
We do not sell, trade, rent or otherwise share for marketing purposes the Personal Information that we collect with third parties, unless you consent or authorize us to do so. We limit the Personal Information provided to the aforementioned affiliate and third-party service providers to the extent necessary for them to provide the services. We do not allow these third-party service providers to use your Personal Information for their own purposes and only permit them to access and process your Personal Information for specified purposes and in accordance with our instructions. Such service providers are required by contract to safeguard any Personal Information disclosed or transferred by us.
Crown takes all 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 Chief 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.
Personal Information is maintained on Crown’s networks or on the networks of its service providers. Personal Information may also be stored in a secure off-site storage facility. Crown retains Personal Information only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. Crown has established policies and procedures relating to the retention and disposal of its records including Personal Information. This includes retaining Personal Information for at least seven years after which all documentation will be destroyed in a manner commensurate with its sensitivity.
You may request access to your Personal Information,. 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. Crown may not always be able to comply with your request for access to Personal Information for specific reasons which you will be notified of, if applicable, at the time of your request.
In some circumstances you have the right to request that we delete or remove your Personal Information. 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.
Despite the foregoing security measures and significant steps Crown has taken to protect your Personal Information; no company can fully eliminate all security risks associated with the Processing of Personal Information. With that in mind, we cannot guarantee the security of any Personal Information provided to or received by us. We encourage you to provide only the Personal Information you are comfortable with providing to a third-party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.
In the event of a unauthorized access to, use or disclosure of Personal Information, Crown will investigate and assess the implications of the breach, and will notify affected individuals as required by law. as soon as feasible. Where the breach creates a real risk of significant harm to an individual, Crown will notify the OPC and/or the provincial regulator, as the case may be, and as required by law, as well as affected individuals within 30 days of identification of the breach, and take remedial measures as applicable.
This 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.
Clients and/or Investors may contact Crown’s Chief Privacy Officer in writing, including by email, if they wish to:
Requested information will generally be provided within 30 days of the request being made. Crown’s managing partner/privacy officer may be contacted at:
Attn: managing partner/privacy officer
Crown Realty Partners
400 University Avenue
Suite 1900
Toronto, ON M5G 1S5
416.927.1851
info@crp-cpmi.com
If a Client/Investor is not satisfied with the results of an investigation or the corrective measures taken by Crown, they may exercise the remedies available under law by contacting the OPC at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3