Privacy Policy

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 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, you will find information about the principles that guide us in how we collect, use and disclose personal information through our websites, mobile applications and technologies installed on or used in our properties, and your choices regarding the use of your personal information.

OverviewOrganizations, such as Crown, which collect, use or disclose Personal Information (as defined below) in the course of commercial activities must comply with the obligations set out in Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”).  PIPEDA only applies to information about natural persons.  Similar requirements are set out by the Alberta Personal Information Protection Act; the British Columbia Personal Information Protection Act; and, the Quebec Act Respecting the Protection of Personal Information in the Private Sector.  Crown’s responsibilities also extend to any Personal Information it transfers to a third-party for processing.

Crown has established a privacy 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 realty 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 Privacy Officer to administer the process. All of our employees, contractors, consultants, agents and third-party service providers are bound to comply with this Privacy Policy.

By accessing our Services, Clients and Investors accept the terms of this Notice and consent to the collection, use, disclosure and retention of Personal Information as described herein.

If you have any questions about this Privacy Policy, please contact us by email or in writing to:

Attn:  Chief Privacy Officer
Crown Realty Partners
400 University Avenue
Suite 1900
Toronto, ON M5G 1S5
416.927.1851
[email protected]

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“Personal Information” is information that identifies an individual 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.

Examples of information collected includes:

• Identifiers, which include name, address (business or home), telephone number; email address, fax number, screen name, user ID and password, IP address, or MAC address;
• Financial information for certain investment-related Services offered to investors;
• Health screening information for visitors to Crown managed properties related to health, previous travels, your contacts and thermal and symptom screening to ensure safe visits at Crown managed properties and to comply with current health guidelines in connection with public health outbreaks;
• Information relating to Internet activity or other electronic network activity, which includes operating system type and version, web server type and version, PHP version, database type and version, cookie information, device information, browsing activities, and platform or mobile application use data, referring domain, destination domain and destination path, performance, security, software configuration, website user statistics and use and viewing activity records, and communication preferences;
• Mobile phone number, mobile country code, unique device identifier, mobile advertising identifier (assigned by your mobile platform), information about the screen size of your mobile device(s), the date and time of your device use, and other mobile device-related information;
• Geolocation data, which includes geographic information derived from your IP address or MAC address; latitudinal and longitudinal data; and

Other information, including the contents of Client/Investor communications with Crown, whether via email, social media, telephone or otherwise, and inferences may be taken from other personal information collected.

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.

Crown collects and maintains Personal Information about Clients and Investors in connection with the offering and sale of interests in Crown funds, the provision of various realty related services, Client/Investor communications, or otherwise as required by law.

We collect and maintain Personal Information in order to:

• Establish, service and administer investments made in a Crown fund or services provided (including providing financial, tax or other information that may be requested or needed to support these investments or services);
• Assess an Investor’s eligibility in a Crown fund;
• Execute transactions;
• Protect Crown and its Clients/Investors from error and fraud;
• Establish Crown’s legal rights or defend against legal claims;
• Track and monitor traffic to Crown’s websites; or.
• Identify health information for building occupants and visitors to Crown managed properties to ensure compliance with public health requirements

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:

• Subscription agreements or other forms that are submitted by an investor or prospective investor or client;
• Service agreements;
• Transactions with Crown or any of its affiliates;
• Meetings and telephone conversations between Crown and a Client;
• Visits to Crown’s websites, mobile applications, social media visits to Crown’s properties; and
• Other information provided.

A Client/Investor may withdraw all or part of their consent for the collection, use or disclose 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 Crown’s ability to continue to provide Services.

Personal Information shall not be used or disclosed for purposes other than those for which it was collected.  Crown may disclose Personal Information to third parties and to Crown affiliates, when necessary and without the consent of a Client, including:

• service providers, such as lenders, financial institutions, government authorities, or brokers used to finance or facilitate transactions by, or operations of, a Crown fund;
• other service providers such as accounting, legal, or tax preparation services;
• regulatory, tax or other government authorities and agencies. Crown will only disclose Personal Information to a governmental entity or other regulatory or self-regulatory organization when required to do so by such laws, regulations, or by court order;
• Crown affiliates for various purposes permitted by law, including affiliates’ advertising and marketing of their products and services to a Client/Investor;
• Other individuals or entities, when Crown believes that disclosure is necessary to detect, prevent or report suspicious activities, prevent physical harm, financial loss or violations of agreements and policies; and
• For specific products or services, including third-party fintech apps and data aggregators, when a Client/Investor has provided their consent.

The collection of Client 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.

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 physical, electronic and procedural controls consistent with regulatory standards to safeguard 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, 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:

• Create a strong and unique password for devices and user accounts.
• Never share passwords (note that Crown will never ask for a password, including in any unsolicited communication such as letters, phone calls or email messages).
• Log out of their user account once finished using it.

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.

Crown may use cookies and other similar technologies on its websites. A “cookie” is a unique numeric code that we transfer to your device so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. The use of cookies allows Crown to measure website activity to provide a better user experience. Cookies and other similar technologies may be used to advise on the length of a visit, the pages on a website reviewed, the prior website visited, and the name of the user’s internet service provider.

Most internet browsers accept cookies by default. Cookies may be blocked by activating the setting on the browser that allows the user to reject all or some cookies. Although a user is not required to accept cookies, if these cookies are blocked or rejected, a user may not have access to all of the features available through the Services.

Crown may use third party analytics such as Google Analytics or other similar analytics services to monitor usage and improve content and functionality. For information on how Google processes and collects your information regarding Google Analytics and how you can opt-out, please see https://tools.google.com/dlpage/gaoptout.

Clients may contact Crown’s Chief Privacy Officer in writing if they wish to:

• access their Personal Information;
• correct their Personal Information;
• withdraw consent to any use and disclosure of their Personal Information (however, this may limit the Client’s opportunity to access Crown’s services or funds);
• obtain more information or have concerns; and
• file a complaint relating to how Crown has handled their Personal Information (if a Client is dissatisfied with the results of an investigation of a complaint, they may bring the complaint to the attention of the Office of the Privacy Commissioner of Canada (“OPC”)).

Requested information will generally be provided within 30 days of the request being made.  Crown’s Chief Privacy Officer may be contacted at:

Attn:  Chief Privacy Officer
Crown Realty Partners
400 University Avenue
Suite 1900
Toronto, ON M5G 1S5
416.927.1851
[email protected]

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