Last Updated: March 26, 2021
Crown Realty Partners and its affiliates (together, “Crown“, “we“, “us“, or “our“) are an integrated commercial real estate investment and management firm. Our services include our websites, mobile applications, investment products, our service portal offered to tenants of our managed properties, technologies installed and used by Crown on our properties, and other realty services (collectively, “Services“).
Crown may collect personal information about you in writing, electronically or verbally. We may collect personal information about you in connection with the offering and sale of interests in Crown managed investment funds, the provision of Services, or as otherwise required by law. Crown collects and uses personal information only as necessary to provide our Services, including to develop, assess, and improve our Services. We only collect personal information if non-identifying information will not suffice. We minimize our collection and use of personal information to what is needed for these purposes.
We may collect the following categories of personal information about you:
- 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 your health, your 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 your communications with us, whether via email, social media, telephone or otherwise, and inferences we may make from other personal information we collect.
We collect personal information about you in order to properly identify you, to contact you or your designated representatives, to establish, service and administer investments made in a Crown managed investment fund or related services, to understand your investment needs, to process and execute investment transactions, to make appropriate investment decisions on your portfolio, to protect against error and fraud, to manage the administration of your account, to manage and safeguard Crown-managed properties, to provide you with Services, to establish Crown’s legal rights or defend against legal claims, to inform you of Services that may be relevant to you, to manage your preferences and to provide a more personalized experience, and to satisfy legal, regulatory, custodial and tax reporting requirements.
Crown may disclose personal information to third parties and to Crown affiliates, including to:
- Lenders, financial institutions, government authorities, or brokers used to finance or facilitate transactions by, or operations of, a Crown managed investment fund;
- Service providers for purposes such as accounting, legal, or tax preparation services; servicing accounts, conducting transactions, surveys, market research, data analysis, reporting, marketing, and development of our products and services;
- Regulatory, tax or other government authorities and agencies;
- Our affiliates (i.e., companies related to us by common ownership or control) for various purposes permitted by law, including our affiliates’ advertising and marketing of their products and services to you;
- Other individuals or entities, when we believe that disclosure is necessary to detect, prevent or report suspicious activities, prevent physical harm, financial loss or violations of our agreements and policies; and
- For specific products or services, including third-party fintech apps and data aggregators, when you have given your consent.
At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party’s jurisdiction, including laws with respect to disclosure of such information, and may be accessible by regulatory authorities in other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession. Crown does not sell or lease personal information to third parties nor does it share personal information with third parties for their marketing purposes.
We may also be required by law to disclose information to government regulatory authorities which collect, use and disclose such personal information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings.
For safety and security reasons, we may use video surveillance technologies at Crown managed properties to monitor the public areas of those properties. Video images of individuals that access our 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.
For questions about our use of video surveillance at our properties, please contact our Privacy Officer.
You may also opt out of receiving promotional emails from Crown by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Confidentiality of personal information is a fundamental principle of Crown. To that end, we restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. No employee may release confidential User information, including the fact that a person either is or is not an Investor, unless required by law or with the Investor’s express consent. Each employee of Crown and any related parties is responsible for ensuring the confidentiality of all personal information they may access. To maintain awareness of our policies and practices in this regard, at least annually we have all of our employees sign a code of conduct containing policies on the protection of personal information and affirming their undertaking to faithfully abide by these practices.
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. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information.
You also play an important role in protecting your privacy and the confidentiality of your personal information. For example, you should:
Create a strong and unique password for your user accounts.
Never share your user accounts or password with anyone. We will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request.
Log out of your user account once you are finished using it, especially if you share your device with anyone else.
Have a strong and unique password on your device, too.
Your personal information is maintained on our networks or on the networks of our service providers. Your information may also be stored in a secure off-site storage facility. We retain personal information only as long as it is needed to fulfill the identified purposes or as may be required to comply with applicable laws. 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 To satisfy regulatory requirements, certain personal information may 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.
Most internet browsers accept cookies by default. You can block cookies by activating the setting on your browser that allows you to reject all or some cookies. The help and support area on your internet browser should have instructions on how to block or delete cookies. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you to when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all of the features available through the Services.
We may use third party analytics such as Google Analytics or similar analytics services. 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.
Crown will do its best to ensure that your personal information is correct and kept current. investors and clients 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.
With certain limited exceptions as provided in Privacy Legislation, you have the right to access your personal information held by us and to request that the information be corrected if it is inaccurate, incomplete or collected in violation of law. You may update or correct information about yourself by writing to Crown’s Privacy Officer, as further described below. We will respond to your written request promptly. Please note that Crown may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons to do so, or if the information has been securely destroyed. Subject to legal or contractual restrictions, we will provide you with an explanation if we are unable to fulfill your access request.
If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of, your personal information under our care and control, please contact the Privacy Officer at email@example.com, Attention: Privacy Officer.
Inquiries or complaints will be dealt with promptly. The Privacy Officer will acknowledge your query, investigate and provide you with a response within 30 days.
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3