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EMPIRE COMMUNITIES
PRIVACY STATEMENT

This Privacy Statement has been adopted by ECMI MANAGEMENT INC., and all of its associated and related companies, (referred to collectively as “Empire”). Some Empire businesses may have additional privacy policies or procedures that address the particular circumstances in which your Personal Information is handled.

At Empire, your privacy is very important to us. We want you to feel secure about any private information you provide to us. As part of our ongoing effort to keep you informed about our privacy practices, we have prepared this policy to inform you about Empire’s commitment to ensuring that the Personal Information obtained during the course of our activities remains accurate and confidential.

The provision of Personal Information to Empire means that the person concerned agrees and consents that we may collect, use and disclose their Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.

In most cases and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that certain services can only be offered if a person provides Personal Information to Empire. Consequently, if an individual chooses not provide us with any required Personal Information, we may not be able to offer the services requested. We will inform you of the consequences of the withdrawal of consent.


WHAT IS PERSONAL INFORMATION?


Personal Information means any information collected in any manner (e.g. verbally, written, electronically), recorded in any form (including audio and video recordings) about an identified individual or that is of a nature that an individual’s identity may be inferred or determined from such information.


WHY EMPIRE COLLECTS AND USES PERSONAL INFORMATION


Empire collects and uses Personal Information of customers, tenants, job applicants, consultants, strategic partners, agents, distributors, suppliers, contractors and other entities (including their employees) in the ordinary course of its businesses. This information allows Empire to:

• market and sell Empire homes and services to customers;
• rent homes, condominiums and other Empire properties to tenants;
• engage in various kinds of real estate transactions;
• communicate with, and provide information to, customers and others about products, services and offers that may be of interest to them, including in some cases products and services of carefully selected third parties;
• develop and maintain relationships with, among others, Empire customers, consultants, strategic partners, agents, distributors, suppliers, contractors and other entities;
• determine customer/tenant eligibility for financing or renting homes and accessing other services, including conducting initial and periodic credit checks;
• collect amounts outstanding from customers/tenants and those providing guarantees or other forms of security for customers/tenants;
• protect the rights, interests and property of Empire, customers/tenants and others;
• adhere to applicable legal and regulatory requirements; and
• accommodate various other purposes necessary to carry out its business that are generally consistent with these purposes.


TYPES OF PERSONAL INFORMATION WE COLLECT


The Personal Information we collect, use and disclose will depend upon the nature of our relationship and business with you. In most cases, it depends upon the products or services you are interested in, and the amount of information we need to communicate with you, assess eligibility, meet our obligations and run our businesses. Knowing you better helps us understand your needs and ultimately to provide the right products and services for you.

This website and Empire’s services are not directed to children under the age of 18, and we ask that minors not submit any Personal Information to us. If you have reason to believe a minor has provided us with Personal Information, please contact us to request that such information be deleted from our records.


HOW WE COLLECT PERSONAL INFORMATION AND OBTAIN CONSENT


Personal Information is collected from you directly online, over the telephone, in written form or in face-to-face meetings and visits. Empire collects Personal Information using various documents including registration forms, applications, questionnaires and surveys, purchase and lease agreement and other related documents. In certain cases, information collected using video or audio recording equipment can constitute Personal Information as well.

Empire may also collect Personal Information from third parties, such as when we contact references for employment or tenant applications, perform credit, government registry, social media and similar background checks. In some cases the third party may require you to provide separate consent to those checks.

Empire obtains your consent to collect, use and disclose Personal Information through this Privacy Policy, through direct consent forms or verbal requests, and by implication through your actions of providing it to us, depending on the circumstances and the sensitivity of the information. Information about an individual who engages with Empire in a business capacity (e.g. business address, phone number or email address) may be used to communicate with that individual for professional purposes without additional consent.

In most cases you are free to refuse or withdraw your consent at any time upon reasonable notice. Certain products and services can only be offered if a person provides Personal Information to Empire. Consequently, if an individual chooses not provide us with certain Personal Information, we may not be able to offer our products and services. In other cases, we may be required to use or store Personal Information for a period of time after you withdraw your consent, for legal or contractual purposes.

We use only fair and lawful methods to collect Personal Information and only collect, use and disclose Personal Information as is required to carry on our business and adhere to the law. Empire does not sell or rent Personal Information to third parties. Where Personal Information is shared with third parties for marketing purposes (such as strategic partners who offer products or services relevant to ours), it will be disclosed in this Privacy Policy or in separate communication to you.


USE OF VIDEO SURVEILLANCE AND RECORDINGS


Video equipment may be installed and operating in our for sale communities during the marketing period or common areas of our rental properties. The video equipment may have capabilities such as zoom, audio recording or night-vision features. The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.

The purpose this equipment is to ensure your safety, security and reasonable enjoyment (as well as that of other persons who are our customers/tenants), to ensure you have access to the premises, equipment and services that Empire provides, to preserve our property, and to deter crime.

Where required by law, signs will be posted informing you that video equipment is operating and recording your Personal Information.


USE OF AUDIO EQUIPMENT AND RECORDINGS


There are circumstances under which Empire may make audio recordings of communications with contractors, customers, tenants or others. There are several purposes for making the recordings including situations where there are performance issues in respect of Empire’s role as contractor, landlord or product or service provider, to ensure the safety of our properties and employees, to monitor customer service and to prevent harassment.

Audio recordings may be made during meetings, interviews, or telephone calls involving Empire and other parties. Audio equipment may be operating at other times.


WHEN EMPIRE MAY SHARE YOUR PERSONAL INFORMATION


In most cases we only disclose Personal Information with your consent, obtained through this Privacy Policy or separate communication with you. By providing us with your Personal Information in connection with your interest in our products and services you are agreeing that we can disclose it for purposes directly related to your interest and needs. This includes, for example, sharing information with credit agencies to evaluate your creditworthiness as a prospective customer or tenant, or disclosing information to check references provided by job applicants.

We may also share your Personal Information to third parties who perform services for us or on our behalf. Where Empire discloses Personal Information to service providers, we will require them to use such information solely for the purposes of providing services to the person concerned or Empire and to have appropriate safeguards for the protection of that Personal Information.

Personal Information may be transferred to, and maintained on, computers located outside of your state, province, or country and the data protection laws of those regions may differ from those of your jurisdiction. Empire takes steps to ensure that Personal Information transferred internationally is treated confidentially, in accordance with this Privacy Policy and subject to adequate security controls. If you do not want your information transferred to or processed or maintained outside of the country where you are located, you should not use the Empire website or services.

There are certain circumstances where we may, or may be required to, collect, use or disclose your Personal Information without your knowledge or consent. Those circumstances include: if the disclosure is required by law (including compliance with court orders and rules) or lawfully requested by a government agency; information is provided to our lawyers in appropriate circumstances; for the purpose of collecting a debt you owe to us; where necessary in an emergency situation; or to investigate potential breaches of contract or law.

Where obliged or permitted to disclose Personal Information without consent, Empire will not disclose more information than is required.


THE ACCURACY AND RETENTION OF PERSONAL INFORMATION


Empire endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use the information. If you notify us that your Personal Information is inaccurate, incomplete or out of date, Empire will revise the Personal Information and, if necessary, use its best efforts to inform third parties of the updates.

Your Personal Information is retained only as long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter, in case we need it to complete obligations to you, resolve a dispute, or meet our legal obligations. After the Personal Information is no longer necessary, it will be destroyed or made anonymous.

Empire uses reasonable care when storing or destroying your Personal Information in order to prevent unauthorized access.


ACCESSING YOUR PERSONAL INFORMATION


You have the right to make a written request to access your Personal Information held by us. To guard against fraudulent requests for access or revision, we may ask you for additional information to confirm your identity.

In some cases, Empire will not be able to change Personal Information it maintains, but will append in its records any alternative information provided by the individual. Similarly, Empire may not be able to fulfil all or part of an access request, but will explain the reasons for this and whether you have a right to challenge that decision.

Empire will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law there may be a charge if you request a copy of records.


OUR WEBSITE AND COOKIES


When you access or otherwise use our websites or other digital services, we automatically collect certain data, including:
• information about the device you use to access any of the services, including the Internet Protocol address, hardware model, operating system and version, mobile network information and other unique device identifiers.
• information gathered by cookies, web beacons, or other types of small temporary files or web-based tracking technologies. Like many other websites, cookies and these other technologies may be used in order to improve your individual experience as a user of our services, or to generally improve or enhance the overall functionality of the services.
• subject to your device permissions, information about the precise or general location of your device, to customize our services based on your location. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.
• social media information, to the extent we offer any social media interaction features, such as the Facebook Like button. These features may collect your Internet Protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Your interactions with these features maybe governed by the privacy policies of the company providing it.

We may use advertising cookies so that we can understand what products or services you are interested in, and show you ads on other websites based on how you interreacted with Empire’s website. Cookies from other sites may also be used to show you advertising on Empire’s website. This information does not directly identify you, such as by name or contact information. You can disable or manage your cookie preferences within your device or browser setting to prevent this.

Empire may also use third party analytics services, such as Google Analytics, to collect and process certain data about your use of our website, other websites, apps, and online resources. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: policies.google.com/privacy. You can also install the Google Analytics Opt-out Browser Add-on to prevent this data from being collected and used by Google Analytics, available at: tools.google.com/dlpage/gaoptout.


CHANGES TO OUR PRIVACY POLICY


Empire reserves the right to change this Privacy Policy from time to time and in our sole discretion. If we make a material change, this Privacy Policy will be updated accordingly. We recommend that you periodically review this Privacy Policy, which is available on our website (www.empirecommunities.com/privacy-policy/) so that you are aware of the changes. Your continued reading of this Privacy Policy and use of our website following the posting of a revised policy constitutes your acceptance of these changes.


COMMENTS AND QUESTIONS


If you have a question, issue or complaint related to this Privacy Policy or any of our procedures, please contact our Privacy Officer at the email address or mailing address listed below:

Empire Privacy Officer
125 Villarboit Crescent
Vaughan, Ontario L4K 4K2
privacy@empirecommunities.com

If we are not able to resolve your concern, you may have the right to raise a complaint with the privacy regulator in your province, state or country. You may contact Empire for more information about complaint escalation options available to you.