Devonian Clearwater Properties 1 Ltd. (Devonian)
At Devonian, the privacy of your personal information is important to us. This Privacy Protection Policy was developed to advise you of our commitment to the protection of your personal information.
What is Personal Information?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
- age, name, ID numbers, personal e-mail address, home address, income, or ethnic origin;
- opinions, evaluations, comments or disciplinary action; and
- employee files, credit records, loan records, intentions (e.g. to acquire goods, services or to change jobs) or existence of a dispute between a customer and a merchant.
Personal information does not include information normally found on a business card, such as name, title, company, business address, and business telephone or fax number. It also does not include information that is publicly available.
Who is responsible for administering our Privacy Protection Policy?
Our Vice President is also our Chief Privacy Officer. The Chief Privacy Officer, along with managers in each functional area/department, are responsible for ensuring compliance with federal and provincial privacy legislation, as applicable, and with this Privacy Protection Policy.
Why do we collect your personal information?
We are committed to providing purchasers, sellers, employees, tenants, customers, suppliers and investors with quality resources, management/real estate services, and reporting. As a company involved in all areas of real estate, we interact with and provide a variety of services to all of the groups listed above. In order to meet these goals, we may collect, use and disclose personal information, when applicable, for the following purposes:
- processing of employment documentation, including all payroll-related functions;
- processing of payments to/from tenants and suppliers and to/from buyers and sellers;
- provision of investor relations services to our investors;
- administration of marketing/public relations initiatives such as draws and raffles located at our properties;
- provision of real estate services as outlined in our leases, purchase and sale agreements and related documentation;
- carrying out market and product analysis and marketing of our products and services in general
This is not a comprehensive list of the purposes for which we collect personal information. It is an overview of the activities that we engage in when we collect, use or disclose your personal information and the reasons why we do so. Prior to collection of your personal information, we will inform you of the reasons we are collecting your information and our intended actions in respect of the same.
How do you consent to our collection, use and disclosure of your personal information?
Before collecting any of your personal information for any purpose, we must obtain your informed consent. You may provide us with your informed consent either expressly or implied.
- Express consent – You may provide us with your explicit consent to our collection, use and disclosure of your personal information for the purposes we identify for you by communicating your consent in a straightforward, clear and explicit manner, either orally or in writing.
- Implied consent – You may also provide us with your implied consent by way of your action or inaction. For example, by providing us with your resume or other documentation, you are impliedly consenting to our review of your resume or such other documentation.
Should you choose not to consent to a general or particular use of your personal information, you must provide us with a written statement to this effect for our records and so that we may ensure that we do not use your personal information in this manner. Choosing to do so may affect our ability to provide you with certain products or services.
There may be instances where the law requires or permits the collection, use or disclosure of your personal information without your consent, for example, in emergency situations.
You may withdraw your consent to any of our uses of your personal information by giving our Chief Privacy Officer reasonable prior written notice of the same. Again, withdrawing your consent to certain uses of your personal information may affect our ability to provide you with certain products or continued services.
How much personal information do we collect, use or disclose?
We collect, use and disclose your personal information only to the extent required to fulfill the purposes for which we collected it.
In order to better service you and fulfill our stated purposes, we may disclose your personal information to third parties who are legally obligated to keep such information private. We do not share your personal information with any other third parties without your consent.
How long do we retain your personal information?
We retain your personal information only for as long as is required to fulfill the purposes for which we collected it, and to meet all of our legal and regulatory requirements. Once your personal information is no longer required, we take proper measures to destroy, erase, or anonymize it in a manner that continues to maintain your privacy.
Legislative requirements may vary between provinces with respect to the information we must keep on file, but we are committed that all personal information that is retained will be done so in a secure, confidential manner.
How do we protect your personal information and keep it up-to-date?
While security and privacy risks can never be eliminated entirely, we take all measures we believe to be reasonably appropriate to safeguard your personal information against unauthorized access, disclosure, copying, modification or misuse.
Methods we use to protect your personal information include passwords to protect databases, firewalls in the computer system, restricted access to offices and locked filing cabinets. All personal information is kept secure from alteration, either intentional or accidental. Destruction of personal information is performed in a secure manner. Access to your personal information is restricted to those of our employees who need to know the information to fulfill the purposes for which we collected it. Some of our data storage servers are located in the United States of America.
We rely on our personal information sources for the accuracy of the information they provide, and we do our best to ensure that the personal information we use on an ongoing basis is accurate, complete and up-to-date. Should you find that the personal information we have about you is out of date or inaccurate, please contact our Chief Privacy Officer.
How can you access personal information we have about you?
You have a right to access personal information we have about you and to know how we have used it, subject to certain legal exceptions. To submit a request to access your personal information, please contact our Chief Privacy Officer.
If you require assistance in preparing your request, please contact us and we would be pleased to assist you.
As e-mail is a less secure medium of communication, please minimize the amount of any personal information you include in any e-mail correspondence to us.
Questions and concerns about our personal information practices?
If you have any questions, concerns, comments or suggestions regarding our Privacy Protection Policy and our personal information practices, please contact our Chief Privacy Officer in writing.
Chief Privacy Officer
Devonian Clearwater Properties 1 Ltd.
103 – 743 Railway Avenue
Canmore , Alberta T1W 1P2
Fax: (403) 678-6075
If our Chief Privacy Officer is unable to resolve any concerns you may have regarding the same, you may contact the Privacy Commissioner of Canada at www.privcom.gc.ca or at:
112 Kent Street
Ottawa , Ontario K1A 1H3
Telephone: (613) 995-8210
Fax: (613) 947-6850