This Privacy Policy (the “Policy”) describes the practices of Urban Residences Charlottetown (URC) with the collection, use, retention, disclosure, and protection of information about an identifiable individual (“Personal Information”). In particular, this Policy applies to Personal Information URC collects about individuals who:
How URC Collects Personal Information;
The amount of Personal Information collected by URC is limited to what is necessary for the identified purpose of that collection.
URC may collect Personal Information
(a) directly from you;
(b) through automated means; and/or
(c) from third parties or other sources.
Directly from you;
URC collects Personal Information you provide directly to URC:
(a) by mail, email, telephone, text, or other electronic means;
(b) through websites, mobile or web applications;
(c) when you respond to social media posts; or
(d) in any other direct manner (for example, when you apply for a lease, participate in a survey, submit a job application, submit a bid or quote to provide services, or become an investor).
Through automated means;
URC may collect certain types of information using automated means, including when you visit our rental property, contact us over the phone, through video surveillance, video recordings, audio equipment, audio recordings or cookies, pixels, and similar technologies when you interact with URC’s websites or mobile or web applications.
From third-party sources;
URC may collect Personal Information from third parties.
Subject to your consent or if required or permitted by applicable law, URC may collect Personal Information from current and former employers, current and former landlords, personal references, background check services, credit reporting agencies, and financial institutions. URC may also collect Personal Information from other third parties, including, but not limited to, URC and related companies, service providers, co-residents, occupants, guarantors, third-party payors of rent, business partners (including, entities from which URC acquires properties), brokers, recruiters, credit bureaus, and registrar and transfer agents.
URC may also collect Personal Information from publicly available sources of information or authorities or public bodies.
What Personal Information URC collects;
The Personal Information URC collects includes;
(a) lease application information, including name and contact information (such as your email address, residential address, and telephone number) for prospective residents, occupants, guarantors or third-party payors of rent, income and other financial information, rental history, references, credit history (including credit score and credit report from credit reporting agencies) and employment-related information;
(b) tenancy information, including name and contact information for all residents, occupants, guarantors, or third-party payors of rent, emergency contact information, emergency medical information, proof of insurance, vehicle-related information, bank account information, and ownership of pets;
(b) service provider information, including name, contact information, bids/quotes, customer references, proof of insurance, and bank account information;
(c) website and applications data, including cookies, location data, weblogs, and internet protocol address; and
(d) other information may be used for the purposes described below and as requested from you from time to time.
You may request to learn more about the information URC collects about you and how it is handled, including the categories of persons who have access to that information within URC, how long URC keeps it, and the source of information URC may collect about you from other businesses, by contacting URCs Privacy Officer at the address indicated in this Policy.
How URC Uses the Personal Information;
URC uses Personal Information for the following purposes:
(a) to determine your suitability for a lease, including creditworthiness;
(b) to schedule property viewings;
(c) to administer your lease agreement and tenancy; including communicating with you, processing rent payments, arranging for maintenance or repairs, confirming payment of utility bills, facilitating the set-up, switch-over, or closing of utility accounts, repaying security deposits, and collecting debts;
(d) to enforce the terms of your lease agreement, including collection of any judgment that may be obtained against you as a consequence of a breach of your lease agreement (or other related agreement);
(e) to communicate with you regarding your job application and/or process information related to a job application or offer of employment;
(f) to communicate with employees and administer the employment relationship;
(g) to communicate with board members, administer their appointment, and for governance and regulatory purposes;
(h) to communicate with service providers and administer and enforce contracts;
(i) to communicate with you by email, phone, or mail about URC’s services, events, surveys, and other information that may be relevant to you;
(j) to protect URC assets, business, properties, residents, occupants, employees, and other individuals;
(k) to facilitate actual or potential business transactions, such as the sale of assets or business or any financing;
(l) for business planning purposes, internal control, business continuity, and internal/external auditing;
(m) URC uses video recordings to protect residents, occupants, guarantors, visitors, mployees, job applicants, service providers, and other individuals who visit URC rental properties or offices, and to maintain the security of these locations, as further described in the “Video Surveillance and Recordings” section;
(n) URC uses cookies, pixels, and similar technologies to improve the display and content of URC’s websites and to understand how users interact with URCs websites. URC may also use this information for advertising purposes. To learn more about URC’s use of these technologies and how to manage your preferences please see the “Cookies and Similar Technologies” section below;
(o) to respond to your request or inquiry;
(p) to document and investigate incidents;
(q) to investigate, resolve, or defend any complaint, dispute, claim or investigation;
(r) to comply with a legal obligation;
(s) for other legitimate business activities;
(t) for other purposes that may be communicated separately; and (u) as otherwise required or permitted by law.
Who URC Shares Your Personal Information With;
URC may share your Personal Information with others, such as:
(a) URC affiliates;
(b) URC service providers, who may use Personal Information on URC’s behalf in connection with the purposes listed above, including to communicate with you directly;
(c) URC insurers;
(d) External auditors;
(e) any co-resident, occupant, guarantor, or third-party payor of your rent if required under your lease agreement or related housing agreement;
(f) through public directories of residents maintained by URC (e.g., by the front door);
(g) credit reporting agencies to evaluate your creditworthiness in connection with an application for a lease;
(h) former and current employers, former and current landlords, personal references, and present banking institution, all of whom are named by you in documents submitted to URC so that URC may contact them as part of the process of evaluating your lease or job application, as the case may be;
(i) third parties to enforce the terms of your lease agreement (or any related agreement), including collection of any judgment that may be obtained against you as a consequence of a breach of your lease agreement (or any related agreement);
(j) providers of any security alarm system, cable television, telephone, telecommunication, internet and internet connectivity, hydro-electricity, water/hot water, gas, and/or other similar or related services that are available and outlined in the lease agreement.
These third-party providers are restricted to using your Personal Information to fulfill other than to contact you for the provision of such services.
(k) governmental authorities when required to comply with URCs legal obligations [for example, URC may disclose your Personal Information to Canada Customs & Revenue Agency, to whose attention the T-5 interest income tax information return and/or the NR4 non-resident withholding tax information return is submitted (where applicable)];
(l) after-hours technology and customer service providers who may have access to such Personal Information incidentally through their administration and servicing of software used by URC in business operations;
(m) third parties in connection with a disposition of your building, an assignment of your lease agreement (or other related agreement) or to obtain financing;
(n) advisors or potential buyers or financiers (debt or equity) in connection with an actual or potential business transaction, such as the sale of assets or business or any financing; and
(o) other third parties where you further consent to such disclosure or as otherwise required or permitted by law.
Consenting to URC Collection, Use, and Disclosure of Your Personal Information;
In most cases, the collection, use, or disclosure of your Personal Information by URC requires your knowledge and consent. At certain times, your consent for the collection, use, and disclosure of your Personal Information may be implied from how it is collected. For example, when you provide URC with your Personal Information in connection with a lease or job application, you have implicitly consented to URC collecting, utilizing, and disclosing your Personal Information in a manner necessary to determine your suitability for, and administering your lease or to communicate and process your job application. In other cases, your acknowledgment of this Privacy Policy constitutes your consent, such as when you accept an agreement that incorporates this Policy or use our website or mobile applications. Consistent with legal requirements, we may from time to time separately ask for your express consent to handle your Personal Information for particular or new purposes.
You may always choose not to supply URC with your Personal Information or request to withdraw consent to the ongoing collection, use, or disclosure of your Personal Information. This may impact URC’s ability to provide you with services. We will explain to you any consequences of a request to refuse or withdraw your consent, as well as any situations where we cannot fulfill your request.
Collection, Use, and Disclosure of Personal Information Without Consent;
There are certain circumstances where URC may, or may be required to, collect, use, or disclose your Personal Information without your knowledge or consent. Those circumstances include (but are not limited to):
(a) if the collection, use, or disclosure without your knowledge or consent is required or permitted by law;
(b) the Personal Information is provided to URC’s lawyers;
(c) to collect a debt you owe to us;
(d) to resolve or defend a complaint, dispute, claim, or investigation;
(e) to comply with a subpoena, warrant, or order made by a court, person, or body with jurisdiction to compel the production of information;
(f) to comply with rules of the court relating to the production of records;
(g) to comply with a request for information from a government institution or investigative body that has identified its lawful authority to obtain the information;
(h) to comply with a request from a government agency (e.g., Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) that has the authority to review URC’s files and interview URC’s employees as a part of their mandates;
(i) to act in respect of an emergency that threatens the life, health, or security of an individual; or
(j) the Personal Information has been collected when consent is not required.
Retention of your Personal Information;
URC maintains policies and practices governing the retention and destruction of Personal Information in its possession or custody. URC retains your Personal Information for as long as it is necessary to fulfill the purposes for which it was collected or used and to comply with applicable laws.
Protection of your Personal Information;
URC will protect your Personal Information in a manner that is consistent with and appropriate to the sensitivity of that Personal Information. For example, URC employs physical, technical, and organizational measures to ensure your Personal Information receives an adequate level of protection while it is under URC’s care, including when your Personal Information is transferred to one of URC service providers located outside the jurisdiction where you reside. URC’s handling of your Personal Information will respect its confidential nature at all times from the time of its collection until its ultimate disposal or destruction.
URC maintains policies and practices that ensure the protection of your Personal Information. Depending on the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, URC implements a combination of measures to protect your Personal Information, including:
● Internal practices that limit employee access to Personal Information
● If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software, and similar measures;
● A designated Privacy Officer to monitor URC’s compliance with applicable data protection laws;
● Employee privacy and data security training;
● Procedures for receiving, investigating, and responding to complaints or inquiries regarding URC’s information handling practices, including any security incidents involving Personal Information; and
● The framework governing the retention and destruction of Personal Information is more fully described above in the “Retention of Your Personal Information” section of this Policy.
While URC takes all reasonable measures to safeguard your personal information, please note that no method of electronic transmission of personal information can be guaranteed to be completely secure. Transfers of Personal Information to Other Jurisdictions;
URC may store your Personal Information within or outside of Canada. Some of HURCs service providers may also access, process, or store your Personal Information outside the province where you reside. In that case, URC uses reasonable safeguards to ensure that URCs service providers protect your Personal Information wherever it is used or stored. When your Personal Information is used or stored in a jurisdiction other than where you reside, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts, and law enforcement in that jurisdiction.
Canada’s Anti-Spam Legislation (CASL);
At this time, URC has taken steps to generally prohibit third parties from using your Personal Information to send you Commercial Electronic Messages (CEMs) unless the same is exempt from restrictions of, or are otherwise sent in full compliance with, CASL.
Use of Video Surveillance, Recordings, and Photographs;
Video equipment may be installed and operating in common areas of URCs rental buildings and offices. The video equipment may have capabilities such as zoom, or night-vision features. The video equipment may be operating at all times.
Surveillance of the video recordings or the taking of photographs may occur at any time to;
(a) ensure the safety, security, and reasonable enjoyment of URCs residents, occupants, employees, service providers, and other visitors to URCs rental properties and offices;
(b) ensure you have access to the premises, equipment, and services that HURC has agreed to provide;
(c) to preserve URC’s property and to deter crime;
(d) to document and investigate incidents;
(e) to investigate, resolve, or defend any complaint, dispute, claim, or investigation; and
(f) to assist in the administration of business operations. Where required by law, signs will be posted informing you that video equipment is operating and recording Personal Information
about you. You can contact URC’s Privacy Officer if you have questions regarding the video recordings.
Exercising your Right to Access or Rectify your Personal Information and Other Privacy Rights;
Access to your Personal Information held by URC may be requested by contacting the Privacy Officer in writing. Upon such written request, you shall, to the extent possible and/or where permitted under applicable law, be informed of the existence,
use, and disclosure of your Personal Information and be given access to and ensure the accuracy of that Personal Information. You also have the right to request the rectification of your Personal Information if it is inaccurate, incomplete, or no longer up to date. Depending on where you reside, you may also be entitled to request the rectification or deletion of your Personal Information if our collection, disclosure, or retention of such information is not authorized by law. Any questions concerning requesting access to, or rectification of, Personal Information or your other privacy rights may be addressed to the Privacy Officer. URC undertakes to use reasonable efforts to maintain the accuracy, completeness, and currency of your Personal Information that is held by URC as is necessary to fulfill the purpose for which it was collected and is to be used. URC may, from time to time, ask you to confirm the accuracy of your Personal Information for such purpose.
Cookies and Similar Technologies;
When you visit the URCwebsite(s), URC may collect and use your internet protocol address to help diagnose problems with the URC server and to administer the website, to understand how users interact with the URC website, and to gather broad demographic information. URC may also collect web page choices, information about your browser, device, platform, operating system and versions, and time you spend on the site, to help URC improve your experience. Although the URC website(s) may collect high-level information about your location (for example, the longitude and latitude associated with your municipality), they do not collect precise geolocation without your consent.
URC uses “cookies”, a technology that installs a small amount of information on a website user’s computer, to permit URC’s’ website to recognize future visits using that computer and to avoid having to register your contact information at each visit. Cookies enhance the convenience and use of the URC website(s). For example, the information provided through cookies is used to recognize you as a previous user of URC’s website(s), to track your activity on URC’s website(s), and obtain general information about other websites you have visited, to respond to your needs, and to otherwise facilitate your experience on URC website(s). You may choose to decline cookies if your browser permits, but doing so may affect your use of URC’s website(s) and your ability to access certain features of URC’s website(s) or engage in transactions through our website(s).
URC also uses web cookies and pixel tags to track user behavior on URC’s websites and to compile reports regarding user demographics, and website tracking patterns. Within URC’s applications, URC may also use analytic tools and automated tracking technology or methods. URC uses these tools to analyze and enhance the user experience. URC may use third-party advertising networks to advertise on URC’s websites or other websites. These advertising networks use cookies or similar technologies to track your navigation habits on our websites and third-party websites to serve you advertising that is customized to your inferred interests and preferences. For example, a cookie may be placed on your computer when you visit a URC website, which is recognized and used by third-party advertising networks to serve you with a URC ad when you visit other websites within their advertising network. As described above, you may be able to set your browser to decline cookies. Where required by law, URC will ask for your consent before enabling such technologies. If you decline cookies you may still receive online advertising; however, it may be less personalized. Some advertising networks participate in industry programs that include web pages to visit to opt out.
Third-Party Websites;
URC may provide links to other websites that are not operated or controlled by URC. These websites are not governed by this Policy. You should review the privacy policy associated with any linked website before visiting the site or providing any information.
Children’s Personal Information;
URC’s website(s) are for those who are over the age of majority. URC does not knowingly solicit or collect any Personal Information from children under the age of majority through URC’s website. If you are under the age of majority, please do not submit any Personal Information through the website. If URC is notified or discovers that a child under the age of majority has submitted Personal Information to us, URC will take reasonable steps to delete the information.