PRIVACY STATEMENT

HOW AND WHEN BROCK-KING COLLECTS PERSONAL INFORMATION

1. Brock-King collects personal information in the following situations:

   • When individuals apply to us for approval to become a tenant in one of our residential or commercial properties or purchaser of any unit in a development project. This information is collected through application forms, disclosure forms, agreements of purchase and sale, credit information forms and transaction documents. This information is collected from prospective tenants, purchasers and guarantors. Personal information includes contact information (for example, name, mailing address, e-mail address, telephone number), demographic information, household information, emergency contact, vehicle information, officers or directors information, articles of incorporation, business or social insurance numbers and financial information.

   • From individuals on a voluntary basis through surveys and/or questionnaires or generally through any web sites operated by Brock-King. Personal information includes contact information (for example, name, mailing address, e-mail address, and telephone number), demographic information, household information, preferences and financial including income information.

   • From agents, brokers, landlords, employers or references with whom you have or had a relationship.

USE OF PERSONAL INFORMATION BY BROCK-KING

2. Brock-King uses personal information that it collects for the following:

   • To determine whether or not a prospective tenant is eligible for services requested;

   • To verify your identity and detect and prevent fraud;

   • To ensure that the parking spaces in our properties are only being used by those individuals entitled to do so;

   • To understand individual needs and preferences and to make available, promote and provide you with information, goods, offers and services;

   • To manage the distribution of communications to tenants;

   • To administer your online account or service you request;

   • To disclose information as may be required by law;

The information also enables us to develop services to better meet the needs and preferences of tenants or purchasers. Brock-King may, from time to time, contact individuals by electronic format, regular mail or telephone for any of the purposes set out above and this shall constitute your consent unless you opt-out as more particularly set out herein.

DISCLOSURE OF PERSONAL INFORMATION BY BROCK-KING

3. Brock-King does not sell, rent or trade personal information that it collects. Brock-King will not knowingly disclose personal information to any third parties except in the following circumstances:

   • When Brock-King has received consent to do so or under limited circumstances specifically described at such time as personal information is collected;

   • When Brock-King, in good faith, believes the law permits or requires such disclosure;

   • Where passing the information to third parties is necessary in order to provide you with information, products or services;

   • To its agents and professional advisors for the purpose of collection of unpaid rent, deposits and any other charges owed to Brock-King;

   • To any companies or legal entities associated with, related to or affiliated with Brock-King or any condominium declarants and their respective employees;

   • To any real estate agent or broker who introduced you to a specific project or building or to Brock-King;

   • To one or more third party data processing companies who handle or process marketing campaigns on our behalf or on behalf of companies associated or affiliated with us and who may, in turn, send Commercial Electronic Messages (CEMs) to you however you can opt-out of receiving future marketing and promotional communications at any time be clicking the unsubscribe link included in any email communication or by contacting us as set out under the tab “Contact Us” on the website;

   • To any trades, sub trades or suppliers working on the specific project or building;

   • In the event that ownership or management of a particular property is transferred to another owner or management company, Brock-King may disclose personal information of tenants or purchasers of such property to such new owner or management company;

   • In the event of the sale of Brock-King, personal information may be one of the transferred business assets;

   • To any relevant governmental authority, auditors or accountants.

RETENTION OF PERSONAL INFORMATION BY BROCK-KING

4. At such time as personal information is no longer required for the purposes stated in this Privacy Statement or other statutory requirements, such personal information will be made anonymous or destroyed.

COLLECTION, USE AND DISCLOSURE OF NON-IDENTIFIABLE INFORMATION

5. As more particularly set out herein, Brock-King may collect and use Non-Identifiable Information to assess the effectiveness of web site content and traffic. This allows Brock-King to improve the quality of visits to web sites managed by it by streamlining visitors’ ability to navigate these sites and developing featured programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analyses of the collective characteristics and behaviour of individuals, and to measure demographics and interests.

6. As more particularly set out herein, Brock-King may also use aggregate non-identifiable information it collects to inform its current and prospective sponsors and advertisers about the number of visits to its web sites, the demographic characteristics of these visitors and the number of times visitors have viewed and "clicked" on their advertisement(s). Brock-King also discloses to advertisers the overall demographics available regarding visitors who "clicked" on their advertisement. Aggregate non-identifiable information may be used to describe Brock-King services and products to third parties such as prospective business partners and financial institutions. In any of these circumstances, only non-identifiable information in an aggregate form and not personal information is disclosed.

ANALYTICS

7. Web sites operated by Brock-King may use third parties such as Google Analytics, a web analysis service, to help gather and analyze information about the specific areas you visit. Google Analytics and other such third party service providers use technologies such as cookies to evaluate and improve your experience and the convenience of Brock-King’s web sites and to contextualize the ads. For more information, please go to https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, please go to https://tools.google.com/dlpage/gaoptout/.

ADWORDS

8. Web sites operated by Brock-King may use internet-based advertising, such as Google AdWords to serve our advertisements on third-party websites to previous visitors of the Brock-King operated web sites. These companies may use cookies or tracer tags to report certain information about your visits to the web sites in order to measure the effectiveness of the relevant marketing plans as well as deliver to you ads relevant to you.

You can set preferences or opt out of internet-based advertising entirely by visiting the relevant website (i.e. Google: https://www.google.com/settings/ads/anonymous?hl=en-GB&sig=ACi0TCiWDjtIOonUTWIhnnC5T0eFi6-UUqlrHSDAcqDHz_YjVmohorOqrCRo1q07VNgEvgLj9uCc-70SDT1KbZWzQg3FjLP91MJSDRmcDyuklLG2eWJMYV8).

WEB SITES OPERATED BY THIRD PARTIES

9. Web sites operated by Brock-King may contain links to other web sites that may collect personal information. This Statement does not extend to the data collection, disclosure, use and retention practices of such third parties and Brock-King does not assume any responsibility for the privacy practices, policies or actions of such third parties. Individuals should read the privacy policies of such third parties, and make an informed decision whether or not to visit such web sites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.

COLLECTION AND USE OF VIDEO OR AUDIO RECORDINGS

10. Video and audio equipment may be installed and operated in common areas of the projects or the buildings. Surveillance of any video or audio recordings may occur at any time and without notice to you to ensure the safety, security and reasonable enjoyment of all occupants and visitors to the projects or buildings as well as record situations where there are work-related concerns. Therefore, your image, movements and actions may be captured by said equipment and may be used against you.

SAFEGUARDING PERSONAL INFORMATION

11. Brock-King has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. Personal information is stored in confidential databases and locations in the Greater Toronto Area. These sites have appropriate security measures in place to protect against the loss, misuse and alteration of personal information under the care and control of Brock-King. Any information transmitted via the Internet, however, may be intercepted by third parties. Brock-King does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. Brock-King employees are restricted from using and disclosing personal information collected by Brock-King other than in accordance with this Statement.

ACCESSING PERSONAL INFORMATION

12. Individuals have the right to access, verify and correct or amend all of their personal information collected by Brock-King, on behalf of our tenants or purchasers. Brock-King believes that it is imperative that personal information be as accurate, complete and up to date as is necessary for the purposes for which it is collected. Accordingly, to help Brock-King keep personal information as current as possible, Brock-King encourages individuals to amend inaccuracies and make corrections in their personal information collected by Brock-King, on behalf of our tenants or purchasers, as often as necessary.

HOW TO FILE A COMPLAINT

13. To file a complaint with Brock-King concerning the collection, use and/or disclosure of personal information, please send an email to the Privacy Officer at Brock-King at privacy@Brock-Kingproperties.com or call 416-703-1877.

All complaints will be investigated by the Brock-King Privacy Officer as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints clearly and promptly and will be notified of any relevant steps taken or to be taken as a result of a complaint.

COMMENTS AND QUESTIONS

14. Any comments or questions about this Statement, should be addressed as follows:

Brock-King Properties
35 Lesmill Road
Toronto, Ontario M3B 2T3
Attention: Privacy Officer
By email: privacy@brockking.com
By phone: 416-703-1877

EFFECTIVE DATE OF STATEMENT

15. This Statement has been adopted by Brock-King as of January 1, 2017. Revisions to the Statement will be posted on this web site as soon as practical.