We at InterRent REIT are committed to the protection of personal information under our control. This privacy policy outlines how we collect, use, disclose and protect personal information received by us, and may be modified or updated from time to time to reflect changes in business practices or legal and regulatory requirements, and will be effective once posted on our website.
For the purpose of this policy, personal information is information about an identifiable individual, and includes but is not limited to a person’s name, age, date of birth, financial information including income and employment details and other similar information. However personal information does not include anonymous or aggregated information that does not contain personally identifiable information.
The following sections of this policy set out the best practices we follow with respect to personal information.
Accountability
The ultimate responsibility for the personal information we collect rests with our Privacy Officer, who may delegate responsibility to other team members within our organization to ensure privacy compliance. This includes limiting access to personal information to our team members who require it, ensuring that third parties comply with this policy through reasonably commercial or contractual means, data protection policies, ongoing training of our team members, and procedures to respond to privacy complaints or concerns.
Identifying Purposes
Personal information collected by us is used for the specific purposes which are identified when the information is collected, and is used for the purposes including the following:
- To complete approvals for business transactions and including suite rentals, commercial leasing and agreements with suppliers and third-party service providers.
- To verify an individual’s identity.
- To verify credit history, collect financial information for payment arrangements and verification, and Credit Bureau reporting for unpaid debts.
- To comply with applicable laws and in response to legal requests or legal proceedings and for legal transactions.
- To provide limited personal contact information to third parties such as insurance, utility and telecommunications providers and other service providers for service offerings to residents and to ensure compliance with lease terms.
- To provide services to residents including notifications, customer satisfaction surveys, events, and safely and security services.
With respect to the foregoing, we will only collect and disclose the minimum amount of personal information necessary for the purpose it is being provided, and that any person using such information complies with applicable privacy laws. Upon request, we will explain the nature of personal information being disclosed and the related purpose.
Consent
The collection use and disclosure of personal information provided to us requires the knowledge and consent of the person providing it. Consent may be expressed or may be implied from the circumstances in which it has been provided and the nature of the relationship that a person has with us. When personal information is provided to us, it is implied that such information may be used in accordance with this policy. For other purposes, we will request express consent from the person who has provided it.
When personal information is being provided to us about another person, the person providing the information must ensure they have the required consent to provide this information to us. A person may elect not to provide personal information to us or withdraw their consent to the use of personal information. In this case, we will advise how this will impact on the information, products, and services that we are providing.
Limiting Collection
We always strive to only collect personal information that is necessary for the purpose for which it is required. Personal information is generally collected from the person providing it or from third parties with appropriate consent such as financial institutions, references, credit reporting agencies, emergency contacts, employers, etc. Personal information may also be collected (and disclosed) where required by law or legal proceedings.
Limiting use, Disclosure and Retention
We do not use or disclose personal information received by us other than for the purposes for which it was collected, to provide products and services, and to maintain our legal obligations and our customer relationships.
Depending on its nature and sensitivity, personal information may be shared without your consent or implied consent in the context of legal investigations, requests from law enforcement, courts, or other governmental authorities, or in such other circumstances or emergencies where we reasonably believe such disclosure is necessary to protect the rights or safety of others, or to protect e property.
Information is retained for so long as it is required for the purpose it was collected and as required by applicable law, and when no longer required will be securely erased, destroyed, or made anonymous. Personal information may be retained for a period beyond the duration of our relationship with a person where required by law or similar purposes.
Accuracy
Personal information is kept as accurate and up to date as is reasonably necessary for the purposes for it to be used. We use reasonable commercial standards to ensure the personal information we retain is current and accurate and rely on the persons who have provided us with personal information to notify us of any changes or corrections to such information.
Safeguards
We employ various safeguards and security measures which are appropriate to the sensitivity of personal information being secured. These measures include but are not limited to the following:
- limiting our team members who have access to personal information
- restricted access to our business premises
- encryption, firewalls, passwords, anti-malware detection software and other measures
- privacy and data security training and confidentiality agreements for our team members
The foregoing measures are used to reduce and minimize the risk of loss, theft, damage, damage on the unauthorized use or disclosure of personal information.
Video recordings, photographs, and audio recordings
We use and maintain video equipment at our offices and at some of the properties that we own and manage to ensure the safety and security of our residents and team members. Video recordings are normally retained for a short period of time depending on the capacity and type of equipment you use but may be retained for longer periods of time if required by an investigative body, governmental authority or for legal purposes. Video recordings may capture images, actions or other identifiable information and where required by law; signs will be posted informing that video equipment is operating.
Photographs may also be taken to document incidents, to document the conditions of our properties, to ensure safety and security and related purposes and are retained until the purpose for which they were taken has ended.
Audio recordings are also used to record emergency calls, incoming requests for services and related issues and for training purposes. Recordings may be retained where relevant or required for legal matters or if properly requested by an investigative or governmental authority.
Video recordings, audio recordings, and photographs are securely stored with access restricted to our team members who may require the information contained therein.
Openness
Access to specific personal information we retain is made available to persons who make a request to us. This information includes the name and title of our Privacy Officer, how a person can gain access to their personal information, a general description of types of personal information, how it is used and disclosed, and a copy of this Policy and any other information relevant to the request received. Our designated team members can ordinarily address such requests, however specific complaints or unanswered concerns can be escalated to our Privacy Officer.
Individual Access
Upon receipt of a written request, which includes sufficient detail, we will provide to the person making such request a reasonable opportunity to review the personal information that we have. To avoid improper access to this information, we may also take steps to confirm the identity of the person making the request. Requests will be responded to in a timely manner and within the time frame prescribed by applicable laws. We will also ensure that upon request, we shall promptly correct or complete any person information we have that is properly demonstrated to be incorrect or inaccurate.
In the event we are unable to provide access to or to correct a person's personal information for legal, regulatory, or other reasons, an explanation will be provided when it is permissible for us to do.
Challenging Compliance
In the event a person reasonably believes that we have not complied with the principles and requirements of this Policy, we have policies, practices, and procedures in place to address such challenges. Once we have reviewed and investigated a challenge the Privacy Officer will advise the person who raised the challenge of the results of the investigation and as required, any action to be taken by us including amending internal policies and procedures.
Privacy Officer Contact Information
Questions regarding this policy or our privacy practices can be addressed to:
Privacy Officer
InterRent REIT
207-485 Bank Street
Ottawa, ON K2P1Z2
privacyofficer@interrentreit.com
Revisions to this Policy
We reserve the right to amend or update this policy in our sole discretion.
November, 2023
Additional Information – Website Practices
User Tracking
When visiting the InterRent website, our website may automatically collect general information about your visit for analysis using various website analytic services including Google Analytics and others. The purpose of this information is to understand how users interact with the site, ensure responsible and relevant advertising, diagnose any server issues, and to improve user experience. This information may include browser type, operating system, type of device, date and time of the visit to the site, previous web pages visited and broad demographic information.
Cookies
Our website utilizes 'cookies' to recognize you as a returning visitor and enhance our ability to tailor information to align with your individual preferences. A cookie, in this context, refers to a small text file that a website can transmit to your browser, subsequently stored on your hard drive. The primary objective is to streamline your future visits, provide a more personalized experience, and to measure website activity. It's important to note that cookies by themselves, cannot reveal your identity. Most browsers offer options to disable cookie collection or provide notifications when a cookie is being stored on your hard drive. This empowers you to manage your privacy according to your preferences.
Third Party Advertising
We may utilize third party advertising networks to showcase advertisements on other platforms. These advertising networks employ cookies, pixels, or similar technologies to monitor your browsing patterns on our websites and third-party platforms. This tracking is done to present you with personalized advertising based on your inferred interests and preferences. When you visit the InterRent website, a cookie may be placed on your computer. This cookie is recognized and utilized by third-party advertising networks to display InterRent ads when you visit other websites.
As mentioned earlier, you may have the option to configure your browser settings to reject cookies. It's important to note that even if you choose to decline cookies, you may still receive online advertising; however, the level of personalization may be reduced. Some advertising networks participate in industry programs that offer web pages for opting out. For instance, you can visit http://youradchoices.ca/choices.
External Links
Our website may include links to websites that are not operated or controlled by us. Such websites fall outside the scope of this Policy. Please review the privacy policy of any linked website before visiting or sharing any information on these sites.