Corporation Privacy Policy
January 1, 2004
For the purposes of this Policy, "The Corporation" refers to Equity Capital Management & Realty Ltd ..
This Privacy Policy regarding personal information is based on the Canadian Standards Association (CSA) Model Policy on Privacy of Personal Information and applicable law. The CSA Model Policy represents an industry consensus on best practices in the protection of customer personal information.
The Corporation recognizes the importance of privacy and the sensitivity of personal information. As the Corporation, we are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.
Your Privacy Rights
From January 1, 2004, certain organizations, which are Considered to be engaged in commercial activities, must comply with the Personal Information Protection Act, (www.privcom.gc.ca). These obligations may extend to many organizations, including the Corporation. This Act gives you rights concerning the privacy of your personal information. The Corporation is responsible for the personal information We collect and hold. To ensure this accountability, we have developed this policy, and trained our contractors and staff about our policies and practices.
Why Does the Corporation Need Personal Information?
The Corporation provides a wide range of community services and products to our residents and users of our facilities. The Corporation collects personal information in order to serve our residents and users better and to improve our understanding of their needs and preferences. We collect personal information for the following purposes:
(a) to identify you when you contact us;
(b) to improve our understanding of your needs and preferences;
(c) to establish and maintain our relationships with you;
(d) to provide specific and on-going services or products to you;
(e) to help administer your accounts, services and products provided to you by the Corporation now and in the future;
(f) to plan for improvements in our ability to serve our residents' needs;
(g) to provide information and offers related to our services and products;
(h) to provide information and offers which may be of interest to you in complementary services or products we may provide or make available to you;
(i) to effectively and efficiently manage and develop the provision of services, products and operations;
(j) to effectively and efficiently manage compliance with the applicable by-laws and other commitments residents make in Calgary; and
(k) to meet legal or regulatory requirements or in emergency situations.
We also collect personal information so that the information, which we use, shall be as accurate, complete and current as is necessary for the purposes for which it is to be used.
We may use or disclose your personal information for management, analytic, planning or other purposes where the information has been sufficiently aggregated such that any individual cannot be reasonably identified.
The Corporation might acquire or develop relationships with other communities or related community organizations in order to better serve our residents' requirements. In such transactions, personal information generally is one of the transferred or disclosed assets but remains subject to the promises made in any pre-existing Privacy Policy (unless you consent otherwise). We may transfer or disclose your information, including personal information, in connection with any acquisition, merger, reorganization or other fundamental change.
The Corporation will collect your personal information for these purposes and for other purposes that we would inform you of at the time of collection.
In addition to the uses inherent in the list of reasons we collect the information, described above, we may request and use personal information from you in connection with your receipt, use of, or participation in, our special events, social functions, surveys, forums, subscription registrations, content submissions, requests for suggestions, or additional information (including via email to us), and in connection with other activities, services or resources we make available to you from time to time. You may advise us that you do not wish to receive such information or materials or be invited to such functions ("opt out"). You may choose to opt-out at any time, even after you have provided personal information, by following the procedures we describe below in this Privacy Policy. Please note, however, that if you later opt-out, you will not receive any of the information or benefits that may be associated with such activities, materials or functions.
If you do provide us with personal information for any of these activities, we may use it to conduct our activities described in this Privacy Policy.
We do not disclose your personal information to third parties who are not involved in the provision of any specific product or service offering with us and only then in a manner that is consistent with our Privacy Policy, or as regulated by law.
What personal information do we collect?
Personal information is any information that identifies you, or by which your identity could be deduced. If we did not collect, use, retain and disclose your personal information we could not provide you with services or products.
How do we collect your personal information?
We collect nonpublic personal information about you that is provided to us by you or obtained by us with your authorization or consent. We collect information by lawful and fair means. Wherever possible we collect your personal information directly from you, at the commencement of our relationship and in the course of our relationship. Sometimes we may obtain information about you from other sources, such as, for example:
• your insurance company or other benefits provider;
• a third party with whom you have or are seeking to establish a relationship;
• from a government agency or registry;
• your realtor, if we are working with you on the purchase, sale or other transaction involving a home in Calgary; or
• your accountant.
Consent
In most cases, we shall ask you to specifically consent, if we collect, use, retain or disclose your personal information. In many cases we may ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.
Choice/Opt-Out
If you do not wish to obtain our newsletters or materials, be invited to seminars, functions or other events or to be informed about new services and timely developments you have the opportunity to opt-out of receiving such communications or invitations. The Corporation provides several options for you to opt-out of these communications. You may:
1. E-mail us at reception@equitycapital.ab.caorvisitus at www.equitycapital.ab.ca;
2. Contact us at 299-1800.
Use of Your Information
We use your personal information to conduct our programs for residents and users of our facilities and to provide other services and products, to administer our resident relationships and to include you in any direct marketing activities such as circulation of newsletters or materials, invitations to seminars, functions or other events on current issues, new services or timely developments. You may advise us that you do not wish to receive such information or materials or be invited to such functions ("opt out"). You may choose to opt-out at any time, even after you have provided personal information, by following the procedures we describe in this Privacy Policy. Please note, however, that if you later opt-out, you will not receive any of the information or benefits that maybe associated with such activities, materials or functions.
Disclosure of your Personal Information
We do not disclose any non-public personal information about our residents or former residents to anyone, except as expressly or impliedly authorized by those residents to enable us to effectuate our relationship with them, or as permitted by law or this policy. The Corporation does not, without your consent, disclose your personal information to any third party to enable them to market their products and services to you.
Under certain circumstances, the Corporation will disclose your personal information, such as, for example:
• when we are required or authorized by law to do so, for example if a court issues a subpoena;
• when you have consented to the disclosure;
• when the services we are providing requires us to give your information to third parties (for example where you are involved in a group that also involves others) your consent will be implied, unless you tell us otherwise;
• where it is necessary to establish or collect fees or enforce our by-laws or policies;
• if we engage a third party to provide administrative services to us (such as our management company) and the third party is bound by our privacy policy;
• if the information is already publicly known.
Updating Your Information
Since we use your personal information to provide services and products to residents and users of our facilities, it is important that the information be accurate and up-to-date. If during the course of our relationship, any of your information changes, please inform us so that we can make any necessary changes.
Is My Personal Information Secure?
We retain records relating to the provision of services and products to residents and users of our facilities so that we are better able to manage these activities and to comply with our relationships with residents or requirements of law. In order to guard your nonpublic personal information, we maintain reasonable physical, electronic, and procedural safeguards. The Corporation takes reasonable precautions to protect that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
• premises security;
• restricted file access to personal information;
·deploying technological safeguards like security software and firewalls to seek to prevent hacking or unauthorized computer access;
• internal password and security policies.
Access to Your Personal Information
You may ask for access to specific personal information we hold about you. Summary information is available on request. More detailed requests, which require archive or other retrieval costs, may be subject to our normal fees and disbursement costs. We will seek to identify these costs to you at the time of your request.
Correcting Errors
If the Corporation holds personal information about you and you can establish that it is not accurate, complete and up-to-date, the Corporation will take reasonable steps to correct it.
Can I be Denied Access to My Personal Information?
Your rights to access your personal information are not absolute. We may and in some cases must deny access when:
• denial of access is required or authorized by law (for example, when a record containing personal information about you is subject to a claim of privilege) ;
• information relates to existing or anticipated legal proceedings against you or an investigation involving you;
• when granting you access would have an unreasonable impact on other people's privacy;
• when to do so would prejudice negotiations with you;
• to protect the Corporation and our residents' rights and property;
• where the request is frivolous or vexatious.
If we deny your request for access to, or refuse a request to correct information, we shall explain why.
The Corporation does not use your Social Insurance Number. as a way of identifying or organizing the information we hold upon you.
Credit Bureaus
To help us make credit decisions about residents and users of our facilities, prevent fraud, and check the identity of new residents, we may on occasion, request information about you from the files of consumer reporting agencies.
Communicating with Us
If you have any questions or feedback regarding the Privacy Policy, please contact us:
• E-mail us at reception@equitycapital.ab.caorvisitus at www.equitycapital.ab.ca;
• Contact us at 299-1800.
Any personal information (name, email address, phone number) you provide will be used to help us contact you on your issue.
Your comments and questions will be retained and used for service enhancements.
Please include your name and e-mail address in the body of the message.
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.
Can The Corporation Revise This Privacy Policy?
Due to the rapidly evolving privacy developments and because the Corporation regularly reviews all of its policies and procedures, the Corporation may change its Privacy Policy from time to time. The Corporation urges you to review its Privacy Policy frequently.
Requests for Access
If you have any questions, or wish to access your personal information, please write to our Privacy Contact at
Doug Davies, ACCI
Manager / Broker
c/o 810,839 - 5 Avenue SW
Calgary, AB T2P 3C8
If you are not satisfied with our response, the Information and Privacy Commissioner can be reached at:
410, 9925 - 109 Street,
Edmonton, Alberta T5K 2J8
Phone: 1.780.422.6860
Employment Inquiries
If you apply to the Corporation for a job, we need to consider your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.