Privacy Policy

Introduction

This Privacy Policy (the “Policy”) describes the privacy practices of Trinity Real Estate Asset Management Inc. and its affiliates, including Trinity Property Services Inc. (collectively, “Trinity”, “we”, “us”), with respect to our websites and services. It explains how we collect, use, disclose and protect your personal information, and applies to personal information collected from you through our websites, in person, by phone or on paper.

We limit the collection, use and disclosure of personal information to what is necessary for the purposes described in this Policy. This Policy is based on the principles in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and we follow the privacy laws of the provinces where we operate.

What personal information means

Personal information is any information about an identifiable individual. It does not include information that has been aggregated or made anonymous so that it cannot be linked to an individual.

Information we collect

• Information you give us through our website: your name, email address, telephone number, company and the details you include when you submit a leasing inquiry or your space requirements, send a tenant service request, contact us about investing or media matters, apply for a position, or sign up for leasing updates.
• Tenants, applicants and other customers: information collected through application forms, surveys and regular administrative activities, such as your name, contact information and vehicle information (for example, vehicle make, model and licence plate). We use it to identify you and your vehicle and to contact you. We may also collect a copy of government-issued identification to verify your identity, and your banking information for payment.
• Investor accounts: if you are a registered investor, your account details and the documents you view.
• Information collected automatically: when you visit our websites, we collect technical information such as the name of your internet service provider, your IP address, the type of operating system and browser you use, and the pages you visit, through cookies and server logs. We use this information, in aggregate, to run, secure and improve our websites and to understand in general terms who visits them.

Residential property management

In addition to the information above, as part of our residential property management services we collect information such as your date of birth or age, gender, family status, occupation, emergency contact details, the names of other occupants of the unit, including dependants, and pet information (for example, pet name and registration number). We use this information to identify you, assess eligibility for rental units and manage the property.

To determine your suitability for a lease, we may also collect information such as your salary and other income and financial information, employment information, educational information (if you are a student), the results of a credit check and your rental history. We may collect specific medical information that we need to be aware of, such as an existing medical condition that is relevant in a building evacuation, to address and reduce safety risks.

We may collect personal information from third parties, such as your employer, your educational institution and your past landlords (as part of a standard reference check), to confirm that the information you have provided is accurate. If you do not provide valid credit check results with your lease application, we may obtain them from a credit bureau to assess your creditworthiness.

How we use it

• To respond to your inquiry or request, and to provide the services you ask for.
• To evaluate lease and rental applications, including credit checks, reference checks and verifying financial eligibility.
• To manage leases and fulfil our contractual obligations, process rent payments and deposits, and provide tenant services such as maintenance requests.
• To manage our properties and investor relationships, and to keep our properties, tenants and residents safe and secure.
• To send you leasing updates or other commercial electronic messages, only with your consent.
• To operate, secure and improve our websites and services.
• To meet our legal and regulatory obligations.

Sharing your information

We may share personal information with our affiliates, for purposes such as providing and improving our services. We may also share it with third parties outside Trinity in limited circumstances, and only to the extent needed. For example (this list is not exhaustive):

• Service providers that work with or for Trinity, such as our website host, contractors and maintenance personnel, utility companies, locksmiths, insurers and collection agencies. The categories of information we share depend on the service provided.
• Property owners: limited information, such as your name, rent amount, unit number, lease status and whether we accepted your application.
• Credit bureaus and financial institutions, to assess creditworthiness and process payments.
• A party representing you, such as your lawyer or accountant, or other third parties at your direction or with your consent.
• Emergency contacts, if necessary in an emergency affecting you or other residents.
• Legal and regulatory authorities, and other third parties, to enforce our rights or to comply with the law, such as in response to a court order or a law enforcement request.

We may also share personal information as needed to operate our business, including as part of a sale of a property, an assignment of your lease or obtaining financing, and as required or permitted by law. When we share personal information with third parties, we require them to keep it confidential and secure and to use it only for the purpose it was shared for. Trinity does not sell or lend your information to any third-party marketing group.

Where your information is stored

We generally store personal information in Canada. However, we and our service providers, including our affiliates, may access, store and process it outside Canada, including in the United States (and, for individuals in Québec, outside Québec). In those cases we continue to protect it with appropriate safeguards, but it may be subject to the laws and authorities of those other jurisdictions.

Consent

By contacting us or voluntarily providing personal information, you consent to our reasonable collection, use and disclosure of it for the purposes for which it was provided and as described in this Policy. In some cases consent may be implied by the nature of your dealings with us, for example when you submit a lease application. If we need to use your personal information for a purpose not described in this Policy, we will ask for your consent first.

If you provide us with personal information about another person, you are responsible for obtaining that person’s consent to its collection, use and disclosure as described in this Policy.

We send commercial electronic messages only with your consent, as Canada’s Anti-Spam Legislation (CASL) requires, and every message includes a way to unsubscribe.

You may choose not to provide personal information, or withdraw your consent at any time by contacting us. Legal requirements may sometimes prevent us from accepting a withdrawal, and if you withdraw consent or do not provide information, we may not be able to provide some services or process your application.

Cookies

Cookies are small data files saved to your device when you visit a website. We use session cookies, which are deleted when you close your browser, and persistent cookies, which remain on your device until they expire or you delete them.

Some cookies are needed for our websites to work, such as the cookies that keep you signed in to the investor login and help protect the site. We also use analytics cookies, through Jetpack Stats (a service of Automattic Inc.), to understand how visitors use the site, such as which pages are viewed. We use this information in aggregate, not to identify you.

Most browsers accept cookies by default. You can set yours to refuse cookies or to alert you when cookies are being sent, and you can delete cookies at any time; see your browser’s help pages for how. Some features, such as the investor login, may not work without cookies.

Keeping and protecting it

We keep personal information only for as long as we need it for the purposes for which it was collected, or as the law requires. When it is no longer needed, we securely destroy, erase or anonymize it.

We protect personal information with reasonable administrative, technical and physical safeguards against unauthorized access, loss or misuse. Access is limited to employees who need it to provide services, for example in accounting, leasing and operations. No transmission over the internet is completely secure.

Accessing, updating and correcting your information

You may ask to access, update or correct the personal information we hold about you, or ask us to delete it, subject to legal limits, by contacting our Privacy Officer. We may need to verify your identity before acting on your request.

Contact us

Trinity has appointed a Privacy Officer to oversee compliance with this Policy and to address any questions, concerns or complaints about our privacy practices.

Naushin Virji, Privacy Officer
Trinity Real Estate Asset Management Inc.
77 Bloor Street West, 16th Floor, Suite 1601
Toronto, ON M5S 1M2
Email: nvirji@trinity-group.com
Telephone: 416-255-8800

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or the privacy commissioner of your province.

Changes to this Policy

We review our policies periodically and may update this Policy from time to time. Changes will be posted on this page, and the date at the top shows when it was last updated. We encourage you to review it from time to time.