Privacy Policy
Devonshire Properties Inc. (“Devonshire”, “we”, “our” or “us”) respects the privacy of our clients and users and understands the importance of complying with applicable data protection laws. We have adopted the following Privacy Policy to address how we collect, use, disclose and safeguard your information.
This Privacy Policy is based on, and complies with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official website of the Privacy Commission of Canada at https://www.priv.gc.ca/.
Definition of “Personal Information”
When used in this Privacy Policy, and consistent with applicable Canadian data protection laws, “Personal Information” means any information about an identifiable individual. This may include, without limitation, the individual’s name, date of birth, age, gender, marital status, email address, mailing address, telephone number, income, credit history, financial information, personal preferences and other information about his or her family.
Personal Information does not include:
(i) information pertaining to an organization as distinct from an individual person; (ii) information provided by an individual in the capacity of an employee of an organization;
(iii) an individual’s name, address, telephone number or e-mail address which is listed on a directory or is available through directory assistance; and
(iv) other information that is publicly available and is specified by regulations under PIPEDA and similar provincial legislation.
The Information We Collect
The information that we collect depends on how you engage with Devonshire, the services that you request, your location and applicable law. However, the information that we collect broadly falls into the following categories:
(a) Information from You
You may voluntarily provide certain Personal Information about you to us by mail, by email, over the telephone, through our website or in any other direct manner. For example, we collect Personal Information when you contact us with an inquiry, fill out an application or other form or while visiting our website by inputting information requested during the course of your visit.
(b) Information from Other Sources
From time to time, we may obtain Personal Information about you from other sources, such as references, employers and consumer reporting agencies. We do so in order to
provide you with the services that you requested as well as to verify your identity and the accuracy of the information that you have provided.
(c) Information from Online Technologies
We collect certain types of information electronically, such as information about your device and your use of our website, through technologies such as cookies and web and mobile analysis services. This information helps us understand what actions you take on our website and to ensure that our website is functioning normally. Further information is provided below in the section titled “Anonymous Information and Cookies”.
You may visit our website anonymously, if you wish to not provide your Personal Information. We will collect Personal Information from you only if you voluntarily submit such information to us. You can always refuse to supply your Personal Information, except that it may prevent you from engaging in certain activities on our website.
How We Use Your Information
Devonshire uses and discloses your Personal Information for the purposes for which it was collected. Specifically, we collect your Personal Information for the following purposes:
• Establishing and maintaining communications with you;
• Making decisions about tenant applications such as assessing eligibility and renewal of leases;
• Responding to your inquiries about applications, accounts and other services; • Evaluating credit worthiness for purposes of enforcing tenant agreements; • Processing payments;
• Responding to emergency situations;
• Ensuring the orderly management of our rental and commercial properties; •
Providing building and rental-related services to you;
• Updating you about our services and to offer you additional products or services that you may be interested in, so that we may continue to serve your housing needs; and • Meeting legal requirements.
Your Personal Information will not be used without your consent for purposes other than those listed above or in accordance with applicable laws. From time to time, we may collect Personal Information for new or additional purposes, in which case we will amend this Privacy Policy to include these new or additional purposes and will obtain your consent through your continued use of our website and services.
You may withdraw your consent at any time, subject to any legal implications. In some cases, if you do not consent to our use or disclosure of certain Personal Information, we may be unable to continue to provide all or part of the services you have requested. You may withdraw your consent by contacting the Privacy Officer at the address below.
Personal Information may be anonymized and consolidated into group data, which may be shared on an aggregated basis with research firms. The shared data will not disclose your Personal Information and will not enable the recipients to contact you. This Privacy Policy does not apply to aggregated data from which it is not possible to determine the identity of a specific
individual. Devonshire reserves the right to use aggregated data in any way that it determines appropriate.
Disclosure of Personal Information
Devonshire may disclose your Personal Information in the following circumstances: (a) In the course of business
Employees of Devonshire with a legitimate reason for accessing your Personal Information may have access to your Personal Information in the course of business. They must follow all applicable laws and regulations, including this Privacy Policy. Any unauthorized use of or disclosure of Personal Information by any of our employees is prohibited and may result in disciplinary measures.
(b) Services from Third Parties
From time to time, we may use and disclose your Personal Information to our affiliates, service providers, data processors and other third parties (“Third Parties”) in order to meet your needs, provide you with services offered through us or as otherwise authorized by you. In these circumstances, the Third Parties are only given the information that is needed in order to render their service. The Third Parties receiving the Personal Information are obligated to keep such information confidential and secure and are prohibited from doing anything with this information that we have not authorized them to do. If required or permitted to do so by law, we will disclose your Personal Information to Third Parties without obtaining your prior approval or providing you with notice thereof.In some cases, we partner with Third Parties to offer you services that may be of interest to you (for example, telecom services). You may be directly contacted by such Third Parties from time to time in relation to such services.
(c) Sale or Transfer of Business or Other Transaction
We may disclose or transfer your Personal Information to Third Parties as part of a merger, acquisition, debt financing or sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which Personal Information is transferred to Third Parties as one of our business assets.
(d) Other Permitted Reasons
Devonshire may be required to disclose Personal Information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. We may also disclose information to a government body or agency in order to comply with tax reporting requirements as well as to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers in emergencies or where required or permitted by law. We may also release certain Personal Information when we have reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or personal safety of Devonshire, its clients, employees or other members of the public, in accordance with or as authorized by law.
How We Safeguard Information
We restrict access to Personal Information about clients to those employees of ours and Third Parties who need to know that information in order to provide products or services to our clients. We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain regarding clients. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information.
At all times, Devonshire adheres to applicable legal or regulatory requirements concerning the storage and protection of Personal Information. Where the services of Third Parties are used, these Third Parties and the databases where they store Personal Information may be located outside of Canada. As a result, when your Personal Information is used or stored in a jurisdiction outside of Canada, it may be subject to the laws of that jurisdiction in which it is located.
Anonymous Information and Cookies
Our website collects anonymous information about how our website is used. This means that the information collected cannot be traced back to a specific person. For example, our web servers record certain information automatically from your web browser or mobile device when you visit our website. This information is collected using “cookies”, which are small text files that are saved on your computer when you visit a website that uses cookies, and may include the pages you visited, your IP (Internet protocol) address, the type of mobile device you use, web browser type and other site usage statistics. This anonymous information is used for research and analytical purposes only in order to better understand how our website is being used and to improve the functionality of the site. It does not reveal any Personal Information about you, the user. This aggregate data may be disclosed to Third Parties, but never with personally identifying information in the resulting data. Most major websites use this technology and most browsers are set up to accept them. You may configure your browser to notify you when you receive a cookie and you may refuse to accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our website. You may choose to delete cookies after visiting our website.
Google Analytics
Our website uses Google Analytics, a web and mobile analysis service provided by Google that facilitates an analysis of your use of our website. You may opt out of Google Analytics by installing a deactivation plug-in from Google that will provide you with more control over what data Google can collect on websites you access. However, the deactivation plug-in does not prevent information from being transmitted to us or to other web and mobile analysis services that we may use.
Data Security
Unfortunately, the transmission of information over the internet is not completely secure. Although we will take reasonable steps to protect your Personal Information, you agree to do so at your own risk, as we cannot guarantee the security of your data transmitted to our website.
Where a security breach has occurred, we may try to notify you electronically so that you can take action to protect your Personal Information. By using our website or providing us with your Personal Information, you agree that we can communicate with you electronically regarding any security, privacy or administrative issues relating to our website. We may post a notice on our website to advise of the breach or we may email you a notification to the e-mail address provided to us.
A Notice to International Users
If you are visiting our website from outside Canada, please be aware that you are transferring information (including Personal Information) to Canada where our servers are located. By transmitting your information (including any Personal Information), you consent to Devonshire’s use of your information for the purposes set out in this Privacy Policy.
Accessing and Rectifying Your Information
You have the right to access the Personal Information we keep in your file and request rectifications of any Personal Information in your file that may be obsolete, incomplete or incorrect. If you would like to access your Personal Information or make changes to your Personal Information, please submit a written request to our Privacy Officer at the address listed below. We will respond to your request as efficiently as possible.
Changes to this Privacy Policy and Your Acceptance of these Terms
Devonshire reserves the right to make changes to and to update this Privacy Policy at any time. Such changes will take effect immediately upon posting. We encourage you to check this Privacy Policy from time to time to review the most current version. For your convenience, the last revised date of the current Privacy Policy will be posted at the bottom of this page. If you do not agree with the terms of this Privacy Policy, please do not use our website. By continuing to interact with us following such changes, including by using our website, you will be deemed to have accepted such changes.
Inquiries
If you have any questions or concerns about this Privacy Policy, or would like to submit a request to access or rectify your Personal Information, please contact our Privacy Officer in writing or by phone:
Privacy Officer
Devonshire Properties Inc.
Suite 300 – 1333 Johnston Street Vancouver, BC
V6G 3R9
(604) 879-7368
Last revised date: January 28th, 2021