StayLant Capital is
a leading, fully
integrated real
estate services
company providing
investment
management, property
management, leasing
and development
services to clients
across
Canada
and in select
U.S.markets. While
privacy has always
been treated as a
priority at StayLant
, we have now taken
more formal steps to
promote responsible
and transparent
practices in the
management of
personal information
in accordance with
various privacy
information
protection statues.
This Privacy Policy
describes StayLant
’s policies
regarding the
collection, use,
disclosure, and
retention of
Personal Information.
We ensure that our
employees sign a
code of business
conduct that
requires the
safeguarding and
proper use of
confidential
information,
including personal
information. We
also have
appropriate controls
on the protection of
personal information
within our systems
and websites and
ensure that our
employees are
trained to respect
privacy of personal
information at all
times.
StayLant will
continue to review
and amend its
Privacy Policy to
ensure it remains
current with the
changing environment
and regulations and
it may be
supplemented or
modified by
agreements entered
into between
StayLant and an
individual or
organization from
time to time.
StayLant is
responsible for
personal information
under its control
and shall designate
one or more
individuals who are
accountable for the
company’s compliance
with the Privacy
Policy.
Principle 2 –
Collection and
Purpose of Personal
Information
StayLant shall
identify the
purposes for which
personal information
is collected at or
before the time the
information is
collected.
Principle 3 –
Consent for
Collection, Use or
Disclosure of
Personal Information
The knowledge and
implicit or explicit
consent of the
individual are
required for the
collection, use or
disclosure of
personal information,
except where
inappropriate or not
required.
Principle 4 –
Limiting Collection
of Personal
Information
The collection of
personal information
shall be limited to
that which is
necessary for the
purposes identified
by StayLant .
Information shall be
collected by fair
and lawful means.
Principle 5 –
Limiting Use,
Disclosure and
Retention of
Personal Information
StayLant shall limit
the use and
disclosure of
personal information
to those purposes
for which it was
collected, except
with the consent of
the individual or as
required by law.
StayLant shall
retain personal
information only as
long as necessary
for the fulfillment
of those purposes.
Principle 6 –
Accuracy of Personal
Information
Personal information
shall be as accurate,
complete and up-to-date
as necessary for the
purposes for which
it is to be used.
Principle 7 –
Security Safeguards
StayLant shall
protect personal
information by the
use of security
safeguards
appropriate to the
sensitivity of the
information.
Principle 8 –
Openness Concerning
Policies and
Practices
StayLant will make
available to
customers, employees
and other parties
with whom it does
business, specific
information about
its policies and
practices relating
to the management of
personal information.
Principle 9 – Access
to Personal
Information
Upon request,
StayLant shall
inform an individual
of the existence,
use and disclosure
of his or her
personal information
and shall give the
individual access to
the information. An
individual shall be
able to challenge
the accuracy and
completeness of the
information and have
it amended as
appropriate.
Principle 10 –
Challenging
Compliance
An individual shall
be able to address a
challenge concerning
compliance with the
Privacy Policy to
the designated
individual or
individuals
accountable for
StayLant ’s
compliance.
3. Scope and
Application
The ten principles
outlined form the
basis of the
StayLant Privacy
Policy and are
interrelated.
StayLant shall
adhere to the ten
principles as a
whole which must be
read in conjunction
with accompanying
commentary which is
tailored to reflect
the specific
circumstances of
StayLant .
The Privacy Policy
applies to personal
information about
StayLant ’s
customers, suppliers,
employees or other
individuals that is
collected, used or
disclosed by
StayLant and to the
management of
personal information
in any form, whether
oral, electronic or
written.
This Privacy Policy
applies to all of
StayLant ’s
companies including
StayLant Capital
Limited Partnership,
StayLant Real Estate
Services Limited
Partnership,
StayLant Retail
Services Limited
Partnership, and
StayLant Investment
Management Limited
Partnership,
StayLant Capital US
Inc, and StayLant
Residential LLC (collectively,
“StayLant ”).
StayLant ’s U.S.
companies, including
StayLant Capital US
Inc and StayLant
Residential LLC, may
have more specific
guidelines than
outlined in this
policy to ensure
compliance with
applicable
U.S.
legislation.
Fairwinds Real
Estate Management
Inc. is subject to
its own privacy
policies.
Disclosure
means anytime
Personal Information
is transferred to a
third party outside
StayLant .
Personal Information
means any
information about an
identifiable
individual, such as
a customer, supplier,
employee or other
individual, but does
not include:
An individual’s
business contact
information
including the
name, position
name or title,
business
telephone number,
business address,
business e-mail,
and business fax
number of an
individual
Other
information
about an
individual that
is publicly
available
information as
designated under
applicable laws,
such as
information
available from a
public registry.
Aggregated
information that
cannot be
associated with
a specific
individual.
Purposes
means the purposes
for the collection,
use, or disclosure
of Personal
Information that
have been identified
to an individual by
StayLant , including
the purposes
described in this
Privacy Policy.
Use
means use whichoccurs any time
data about an
identifiable
individual is
accessed,
manipulated, altered
or deleted within
StayLant .
StayLant is
responsible for the
Personal Information
under its control,
and we have
designated a Privacy
Officer who is
responsible for our
compliance with this
Privacy Policy and
with applicable
laws. Other
individuals within
StayLant may be
delegated to act on
behalf of the
Privacy Officer and
StayLant shall use
appropriate means to
provide a comparable
level of protection
while information is
being processed by a
third party.
Principle 2 –
Collection and
Purpose of Personal
Information
StayLant shall
identify the
Purposes for which
Personal Information
is collected at or
before the time the
information is
collected.
StayLant
collects Personal
Information for the
following purposes:
To establish and
maintain
commercial
relationships
with customers
and provide
ongoing service;
To manage and
develop StayLant
’s business and
operations,
including
employee and
personnel
matters; and
To meet legal
and regulatory
requirements
StayLant collects
Personal Information
for these purposes
through various
means including, but
not limited to:
General
email and other
correspondence
that is sent to
StayLant
from service
providers in
connection with
the Purposes
web site forms
verbal
discussions
Property Management
and Leasing
applications for
tenancy
including credit
applications
(may collect
credit-related
or other
information
about the
individual from
a third party
credit reporting
agencies, banks,
references, etc)
applications for
specialized
services and
memberships,
such as parking,
fitness
facilities or
golf club
memberships
leases and other
associated
agreements
entered into
with StayLant
commercial
agreements
entered into
with StayLant
emergency or
incident
reporting
including video
and other
surveillance for
insurance and
risk management
purposes
video
surveillance,
swipe cards and
other
information for
general security
purposes
Investment
Management
commercial
agreements
entered into
with StayLant
Employment
resumes &
personal
references
provided in
applications of
employment
employment forms
Principle 3 –
Consent for
Collection, Use or
Disclosure of
Personal Information
The knowledge and
implicit or explicit
consent of an
individual is
required for the
collection, use or
disclosure of
Personal
Information, except
where inappropriate
or not required.
Requirements for
consent to
collection, use, or
disclosure of
Personal Information
vary depending on
circumstances and on
the type of Personal
Information that is
intended to be
collected, used, or
disclosed.
§In
obtaining consent,
StayLant shall use
reasonable efforts
to ensure that an
individual is
advised of the
Purposes for which
the Personal
Information will be
used or disclosed.
§Generally,
StayLant will seek
consent at the same
time that it
collects the
information.
However, StayLant
may seek consent to
use and disclose
personal information
after it has been
collected, but
before it has been
used or disclosed
for a new purpose.
§
StayLant will
require individuals
to consent to the
collection, use or
disclosure of
Personal Information
as a condition of
the supply of a
service or
employment if such
collection, use or
disclosure is
required to fulfill
the identified
purposes.
§
In determining
whether consent is
required and, if so,
which form of
consent is
appropriate,
StayLant will take
into account both
the sensitivity of
the Personal
Information and the
purposes for which
StayLant will use
the information.
Consent may be
express or implied (including
through use of
“opt-out” consent
where appropriate).
For example, if an
individual provides
his/her mailing
address and requests
information
regarding a
particular service,
consent to use the
address to provide
the requested
information may be
implied.
§
In general, the use
of services by an
individual
constitutes implied
consent for StayLant
to collect, use and
disclose Personal
Information for all
identified Purposes.
§
StayLant can
collect, use and
disclose employee
Personal Information
without the consent
of the individual
where the
collection, use or
disclosure is
reasonable for the
purposes of
establishing,
managing or
terminating an
employment
relationship between
StayLant and the
individual.
§On
giving reasonable
written notice to
StayLant , an
individual may
withdraw consent to
the collection, use,
or disclosure of his
or her Personal
Information subject
to legal or
contractual
restrictions. Upon
notice of withdrawal
of consent, StayLant
will notify the
individual of the
likely consequences
of withdrawing his
or her consent and,
except where
otherwise required
or permitted by law,
StayLant will stop
collecting, using,
or disclosing the
Personal Information
as requested.
If a person provides
StayLant or its
service providers or
agents with Personal
Information about an
individual, the
person represents
that it has all
necessary authority
and/or has obtained
all necessary
consents from such
individual to enable
StayLant to collect,
use, and disclose
such Personal
Information for the
purposes set forth
in this Privacy
Policy.
StayLant may collect,
use or disclose
Personal Information
in certain limited
circumstances
without the
knowledge and
consent of the
individual.
Examples of this
include:
§
StayLant may collect
or use Personal
Information if it is
clearly in the
interests of the
individual and
consent can not be
obtained in a timely
way, such as when
the individual is
seriously ill,
mentally
incapacitated, or in
the case of an
emergency where the
life, health or
security of an
individual is
threatened.
§
StayLant may
disclose personal
information without
knowledge or consent
to collect a debt,
to comply with a
subpoena, warrant or
other court order,
or as may otherwise
be required or
authorized by law.
§
StayLant may
collect, use or
disclose personal
information without
the knowledge and
consent of the
individual if
seeking consent of
the individual is
reasonably expected
to compromise the
availability or the
accuracy of personal
information
reasonably required
for an investigation
or a proceeding such
as in the case of an
investigation of a
breach of agreement
or contravention of
federal or
provincial law.
Principle 4 –
Limiting Collection
of Personal
Information
Except where
required or
permitted by law,
StayLant will limit
the collection of
Personal Information
to the Personal
Information that is
necessary to fulfill
the Purposes. StayLant
will collect
Personal Information
by fair and lawful
means.
§StayLant
primarily collects
Personal Information
directly from its
customers, suppliers
or employees.
§StayLant
may also collect
Personal Information
from other sources
including credit
agencies, employers
or personal
references, or other
third parties who
represent that they
have a right to
disclose the
information.
Principle 5 –
Limiting Use,
Disclosure and
Retention of
Personal Information
StayLant shall limit
the use and
disclosure of
personal information
to those purposes
for which it was
collected, except
with the consent of
the individual or as
required by law.
StayLant shall
retain personal
information only as
long as necessary
for the fulfillment
of those purposes.
StayLant uses
Personal Information
collected from
customers, potential
customers, and other
individuals as
follows:
to
respond to
requests for
information
regarding
StayLant ’s
products and
services
to
determine
whether to
provide products
or services to a
customer or
potential
customer, such
as assessing and
confirming the
accuracy of
information
provided in
applications for
tenancy and
assessing
creditworthiness,
or to determine
whether to
establish a
commercial
relationship
with suppliers
or other third
parties
to communicate
with customers
when required,
outside of
regular business
channels
to establish,
manage, or
terminate our
relationship
with and to
provide services
and products to
customers,
including to
issue invoices,
to collect and
process
payments, and to
fulfill
contractual
obligations
to distribute
any StayLant
publications
that may be
provided to
individuals
other than at
business
addresses
to detect and
protect against
fraud, theft,
breach of
contract, or
non-compliance
with an
obligation by
customers,
tenants, or
others
as required or
permitted by law
for additional
purposes that
may be
identified at or
before the time
that the
information is
collected or for
new purposes to
which an
individual has
consented.
Access to Personal
Information is
limited to those
employees and
service providers of
StayLant who require
access in connection
with the Purposes.
StayLant may
disclose certain
Personal Information
to third parties or
to affiliated
entities as
reasonably required
in connection with
the Purposes, as
otherwise consented
to by an individual,
and where required
or permitted by law,
including as follows:
to an
organization or
individual
retained by
StayLant to
assist in
respect of any
Purposes, such
as service
providers
engaged by
StayLant to
provide data
processing
services,
facilities
management
services, call
centre
operations,
processing and
sending of mail-outs,
or building
maintenance
a credit
reporting agency
references for
customers
to ClikFix,
StayLant ’s
branded tenant
service response
system
to an
organization or
individual
retained by
StayLant to
evaluate an
individual’s or
organization’s
creditworthiness
or to collect
debts
outstanding on
an account
to a financial
institution in
connection with
the assignment
of a right to
receive payment,
the provision of
security, or
other financing
arrangements
to a person who,
in the
reasonable
judgment of
StayLant , is
providing or
seeking the
information as
the agent of the
individual for
which the
information is
sought
to legal,
accounting,
financial,
insurance, and
other advisors
as reasonably
required in
connection with
the Purposes or
the operation of
its business
to
law enforcement
agencies in
connection with
the
investigation of
unlawful acts
to
governmental or
regulatory
agencies as
required or
permitted by law
to
a third party in
connection with
the sale,
reorganization,
or financing of
all or part of
StayLant ’s
business or
operations
for additional
purposes that
may be
identified at or
before the time
that the
information is
collected or
disclosed or for
new purposes to
which an
individual has
consented.
StayLant may
disclose Personal
Information about
its employees:
for normal
personnel and
benefits
administration
where
the employee
consents to such
disclosure or
disclosure is
required by law.
In respect of
Personal Information
disclosed to third
parties, StayLant
takes appropriate
steps to ensure that
such third parties
use the Personal
Information only in
connection with the
Purposes and
safeguard the
Personal Information
against unauthorized
use or disclosure.
Only StayLant ’s
employees, whose
duties reasonably so
require, are granted
access to personal
information about
customers and
employees.
StayLant shall keep
Personal Information
only as long as it
remains necessary or
relevant for the
Purposes or as
required by law.
Depending on the
circumstances, where
Personal Information
has been used to
make a decision
about an individual,
StayLant will retain
the information for
at least one year so
that the individual
has a reasonable
opportunity to
obtain access to it.
Once Personal
Information is no
longer required to
fulfill the Purposes
and is no longer
required or
permitted to be
retained for legal
or business
purposes, it will be
destroyed or made
anonymous.
Principle 6 –
Accuracy of Personal
Information
StayLant will take
appropriate steps to
ensure that Personal
Information
collected by
StayLant is accurate
and complete as
reasonably required
in connection with
the Purposes,
including where
Personal Information
is likely to be used
by StayLant to make
a decision that
affects the
individual to whom
the Personal
Information relates
or if the Personal
Information is
likely to be
disclosed to a third
party.
Principle 7 –
Security Safeguards
StayLant stores
Personal Information
at our premises or
at the premises of
our services
providers and will
protect this
information by
security safeguards
appropriate to the
sensitivity of the
information.
§
StayLant takes steps
to ensure the
security of Personal
Information,
regardless of the
format in which it
is held, while in
its custody is
appropriate to the
sensitivity of the
information,
including physical
security measures
(such as the use of
locked cabinets and
storage facilities)
and technological
security measures
(such as the use of
passwords and
encryption).
§
All StayLant
employees with
access to Personal
Information are
required to respect
the confidentiality
of that
information.
§StayLant
will take
appropriate steps to
protect Personal
Information
disclosed to third
parties, such as by
contractual
agreements
stipulating the
confidentiality of
the information and
the purpose for
which it is to be
used.
Principle 8 –
Openness Concerning
Policies and
Practices
StayLant will make
available to
customers, suppliers,
employees and other
individuals specific
information about
its policies and
practices relating
to the management of
personal information.
StayLant will make a
reasonable effort to
assist individuals
and respond as
accurately and
completely as
practically possible.
Principle 9 – Access
to Personal
Information
Upon request,
StayLant shall
inform an individual
of the existence,
use and disclosure
of his or her
personal information
and shall give the
individual access to
the information. An
individual shall be
able to challenge
the accuracy and
completeness of the
information and have
it amended as
appropriate.
§
An individual may,
upon written request
to StayLant ’s
Privacy Officer,
access the Personal
Information about
the individual that
is in the custody of
StayLant . Within 30
days of such request
(or such longer time
as permitted by law),
StayLant will inform
the individual of
existence, use, and
disclosure of such
information.
§
An individual may,
upon written request
to StayLant
,
request a correction
to an error or
omission in any
Personal Information
that is under
StayLant ’s
control.
StayLant
will, as
appropriate, amend
the information as
requested and use
its best efforts to
send the corrected
Personal Information
to each third party
to which it has
disclosed the
information during
the preceding year.
The written request
must provide
sufficient detail to
enable StayLant ,
with a reasonable
effort, to identify
the individual and
the personal
information or
correction being
sought.
Principle 10 –
Challenging
Compliance
An individual may,
upon written request,
address a challenge
concerning StayLant
’s compliance with
the Privacy Policy
to our Privacy
Officer.
If you have any
questions or
concerns about this
Privacy Policy or
about the collection,
use, or disclosure
of your Personal
Information by
StayLant ,
please contactour Privacy
Officer.
StayLant Capital ("StayLant
") respects your
right to privacy.
The following
guidelines dictate
the manner in which
StayLant protects
the privacy of its
visitors to our web
site and by
accessing, browsing
or using this web
site, you
acknowledge that you
have read,
understand and agree
with the provisions
contained herein.
Web Site
Administration
When you visit the
StayLant web site,
some information may
be collected
automatically by the
software that
operates our web
site (i.e. the site
from which you
linked, your
Internet Service
Provider, the time
and date of your
visit). Our servers
do not track,
collect, or
distribute personal
information about
visitors to our web
site. This
information is used
by our technical
engineers to compile
aggregate statistics
about the total
number of daily
visitors to our site,
the pages most
frequently visited,
and how long people
stay at each page.
None of the
information that we
report allows for
the personal
identification of
individuals.
Links
The StayLant site
contains links to
other web sites;
however, we cannot
be responsible for
the privacy
practices or the
content of such web
sites.
