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Privacy Policy Privacy of personal information is an important principle of Niot Investment Holdings Limited and Carolyn Court Rental Suites. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the premises, goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies. What is Personal Information ? Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g. gender, age, income, home address or phone number, family status), their health (e.g. disabilities) or their activities and view (e.g. religion, politics, opinions expressed by an individual, opinions about an individual). Personal information is to be contrasted with business information (e.g. an individual's business address and telephone number), which is not protected by privacy legislation. Who We Are Our organization, Niot Investment Holdings Limited provides residential apartments and commercial space for lease. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include building managers, security, cleaning and maintenance organizations, bookkeepers and accountants, computer consultants, temporary workers to cover holidays, cleaners and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they will follow appropriate privacy principals. We Collect Personal Information: Primary Purposes About Tenants Like all landlords, we collect, use and disclose personal information in order to service our tenants and operate our property. For our tenants, the primary purpose for collecting personal information is to ensure their safety, security and reasonable enjoyment and that of our other tenants, to ensure they have access to the premises, equipment and services that we have agreed to provide, to preserve our property and to collect rents and other fees. Examples of the type of information we collect for these purposes includes the following:
As a service and convenience for tenants we may maintain public directories of tenants (eg., by front door). If you do not wish to be listed in any directories or wish to be described in a particular way, please let us know. It would be rare for us to collect any personal information without the tenant's express consent, but this might occur in a case of urgency (e.g. the tenant is unavailable) where we believe the tenant would consent if asked and it is impractical to obtain consent (e.g., information provided by a relative about an absent tenant), appropriate public sources (e.g. government, court or tribunal records) or to investigate a breach of the tenancy agreement or contravention of the law. We subscribe to a consumer reporting service. This service provides information to landlords about prospective tenants. In return, landlords provide information to the service in order for the service to maintain a databank on a tenant's history. We collect your full legal name and date of birth to ensure the accuracy of those records. Having a good tenant history filed with the service will make it easier for you to be accepted as a tenant at other properties in the future. We obtain your consent to using the consumer reporting service in your rental application form and tenancy agreement. The information described above and the information set out below about prospective tenants can be collected or updated if the tenant is in arrears of rent or fees or wishes to renew a tenancy agreement. About Prospective Tenants Prospective tenants are requested to complete a rental application form so that we can assess their suitability as a tenant and have necessary basic information should they become tenants. This would include the following types of information:
We will then confirm this information and check references and the conduct history of the prospective tenants. This might include following up with other individuals identified during the course of these inquiries as having relevant information (e.g. a person identified by a reference you provided to us). We may also contact a credit agency and/or consumer reporting service for information about your suitability. We might also check appropriate public sources (e.g. government, court or tribunal records). By completing a rental application form you agree to our collecting this information about your suitability to be a tenant. About Members of The General Public For members of the general public, our primary purpose for collecting personal information is to promote the safety of our tenants and the security of our property. For example we may operate security cameras and monitor the presence, vehicles and conduct of visitors and non-tenants on our property. We believe that the collection of this information is implied by the private and residential nature of our property. Secondly, we might gather personal information in the course of marketing our property to prospective tenants. This information is collected either from appropriate public sources (e.g. telephone directories) or directly from the individuals with their consent. On our website, we only collect, with the exception of cookies (electronic markers identifying computers that have previously visited our website) the personal information you provide and only use that information for the purpose you gave it to us (e.g. to respond to your email message, to provide information about our property and services). Cookies are only used to help you navigate our website and are not used to monitor you. Suppliers and Contractors We often deal with suppliers and contractors who provide goods and services to the properties we own. We monitor their performance, including their promptness, reliability, quality and value of services. Most of this information is business information and would not be covered by privacy legislation. However, occasionally, this information relates to the conduct of an individual (e.g. skill of a particular employee of a supplier or contractor, inappropriate behavior or comments by a particular representative). We reserve the right to collect this information, use it in deciding upon future services and to disclose it to our property manager or others involved in related or similar operations. We may also collect home contact information to reach them in case of emergencies. We may use the services of a property manager. We will share any personal information we collect relevant to a particular property with that property manager but only for the purpose of assisting them in providing services to us. We ask any property manager to have their own privacy policy consistent with both our privacy policy and the Personal Information Protection and Electronic Documents Act. About Contract Staff For people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of an emergency (e.g. an outbreak of a contagious disease) or to investigate a possible breach of law (e.g. if a theft were to occur). We Collect Personal Information: Related and Secondary Like most landlords, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:
You can choose not to be a part of some of these related or secondary purposes (e.g., by not having a third party pay your rent). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation). Protecting Personal Information We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Retention and Destruction of Personal Information We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our tenant files for about ten years. Our tenant and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our tenants for about five years. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed or completely reformatted. You Can Look at Your Information With some exception, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g. short forms, technical language, etc.). We will need to confirm your identify, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days, if at all possible and tell you the reason, as best we can, as to why we cannot give you access. If you believe there is a mistake in the information, you have the right to ask for it to be corrected. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information. Do you Have a Question ? Our Information Officer, Janet Connolly, can be reached at: Niot Investment Holdings Limited She will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a form decision and reasons in writing. This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street
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