The purpose of this Privacy Statement is to inform you about the types of Personal Information that CE Properties (“CE Properties,” “we,” or “us”) collects, uses and discloses in connection with the CE Properties.com web site and the CE Properties service (collectively, the “Site”). It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. By accessing the Site, you agree to the terms of this Privacy Statement.
We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under, and principles of, applicable privacy laws in Canada.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last update” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
1. To which organizations does this Privacy Statement apply?
2. What is Personal Information?
“Personal Information” is any information that is identifiable with you. This information may include but is not limited to your name, mailing address, phone number, email address, birthday, age, address, social insurance number, educational and/or employment history, banking information, investment objectives, and investment experience. Personal Information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.
3. How do we collect your Personal Information?
We will always collect your Personal Information by fair and lawful means; for example, it will be collected when you use our Site, when you create your profile, and when making an investment.
4. Where do we store your Personal Information?
We will keep the Personal Information that we collect at the CE Properties offices or at the offices of our third party service providers, as applicable.
5. How do we use your Personal Information?
We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):
- registering you for a user account for the Site (“user account”) including so that we may verify your identity and your status as an eligible investor pursuant to securities laws;
- maintaining your user account;
- providing or performing any services requested by you;
- providing you with information about Offerings, services or promotions that may be of interest to you if you have specifically requested this information;
- to process any investments you make;
- to verify your identity, creditworthiness, and to meet regulatory requirements;
- to gather your opinion and feedback;
- in aggregated, non-identifiable form, to better understand how our users use the resources provided on the Site;
- improving the Site or our services;
- personalizing any interactive tools to better facilitate your use of the Site;
- for such other uses of Personal Information for which you provide your consent; and
- as otherwise permitted or required by law.
6. To whom do we provide your Personal Information?
We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. For example, we may disclose/transfer your Personal Information:
- to our affiliates and related entities, to provide and improve the services offered through the Site and for assisting us with the Purposes;
- to third party service providers (such as payment processors or auditors) with whom we have a contractual agreements that includes appropriate privacy standards, where such third parties are assisting us with the Purposes: for example, service providers may provide telephone support, or data storage;
- to Issuers (as defined in the Terms), for the purposes of completing an investment in an Offering;
- to such persons for which you provide your consent; and
- as otherwise permitted or required by law.
Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of CE Properties (in which case the use of your Personal Information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law.
In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
7. When and how do we obtain your consent?
We obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances. Implied consent occurs when we can assume you have given consent by some other action you have taken or decided not to take. For example, if you request specific information about an Offer / Property Submission or otherwise use our services and you provide us with Personal Information, we infer that you consent to us using such Personal Information reasonably to provide this information or provide you with the service. In limited circumstances, we may rely on a third party to obtain your consent to the sharing of your Personal Information with us.
Under Canada’s Anti-Spam Legislation, as a user of the CE Properties services we have your implied consent to send you electronic messages unless you notify us otherwise. You may do this by using the unsubscribe feature we include in any electronic message we send you or by modifying your user account profile.
8. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?
We ensure that all third parties (including our affiliates) that are retained to perform services on our behalf and are provided with Personal Information are contractually required to observe the intent of this Privacy Statement and our internal privacy policies and practices.
9. How long will we utilize, disclose or retain your Personal Information?
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law. We have established minimum and maximum retention periods and procedures for maintaining and destroying your Personal Information.
10. How can you review your Personal Information that we have collected, utilized or disclosed?
If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.
11. How do you know that the Personal Information we have on you is accurate?
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.
12. What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
13. How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
14. How do we know that it is really you requesting your Personal Information?
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
15. What safeguards have we implemented to protect your Personal Information?
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification, including:
- that the only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information;
- premises security;
- deployment of technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access; and
- internal password and security policies.
16. How do you contact us regarding access to your Personal Information or our Privacy Statement and practices?
All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Statement and practices, should be forwarded to the Concierge Desk or at firstname.lastname@example.org.