PRIVACY POLICY

What Is Personal Information?
Personal information is information about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual. Personal Information does not include your business contact information when used for the purpose of communicating with you in relation to your employment, business or profession, including your name, position name or title, work address, work telephone number, work fax number or work electronic address.

What Information Do We Collect From You?
We collect and use different types of information from and about you including:

• personal information that could be used to contact you, such as your full name, postal address, telephone number and email address;
• personal information in comments, questions or forms that you may submit to us via our Websites, social media platforms, in person, over the phone, or during other interactions;
• copy of your government-issued photo ID;
• payment information used to process purchases;
• information obtained via cookies, as further described in the “cookies” section;
• non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information derived from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature;
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, browser plug-in types and versions, or operating system and platform;
• details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page or any phone number used to call our customer service number;
• information about mortgage pre-approval statements for internal use only;
• personal information contained within our Buyer Survey, including your name, date of birth, address, reasons for moving, reasons influencing purchasing one of our homes, how you heard about us, how you will use your home, what is your design style, where you find your news, your family status, marital status, occupation and retirement status (this information will be used for internal demographic reporting).

If we combine or connect non-personal, technical, or demographic data with personal information so that it directly or indirectly identifies you as an individual, we treat the combined information as personal information.

How Do We Collect Information From You?
We use different methods to collect information from and about you including:

• we may request that you provide certain personal information to us through various means, including in person through a visitor form, or digitally through website forms or your responses to email communications and online surveys;
• we may obtain personal information from you when you buy a home from us, for the purpose of completing your purchase;
• when you correspond with us by phone, e-mail or otherwise;
• when you sign up on our Websites to receive email newsletters and other informational material;
• as you interact with our Websites, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies and other similar technologies. See “cookies” below.
• We may receive information about you from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers or aggregators.

How Do We Employ Cookies & Other Automated Data Collection?
Our Websites use cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Websites. It also allows us to improve our Website by enabling us to:

• Estimate our audience size and usage patterns;
• Use web browser cookies to:
  • Store your preferences so we may customize our Websites according to your individual interests;
  • Recognise you when you return to our Websites;
  • Collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). You can opt out of such activities by using the mechanisms listed in the “Opt Out” section of our policy, (hyperlink to be added) below.

How Do We Use Your Personal Information?
We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

• contact you, notify you of updates or promotions, or to seek your feedback;
• if you purchase a home from us, notify you of community events, construction or maintenance updates, or other matters related to the purchase of your home;
• meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements;
• present our Websites and provide you with the information, products, services and support that you request from us;
• enable your participation in our Websites’ interactive, social media or other similar features;
• use third-party ad networks, publishers, social media platforms, and other entities to serve targeted content and interest-based (behavioural) advertisements to you, including social media (such as Facebook) based on your browsing history on the Websites. For example, we may have Facebook or Instagram serve posts to you with information about that we believe will be of interest to you. We may also use third party analytics vendors to evaluate and provide us with information about the use of our websites and viewing of our content;
• notify you about changes to our Website, products or services;
• ensure that we present our Website content in the most effective manner for you and for your computer; administer our Websites and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical and survey purposes; and improve our Websites, products or services, marketing, or customer relationships and experiences;
• make suggestions and recommendations to you and other users of our Websites about goods or services that may interest you or them;
• protect our Websites, employees or operations.
• fulfil the purposes for which you provided the data or that were described when it was collected;
• other purposes as may be required or permitted by applicable law.

We may aggregate or anonymize your personal information in order to use the non-identifiable information for any business purpose.

To Whom Do We Disclose Your Information?
We will not sell or rent your name, email address or other personal information to any third party.

a) Third Party Service Providers
We may transfer your personal information to third parties hired to provide certain services, including for example, packaging, sending postal mail, processing event registration, seeking your feedback via about your customer experience, providing analytics and search engine optimization to assist us to improve or our websites, or contacting you about your eQ Home, upcoming events, promotions, and community news. In addition, if you purchase a home from us, we may share your personal information with service providers in order to facilitate the set-up of utilities in your new home (e.g. cable, hydro, etc.). As noted in the “cookies” section below, we may use third-party ad networks, publishers, social media platforms, and other entities to serve targeted content and interest-based advertisements to you.

We will only provide third party services providers with the personal information required by them to deliver the services they have been retained to provide and will obligate such third-party providers to maintain your information in confidence.

We note that our third party service providers may be located in, or transfer your personal information to servers located outside of Canada in the course of providing services to us, with the effect that your personal information may be subject to disclosure pursuant to lawful requests made by foreign authorities.

b) Affiliates and Others
We may share your personal data with:

• any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and affiliates;
• third parties, for any other purposes that we disclose when you provide the data or to which you provide consent
• prospective sellers or buyers of our business assets, in the event that we sell or buy and business or assets, and in accordance with applicable laws;
• government or regulatory authorities, to comply with any court order, law, or legal process, including responding to any government or regulatory request including search warrants, subpoenas, court orders, or other legally valid inquiry or order;
• credit reference agencies, when we ask you to obtain an assessment of your credit score before entering into a contract;
• third parties to:
  • enforce or apply our terms and conditions of supply and other agreements;
  • protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of cybersecurity, fraud protection, money laundering, loss of property, harm to persons, and credit risk reduction;
  • establish or exercise our legal rights or to defend against legal claims;
• as otherwise permitted or required by law.

How Do We Secure Your Personal Information?
The security of your personal information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, use, alteration or disclosure. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we limit access to our servers, and only employees who must see your information to provide products and service to you are entitled to access your information. We store the personal information you provide on secured computer servers that are located in controlled facilities.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

Opting Out/Withdrawing Consent
a) Cookies and Behavioural Advertising
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies.

You may also opt-out of behavioural advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page and the Network Advertising Initiative Opt-Out Page. These websites provide tools that identify member companies that have cookies on your browser and provides mechanisms to opt-out of those cookies.

We use Facebook Custom Audiences to ask Facebook to show you interest-based advertisements based on your interactions with us and to measure how you interact with those advertisements. We may do this using web tracking tools or by converting the email address, phone number or other contact information you have provided to us into a unique value that Facebook may compare to a unique value created from information you provided to Facebook. Please visit Facebook for information on how Facebook’s advertising privacy policies and opt out options. https://www.facebook.com/about/privacy/.

We may also use similar advertising programs for other social media sites you use. If you would like to opt out, please adjust your Facebook and other social advertising settings, use the opt-out features in the advertisement or contact us using the contact details provided below.

Google Ads: https://www.howtogeek.com/285835/how-to-opt-out-of-personalized-ads-from-google/
Instagram Ads: https://help.instagram.com/173081309564229?helpref=search&sr=1&query=ads

b) Promotional Offers and Emails
If you do not want us to use your email address or contact information to promote our own products and services, or third parties’ products or services, you can opt-out by contacting us at any time at the contact details provided below.

You may also opt-out of marketing and promotional email communications by replying to any promotional email we have sent you or following the opt-out links on that message.

c) Withdrawing Consent
You have the right to withdraw your consent to our further collection, use and disclosure of your personal information at any time, subject to applicable legal and contractual restrictions. Withdrawal of consent will not operate retroactively (for example, where we have disclosed your personal information to third parties), and may impact our continued ability to provide you with certain products and services.

d) Accessing and correcting your personal data
You may contact us at the contact information provided below to request access to or correction of any personal information that you have provided to us. You are entitled to complain about our information handling policies by contacting us. If we cannot resolve your complaint, you are entitled to complain to the Privacy Commissioner of Canada, at: https://www.priv.gc.ca/en/contact-the-opc/

Questions/Contact
If you have any questions or concerns about this Policy, or if you wish to access, update, or change any personal information or opt out of or withdraw your consent to our further use of your personal information as described in this policy, please contact us at privacyofficer@eqhomes.ca or by mail at:

Attn: Privacy Officer
eQ Homes Inc.
1737 Woodward Drive Ottawa,
ON K2C 0P9

Changes to Our Privacy Policy
We will post any changes we may make to our privacy policy on our Websites. If the changes materially alter how we use or treat your personal information we will notify you by email to the extent that we have your email address or otherwise through a notice on our Website home pages. Please check back frequently to see any updates or changes to our privacy policy.

1 List of affiliated companies: Riverlands of Rockland Inc., eQuinelle Developments Inc., ., Fernbank Crossing Regional Inc., Greystone Village Inc., Pathways Regional Inc., Riverwalk Manotick Regional Inc., Provence Orleans Realty Investments Inc.