Privacy Policy

Maddox Cabbagetown Privacy Policy

Effective as of April 17, 2025

Maddox Sherbourne Inc. and ONTARI Holdings Ltd. (“Maddox”, “us”, “we”, or “our”) values and respects your privacy. We have prepared this Privacy Policy to describe the manner in which we collect, use, disclose and otherwise process personal information when you visit our website located at https://www.maddox.ca/ (the “Website”), apply to become and/or become a resident at a Maddox property, visit a Maddox property, use Maddox property services, use one of our mobile applications, such as the Maddox app (the “Maddox App”), or otherwise interact with us.

Table of Contents

1. Collection and Use of Personal Information
2. Sharing of Personal Information
3. Digital Technologies on our Website and in our Apps
4. Your Choices and Privacy Rights
5. Data Governance, Security and Retention Practices
6. Other Important Information

1. Collection and Use of Personal Information

How we collect and use personal information:

As described in more detail below, depending on the ways in which you interact with us, we may collect and use your personal information to:

• Establish and maintain a tenancy relationship with you and provide you with property management services
• Authorize your access to one of our properties as a visitor
• Engage with you through our Website or apps, including to show you tailored advertising
• Send you marketing communications
• Facilitate your involvement in contests and promotions
• Gather information through surveys or feedback forms
• Engage with you on social media
• Facilitate your attendance at our events
• Process and respond to job applications
• Communicate with you, such as to schedule an appointment viewing or provide resident support
• Generate anonymous data

To establish and maintain a tenancy with you and provide you with property management services.

If you are a resident, or apply to become a resident, of one of our properties, we collect personal information to establish and maintain our tenancy relationship with you and provide you with property management services, including:

• Processing your rental application. We collect the personal information you provide when you complete a rental application (either directly with us or through a third-party platform) to process your application and assess your suitability as a resident. This may include your full name, tenancy history and current tenancy, employment history, personal and business phone number, email address and physical address, information on your government-issued ID, date of birth, social insurance number (where you choose to provide it), information about occupants in your unit (includes names and relationship to you), information for your guarantor, emergency contact and references, records evidencing financial means and credit history, automobile information, information about pets, and other information you provide on your rental application or during the application process. We may (i) contact your current and former landlords or property managers to substantiate information you have provided on your application regarding your tenancy history and current tenancy and (ii) conduct a credit check and landlord/tenant court search.
• Setting up your resident profile. If your application is accepted and you choose to rent one or more units from Maddox, we will use information you provided on your rental application to create your resident profile. We use your resident profile to help us administer our relationship and deliver service to you and other occupants in your unit(s), including enabling access to the Maddox App and other building systems. When you register for the Maddox App, much of your information will be pulled directly from your resident profile, though you will be asked to create a password.
• Processing rent and other payments. Depending on your preferred method of making rent and other payments (such as to purchase a key fob or pay for parking), we or a service provider on our behalf will collect payment information from you, such as your payment card or bank account information (e.g., in the form of a void cheque), in order to process your payments.
• Providing you with special services and building improvements. You may choose to provide us with information related to a disability, health concern or other special need, which enables us to make available special services or building improvements to help meet your needs and the needs of other residents and visitors. This information may be shared with emergency services in the event of an evacuation, or as otherwise necessary to ensure your safety.
• Processing a work order. If you submit a work order, we collect the information you provide to us about the work you are requesting and any issues you are having (including any attachments, such as images). We use this information to respond to your work order and address any maintenance and repair issues.
• Reserving amenities. If you reserve an amenity, we collect information related to your reservation, such as the type of amenity, the date and time of the reservation, the number of visitors, the type of event, and any special requests or notes. We use this information to assess the request for compliance with building policies, and to carry out any special requests, where feasible.
• Pre-authorizing visitor access. If you elect to pre-authorize a visitor through the Maddox App, we collect your name and unit number and the information you provide about your visitor, such as their name and anticipated arrival and departure times, to generate a code that you can provide to your visitor for use upon arrival at the property to expedite their entry. Where applicable, we may also collect your visitor’s vehicle information (such as license plate, vehicle make, model and colour) to reserve visitor parking.
• Maintaining the security of our properties and the safety of our residents, staff and visitors. We collect certain personal information to maintain the security of our properties and the safety of our residents, staff and visitors. This includes information about the use of key fobs that have been assigned to residents, contractors and staff, including the serial number of the key fob used to open a door to a common area, the door that was opened, and the date and time the door was opened. In certain common areas at our properties, we also use closed-circuit television (CCTV) cameras. While residents may use a key fob to access their residential unit door(s), we do not collect information about the usage of key fobs to access residential unit doors. Where necessary, such as in the event of an emergency, an incident involving theft, property damage or destruction, or other misuse of property, we may use information collected through key fobs and CCTV, as well as other information, such as information collected about visitors and amenity reservations, to help investigate the incident.
• Maintaining a public resident directory. In each of our properties, we maintain a public directory of residents that is accessible to visitors at the front door. For each resident, our public directory generally lists unit number, first initial and last name; however, residents can request to change the manner in which their name is displayed or remain anonymous. Any adjustments to the way your name is displayed (including remaining anonymous) can be made by contacting the management office.
• Providing you with notifications about the property and the services you request. We may provide you with updates and notifications about the property and the services you request. For example, if you opt in to receive automated parcel notifications, we will send you notification about parcels that are delivered and ready for you to pick up. Likewise, if you make a service request, we may provide you with updates regarding the status of your request and the scheduling of work that needs to be carried out. These notifications may be sent by us or by our service provider on our behalf.

To authorize your access to one of our properties as a visitor.

If you visit one of our properties, we collect certain information from you to authorize your access to the property and maintain the security of our properties and the safety of our residents, staff and other visitors, including:

• Visitor information. If you visit one of our properties, we collect your name, the unit you are visiting and the time of your arrival (and, where pre-authorized by the resident you are visiting, your anticipated departure time). You can gain entry to the building by calling the resident you are visiting or using a preauthorization code provided to you by the resident.
• Video surveillance. In certain common areas in our properties, we use closed-circuit television (CCTV) cameras, the presence of which is identified by appropriate signage. Where necessary, such as in the event of an emergency, an incident involving theft, property damage or destruction, or other misuse of property, we may use information collected through CCTV, as well as other information, such as information collected about visitors and amenity reservations, to investigate the incident.

To engage with you through our Website or apps, including to show you tailored advertising.

See the Digital Technologies on our Website and in our Apps section below for a description of the information we collect about you and your device when you visit our Website or use one of our apps, and how we use it.

To send you marketing communications.

If you indicate that you wish to receive marketing communications from us, we may use your contact information to send you updates, newsletters, offers or other marketing communications that may be of interest to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or, where applicable, by changing your settings in the preferences section of your account with us. Alternatively, you can opt out using the contact information provided under the How to contact us about privacy-related matters section below. Please note that you may continue to receive transactional or account-related communications from us.

To facilitate your involvement in contests and promotions.

If you enter a contest or participate in a promotion, we may collect your name, contact information, and any other information or content required to participate in the contest or promotion. We use this information to facilitate your participation in the contest or promotion. We may obtain your consent to share or otherwise publish the content you submit.

To gather information through surveys or feedback forms.

From time to time, we may offer you the opportunity to participate in one of our surveys or fill in a feedback form regarding our services, an event you attended or other Maddox offerings. If you fill in one of our surveys or feedback forms, we use the information you provide, as applicable, to help us understand our residents’ and prospective residents’ needs, improve our services, future events and offerings, and otherwise understand and address concerns.

To engage with you on social media.    

We may offer you the opportunity to engage with our content on or through social networking websites and applications. If you engage with our content in this way, the social networking website or application will collect information about your engagement for the purposes set out in their privacy policies. We may also collect certain information about you that is made available to us through such websites and applications to engage with you, analyze your interactions with our content and otherwise maintain our social media presence.

To facilitate your attendance at our events.

If you register for or attend one of our events or webinars, we may collect information such as your name and contact information so that we can communicate with you about the event or webinar and contact you about future events or webinars. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email.

To process and respond to job applications.

In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information to process and respond to your application for current and future career opportunities.

To communicate with you, such as to schedule an apartment viewing or provide resident support .

If you contact us, such as to schedule an apartment viewing or, where you are an existing resident, in connection with a work order or other service request, we may collect information that identifies you (such as your name and contact information), along with any information you provide in an enquiry form or in your communications with us. We use this information to respond to your enquiry, comment or request. We may monitor and record our telephone conversations with you for documentation, training, and quality assurance purposes.

To generate anonymous data.

We may modify or aggregate your personal information to generate anonymous data that cannot reasonably be associated with you. We do this to protect your privacy and the security of your information, and to use the anonymous information to conduct research and analytics, identify usage trends, and make improvements to our services, Website and apps.

Other purposes for which you provide your consent.

We may also collect and use other information about you, your device, or your use of our services as described to you at the point of collection or as you otherwise provide your consent.

2.  Sharing of Personal Information

With third parties that provide services on our behalf.

We may transfer personal information to third parties (including affiliates) that provide services on our behalf (“Service Providers”), such as for the purposes of billing and invoicing, processing payments, provision of utilities, tenant insurance management, credit monitoring, fulfilling audit or reporting requirements, cloud storage, property management software and IT support, delivery services, and marketing and advertising. We and our Service Providers may access, store and otherwise process personal information outside of Canada (including, for individuals in Quebec, outside of Quebec), including in the United States or other foreign jurisdictions where we or our Service Providers are located.

With our financial institutions, tax assessors, auditors and other third parties for accounting and audit purposes.         

We share certain personal information, such as rent roll information (which may include name, unit number, lease dates and rental amounts), with our financial institution, tax assessors, affiliates and, where necessary, other third parties for accounting and/or tax assessment purposes. To comply with annual auditing requirements, we also share this information with external auditors.

When required or permitted by law, including as necessary to respond to a legally valid order or to prevent loss or harm.

We and our Canadian, U.S. and other foreign Service Providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process (which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities). Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims, for the purpose of collecting a debt owed to us, or to investigate or prevent actual or suspected loss or harm to persons or property, such as that of Maddox, its affiliates, business partners, personnel, residents or visitors.

In connection with a corporate transaction.

We may disclose personal information we have about you in the event we seek to sell or transfer all or a portion of our business or assets to a third party, such as in connection with a proposed or completed merger, acquisition, sale or other corporate reorganization or change in corporate control (including as part of insolvency or bankruptcy proceedings).

With your consent.

We may also share your information with third parties as described to you at the point of collection or as you otherwise provide your consent.

3. Digital Technologies on our Website and in our Apps

Types of data we may collect when you visit our Website or use one of our apps.

When you visit our Website or use one of our apps, we may collect information about you and your device, including:

• Device information, such as your hardware model, unique device identifier, IP address, operating system version, and language and other settings of the device you are using to access our Website or app. When using an app, this data is required for the app to function on your device.
• Usage information, such as information about the time and duration of your use of our Website or app, what portions of our Website or app you access and how frequently you access them, what links (including advertising) you click when using our Website or app, whether you open the emails we send, what materials (including advertising) you view when using our Website or app, the search terms you use, other information about your interaction with content offered through our Website or app, and any information stored in cookies and similar technologies that we have set on your device (as described below).

Types of digital technologies we may use.

We and third-party companies that provide us with advertising and other digital services may use cookies, web beacons and similar technologies (“digital technologies”) to facilitate administration and navigation of our Website and apps, to better understand and improve our Website, apps and services, to tailor the advertising shown to you on our Website and apps or on third-party websites and digital platforms, to monitor use of our Website and apps to detect, investigate and prevent violations of our terms and conditions, and to provide you with a customized online experience, including by providing you with personalized content and ads that are more relevant to you.

Interest-based advertising practices, including sharing with social media and other platforms. 

Interest-based advertising involves the tailoring of ads you see based on your personal information, including your activity on our Website and apps. We may use third parties to serve advertisements on our Website and apps and on other Websites and digital platforms. These third parties may use digital technologies to collect and use information about your visits to our Website and apps and other websites and digital platforms (including usage information, such as web pages or other content you interact with and your response to ads) to measure the effectiveness of our and our third-party advertiser marketing campaigns, and to deliver ads that are more relevant to you and others, both on and off our Website and apps. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. For example, we may provide a hashed version of your email address, device ID or other information to the platform provider to facilitate the delivery of tailored advertising.

To opt out of having your information used for interest-based advertising purposes, please see the Your choices regarding interest-based advertising and the use of other digital technologies section below.

Information about cookies.

“Cookies” are small files that are placed on your computer or other device when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials, so you do not have to enter those credentials each time you visit our Website or use one of our apps.
• Cookies can help us and third parties understand which parts of our Website and apps are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Website and apps and provide you with a better experience.
• Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you visit our Website or apps.

Most browsers accept cookies automatically but can be configured not to do so. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Your opt-out only applies to the web browser you use, so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. If you disable cookies, it may interfere with the functioning of our Website or apps.

Information about beacons.      

We, along with third parties, may also use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos and emails, and can allow a server to read certain types of information from your device, know when you have viewed certain content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our website and (in conjunction with cookies) to provide content and ads that are more relevant to you both on and off our website.

Analytics

We may use a third party such as Google Analytics to help us gather and analyze data about the areas visited on our Website and our apps (such as the pages most read, features most used, time spent, search terms and other engagement data) to evaluate and improve the user experience and to better understand our users. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link:  https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

•           https://policies.google.com/technologies/partner-sites

•           https://support.google.com/analytics/topic/2919631  

Push notifications.

If you choose to receive push notifications, we may send such notifications to your mobile device to provide you with app updates and other relevant information. If you wish to stop receiving push notifications, you can turn off push notifications for our app either within the app or in the settings of your mobile device.

Do-not-track signals and similar mechanisms.

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Due to differences in how web browsers incorporate and activate this feature, it is not always clear whether visitors intend for these signals to be transmitted, or whether they are even aware of them. Because there is currently no industry standard concerning what, if anything, websites should do when they receive such signals, our Website currently does not act in response to these signals. If a final standard is established and accepted, we will reassess how to respond to these signals.

Other digital technologies

We, along with third parties, may use other kinds of technologies in connection with our Website and our apps. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.

4. Your Choices and Privacy Rights

Your choices regarding interest-based advertising and the use of other digital technologies.

For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. 

Please note that even if you opt out of interest-based advertising, tracking technologies may still collect data for other purposes, including analytics, and you may still see ads from us, but the ads will not be interest-based ads.

You may also block digital technologies in your browser or device settings as and if permitted by your device. In some circumstances, disabling these features may interfere with your ability to access certain functionalities on our Website or in our apps.

Marketing communications preferences.

As set out under the To send you marketing communications section above, you can opt out of receiving marketing communications from us any time by clicking the “unsubscribe” link included at the bottom of each email or, where applicable, by changing your settings in the preferences section of your account with us. Alternatively, you can opt out using the contact information provided under the How to contact us about privacy-related matters section below. Please note that you may continue to receive transactional or account-related communications from us.

Exercising your privacy rights.

Subject to applicable law, you may have the right to access, update, correct inaccuracies in, and withdraw consent to the processing of, your personal information in our custody or control. You may make such a request or withdraw consent by writing to us using the contact information provided under the How to contact us about privacy-related matters section below. We may request certain personal information for the purposes of verifying your identity.

To opt out of interest-based advertising, see the Your choices regarding interest-based advertising and the use of other digital technologies section above.

5. Data Governance, Security and Retention Practices

Data governance, security and retention practices.

Maddox has implemented administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against loss, theft and unauthorized access, use, modification and disclosure. These measures include a framework setting out the roles and responsibilities of our personnel with respect to the handling of personal information, as well as controls intended to limit access to personal information on a need-to-know basis to employees and authorized Service Providers who require access to fulfil their job requirements.

Our record retention and destruction processes are designed to retain personal information for no longer than necessary for the purposes set out in this Privacy Policy or as otherwise required to meet legal or business requirements.

We also have procedures in place for responding to questions, requests and complaints regarding our handling of personal information. You can reach out to us at any time using the contact information under the How to contact us about privacy-related matters section below.

6. Other Important Information

Links to third-party sites.

Our Website and apps may contain links to third-party websites and applications that we do not operate and are outside of our control. These links are not intended as an endorsement of or referral to the linked websites or applications. The linked websites and applications have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites and applications, and we have no responsibility or liability for the manner in which the organizations that operate such websites and applications may collect, use, disclose and otherwise treat personal information. We encourage you to read the privacy policy of every website and application you visit or use.

Updates to this Privacy Policy.

We may update this Privacy Policy from time to time to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated and, depending on the nature of the update, provide you with additional notice outside of this Privacy Policy.

How to contact us about privacy-related matters.   If you have any questions, comments or complaints about this Privacy Policy or the manner in which we or our Service Providers (including our Service Providers outside of Canada) treat your personal information, please contact our VP Legal and General Counsel (privacy@maddox.ca), who oversees Maddox’s privacy management program.

Maddox Tyndall Privacy Policy

Effective as of April 17, 2025

Maddox Tyndall Inc. and ONTARI Holdings Ltd. (“Maddox”, “us”, “we”, or “our”) values and respects your privacy. We have prepared this Privacy Policy to describe the manner in which we collect, use, disclose and otherwise process personal information when you visit our website located at https://www.maddox.ca/ (the “Website”), apply to become and/or become a resident at a Maddox property, visit a Maddox property, use Maddox property services, use one of our mobile applications, such as the Maddox app (the “Maddox App”), or otherwise interact with us.

Table of Contents

1.          Collection and Use of Personal Information

2.         Sharing of Personal Information

3.         Digital Technologies on our Website and in our Apps

4.         Your Choices and Privacy Rights

5.         Data Governance, Security and Retention Practices

6.         Other Important Information

1. Collection and Use of Personal Information

How we collect and use personal information As described in more detail below, depending on the ways in which you interact with us, we may collect and use your personal information to:

• Establish and maintain a tenancy relationship with you and provide you with property management services
• Authorize your access to one of our properties as a visitor
• Engage with you through our Website or apps, including to show you tailored advertising
• Send you marketing communications
• Facilitate your involvement in contests and promotions
• Gather information through surveys or feedback forms
• Engage with you on social media
• Facilitate your attendance at our events
• Process and respond to job applications
• Communicate with you, such as to schedule an appointment viewing or provide resident support
• Generate anonymous data
• Otherwise process your personal information with your consent

To establish and maintain a tenancy relationship with you and provide you with property management services.     

If you are a resident, or apply to become a resident, of one of our properties, we collect personal information to establish and maintain our tenancy relationship with you and provide you with property management services, including:

• Processing your rental application. We collect the personal information you provide when you complete a rental application (either directly with us or through a third-party platform) to process your application and assess your suitability as a resident. This may include your full name, tenancy history and current tenancy, employment history, personal and business phone number, email address and physical address, information on your government-issued ID, date of birth, social insurance number (where you choose to provide it), information about occupants in your unit (includes names and relationship to you), information for your guarantor, emergency contact and references, records evidencing financial means and credit history, automobile information, information about pets, and other information you provide on your rental application or during the application process. We may (i) contact your current and former landlords or property managers to substantiate information you have provided on your application regarding your tenancy history and current tenancy and (ii) conduct a credit check and landlord/tenant court search.
• Setting up your resident profile. If your application is accepted and you choose to rent one or more units from Maddox, we will use information you provided on your rental application to create your resident profile. We use your resident profile to help us administer our relationship and deliver service to you and other occupants in your unit(s), including enabling access to the Maddox App and other building systems. When you register for the Maddox App, much of your information will be pulled directly from your resident profile, though you will be asked to create a password.
•  Processing rent and other payments. Depending on your preferred method of making rent and other payments (such as to purchase a key fob or pay for parking), we or a service provider on our behalf will collect payment information from you, such as your payment card or bank account information (e.g., in the form of a void cheque), in order to process your payments.
•  Providing you with special services and building improvements. You may choose to provide us with information related to a disability, health concern or other special need, which enables us to make available special services or building improvements to help meet your needs and the needs of other residents and visitors. This information may be shared with emergency services in the event of an evacuation, or as otherwise necessary to ensure your safety.
• Processing a work order. If you submit a work order, we collect the information you provide to us about the work you are requesting and any issues you are having (including any attachments, such as images). We use this information to respond to your work order and address any maintenance and repair issues.
• Reserving amenities. If you reserve an amenity, we collect information related to your reservation, such as the type of amenity, the date and time of the reservation, the number of visitors, the type of event, and any special requests or notes. We use this information to assess the request for compliance with building policies, and to carry out any special requests, where feasible.
• Pre-authorizing visitor access. If you elect to pre-authorize a visitor through the Maddox App, we collect your name and unit number and the information you provide about your visitor, such as their name and anticipated arrival and departure times, to generate a code that you can provide to your visitor for use upon arrival at the property to expedite their entry. Where applicable, we may also collect your visitor’s vehicle information (such as license plate, vehicle make, model and colour) to reserve visitor parking.
• Maintaining the security of our properties and the safety of our residents, staff and visitors. We collect certain personal information to maintain the security of our properties and the safety of our residents, staff and visitors. This includes information about the use of key fobs that have been assigned to residents, contractors and staff, including the serial number of the key fob used to open a door to a common area, the door that was opened, and the date and time the door was opened. In certain common areas at our properties, we also use closed-circuit television (CCTV) cameras. While residents may use a key fob to access their residential unit door(s), we do not collect information about the usage of key fobs to access residential unit doors. Where necessary, such as in the event of an emergency, an incident involving theft, property damage or destruction, or other misuse of property, we may use information collected through key fobs and CCTV, as well as other information, such as information collected about visitors and amenity reservations, to help investigate the incident.
• Maintaining a public resident directory. In each of our properties, we maintain a public directory of residents that is accessible to visitors at the front door. For each resident, our public directory generally lists unit number, first initial and last name; however, residents can request to change the manner in which their name is displayed or remain anonymous. Any adjustments to the way your name is displayed (including remaining anonymous) can be made by contacting the management office.
• Providing you with notifications about the property and the services you request. We may provide you with updates and notifications about the property and the services you request. For example, if you opt in to receive automated parcel notifications, we will send you notification about parcels that are delivered and ready for you to pick up. Likewise, if you make a service request, we may provide you with updates regarding the status of your request and the scheduling of work that needs to be carried out. These notifications may be sent by us or by our service provider on our behalf.

To authorize your access to one of our properties as a visitor

If you visit one of our properties, we collect certain information from you to authorize your access to the property and maintain the security of our properties and the safety of our residents, staff and other visitors, including:

• Visitor information. If you visit one of our properties, we collect your name, the unit you are visiting and the time of your arrival (and, where pre-authorized by the resident you are visiting, your anticipated departure time). You can gain entry to the building by calling the resident you are visiting or using a preauthorization code provided to you by the resident.
• Video surveillance. In certain common areas in our properties, we use closed-circuit television (CCTV) cameras, the presence of which is identified by appropriate signage. Where necessary, such as in the event of an emergency, an incident involving theft, property damage or destruction, or other misuse of property, we may use information collected through CCTV, as well as other information, such as information collected about visitors and amenity reservations, to investigate the incident.

To engage with you through our Website or apps, including to show you tailored advertising.

See the Digital Technologies on our Website and in our Apps section below for a description of the information we collect about you and your device when you visit our Website or use one of our apps, and how we use it.

To send you marketing communications.

If you indicate that you wish to receive marketing communications from us, we may use your contact information to send you updates, newsletters, offers or other marketing communications that may be of interest to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or, where applicable, by changing your settings in the preferences section of your account with us. Alternatively, you can opt out using the contact information provided under the How to contact us about privacy-related matters section below. Please note that you may continue to receive transactional or account-related communications from us.

To facilitate your involvement in contests and promotions. 

If you enter a contest or participate in a promotion, we may collect your name, contact information, and any other information or content required to participate in the contest or promotion. We use this information to facilitate your participation in the contest or promotion. We may obtain your consent to share or otherwise publish the content you submit.

To gather information through surveys or feedback forms.

  From time to time, we may offer you the opportunity to participate in one of our surveys or fill in a feedback form regarding our services, an event you attended or other Maddox offerings. If you fill in one of our surveys or feedback forms, we use the information you provide, as applicable, to help us understand our residents’ and prospective residents’ needs, improve our services, future events and offerings, and otherwise understand and address concerns.

To engage with you on social media. 

We may offer you the opportunity to engage with our content on or through social networking websites and applications. If you engage with our content in this way, the social networking website or application will collect information about your engagement for the purposes set out in their privacy policies. We may also collect certain information about you that is made available to us through such websites and applications to engage with you, analyze your interactions with our content and otherwise maintain our social media presence.

To facilitate your attendance at our events.     

If you register for or attend one of our events or webinars, we may collect information such as your name and contact information so that we can communicate with you about the event or webinar and contact you about future events or webinars. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email.

To process and respond to job applications.   

In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information to process and respond to your application for current and future career opportunities.

To communicate with you, such as to schedule an apartment viewing or provide resident support.      

If you contact us, such as to schedule an apartment viewing or, where you are an existing resident, in connection with a work order or other service request, we may collect information that identifies you (such as your name and contact information), along with any information you provide in an enquiry form or in your communications with us. We use this information to respond to your enquiry, comment or request. We may monitor and record our telephone conversations with you for documentation, training, and quality assurance purposes.

To generate anonymous data.    

We may modify or aggregate your personal information to generate anonymous data that cannot reasonably be associated with you. We do this to protect your privacy and the security of your information, and to use the anonymous information to conduct research and analytics, identify usage trends, and make improvements to our services, Website and apps.

Other purposes for which you provide your consent. 

We may also collect and use other information about you, your device, or your use of our services as described to you at the point of collection or as you otherwise provide your consent.

2. Sharing of Personal Information

With third parties that provide services on our behalf.           

We may transfer personal information to third parties (including affiliates) that provide services on our behalf (“Service Providers”), such as for the purposes of billing and invoicing, processing payments, provision of utilities, tenant insurance management, credit monitoring, fulfilling audit or reporting requirements, cloud storage, property management software and IT support, delivery services, and marketing and advertising. We and our Service Providers may access, store and otherwise process personal information outside of Canada (including, for individuals in Quebec, outside of Quebec), including in the United States or other foreign jurisdictions where we or our Service Providers are located.

With our financial institutions, tax assessors, auditors and other third parties for accounting and audit purposes.       

We share certain personal information, such as rent roll information (which may include name, unit number, lease dates and rental amounts), with our financial institution, tax assessors, affiliates and, where necessary, other third parties for accounting and/or tax assessment purposes. To comply with annual auditing requirements, we also share this information with external auditors.

When required or permitted by law, including as necessary to respond to a legally valid order or to prevent loss or harm.    

We and our Canadian, U.S. and other foreign Service Providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process (which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities). Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims, for the purpose of collecting a debt owed to us, or to investigate or prevent actual or suspected loss or harm to persons or property, such as that of Maddox, its affiliates, business partners, personnel, residents or visitors.

In connection with a corporate transaction.

We may disclose personal information we have about you in the event we seek to sell or transfer all or a portion of our business or assets to a third party, such as in connection with a proposed or completed merger, acquisition, sale or other corporate reorganization or change in corporate control (including as part of insolvency or bankruptcy proceedings).

With your consent.  

We may also share your information with third parties as described to you at the point of collection or as you otherwise provide your consent.

3. Digital Technologies on our Website and in our Apps

Types of data we may collect when you visit our Website or use one of our apps. 

When you visit our Website or use one of our apps, we may collect information about you and your device, including:

• Device information, such as your hardware model, unique device identifier, IP address, operating system version, and language and other settings of the device you are using to access our Website or app. When using an app, this data is required for the app to function on your device.
• Usage information, such as information about the time and duration of your use of our Website or app, what portions of our Website or app you access and how frequently you access them, what links (including advertising) you click when using our Website or app, whether you open the emails we send, what materials (including advertising) you view when using our Website or app, the search terms you use, other information about your interaction with content offered through our Website or app, and any information stored in cookies and similar technologies that we have set on your device (as described below).

Types of digital technologies we may use.       

We and third-party companies that provide us with advertising and other digital services may use cookies, web beacons and similar technologies (“digital technologies”) to facilitate administration and navigation of our Website and apps, to better understand and improve our Website, apps and services, to tailor the advertising shown to you on our Website and apps or on third-party websites and digital platforms, to monitor use of our Website and apps to detect, investigate and prevent violations of our terms and conditions, and to provide you with a customized online experience, including by providing you with personalized content and ads that are more relevant to you.

Interest-based advertising practices, including sharing with social media and other platforms.             

Interest-based advertising involves the tailoring of ads you see based on your personal information, including your activity on our Website and apps. We may use third parties to serve advertisements on our Website and apps and on other Websites and digital platforms. These third parties may use digital technologies to collect and use information about your visits to our Website and apps and other websites and digital platforms (including usage information, such as web pages or other content you interact with and your response to ads) to measure the effectiveness of our and our third-party advertiser marketing campaigns, and to deliver ads that are more relevant to you and others, both on and off our Website and apps. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. For example, we may provide a hashed version of your email address, device ID or other information to the platform provider to facilitate the delivery of tailored advertising.

To opt out of having your information used for interest-based advertising purposes, please see the Your choices regarding interest-based advertising and the use of other digital technologies section below.

Information about cookies.           

“Cookies” are small files that are placed on your computer or other device when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials, so you do not have to enter those credentials each time you visit our Website or use one of our apps.
• Cookies can help us and third parties understand which parts of our Website and apps are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Website and apps and provide you with a better experience.
• Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you visit our Website or apps.

Most browsers accept cookies automatically but can be configured not to do so. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Your opt-out only applies to the web browser you use, so you must opt out of each web browser on each device you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt out again. If you disable cookies, it may interfere with the functioning of our Website or apps.

Information about beacons.

We, along with third parties, may also use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos and emails, and can allow a server to read certain types of information from your device, know when you have viewed certain content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our website and (in conjunction with cookies) to provide content and ads that are more relevant to you both on and off our website.

Analytics

We may use a third party such as Google Analytics to help us gather and analyze data about the areas visited on our Website and our apps (such as the pages most read, features most used, time spent, search terms and other engagement data) to evaluate and improve the user experience and to better understand our users. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link:  https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

•           https://policies.google.com/technologies/partner-sites 

•           https://support.google.com/analytics/topic/2919631

Push notifications.

If you choose to receive push notifications, we may send such notifications to your mobile device to provide you with app updates and other relevant information. If you wish to stop receiving push notifications, you can turn off push notifications for our app either within the app or in the settings of your mobile device.

Do-not-track signals and similar mechanisms.         

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Due to differences in how web browsers incorporate and activate this feature, it is not always clear whether visitors intend for these signals to be transmitted, or whether they are even aware of them. Because there is currently no industry standard concerning what, if anything, websites should do when they receive such signals, our Website currently does not act in response to these signals. If a final standard is established and accepted, we will reassess how to respond to these signals.

Other digital technologies.

We, along with third parties, may use other kinds of technologies in connection with our Website and our apps. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.

4. Your Choices and Privacy Rights

Your choices regarding interest-based advertising and the use of other digital technologies For more information about interest-based advertising and to understand your options, including how you can opt out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. 

Please note that even if you opt out of interest-based advertising, tracking technologies may still collect data for other purposes, including analytics, and you may still see ads from us, but the ads will not be interest-based ads.

You may also block digital technologies in your browser or device settings as and if permitted by your device. In some circumstances, disabling these features may interfere with your ability to access certain functionalities on our Website or in our apps.

Marketing communications preferences.         

As set out under the To send you marketing communications section above, you can opt out of receiving marketing communications from us any time by clicking the “unsubscribe” link included at the bottom of each email or, where applicable, by changing your settings in the preferences section of your account with us. Alternatively, you can opt out using the contact information provided under the How to contact us about privacy-related matters section below. Please note that you may continue to receive transactional or account-related communications from us.

Exercising your privacy rights.     

Subject to applicable law, you may have the right to access, update, correct inaccuracies in, and withdraw consent to the processing of, your personal information in our custody or control. You may make such a request or withdraw consent by writing to us using the contact information provided under the How to contact us about privacy-related matters section below. We may request certain personal information for the purposes of verifying your identity.

To opt out of interest-based advertising, see the Your choices regarding interest-based advertising and the use of other digital technologies section above.

5. Data Governance, Security and Retention Practices

Data governance, security and retention practices.  

Maddox has implemented administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against loss, theft and unauthorized access, use, modification and disclosure. These measures include a framework setting out the roles and responsibilities of our personnel with respect to the handling of personal information, as well as controls intended to limit access to personal information on a need-to-know basis to employees and authorized Service Providers who require access to fulfil their job requirements.

Our record retention and destruction processes are designed to retain personal information for no longer than necessary for the purposes set out in this Privacy Policy or as otherwise required to meet legal or business requirements.

We also have procedures in place for responding to questions, requests and complaints regarding our handling of personal information. You can reach out to us at any time using the contact information under the How to contact us about privacy-related matters section below.

6. Other Important Information

Links to third-party sites   

Our Website and apps may contain links to third-party websites and applications that we do not operate and are outside of our control. These links are not intended as an endorsement of or referral to the linked websites or applications. The linked websites and applications have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites and applications, and we have no responsibility or liability for the manner in which the organizations that operate such websites and applications may collect, use, disclose and otherwise treat personal information. We encourage you to read the privacy policy of every website and application you visit or use.

Updates to this Privacy Policy.      

We may update this Privacy Policy from time to time to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated and, depending on the nature of the update, provide you with additional notice outside of this Privacy Policy.

How to contact us about privacy-related matters.     

If you have any questions, comments or complaints about this Privacy Policy or the manner in which we or our Service Providers (including our Service Providers outside of Canada) treat your personal information, please contact our VP Legal and General Counsel (privacy@maddox.ca), who oversees Maddox’s privacy management program.