Privacy Policy

Effective Date: February 1, 2020

CONNECT asset management Corp., (“CAM”) recognizes the importance of privacy and the sensitivity of personal information that we collect, use and disclose in providing our Services. We are committed to protecting any personal information we hold. This Privacy Policy outlines the types of personal information we collect about you, how we manage your personal information, and the steps we take to safeguard your privacy.

CAM is responsible for the personal information we collect and hold. To ensure this accountability, we have developed policies and procedures with the objective of protecting personal information, and have trained our lawyers and support staff about our privacy practices.

Definitions

‘Personal information’ or ‘Personal Data’ includes any information that can be directly or indirectly linked to a specific individual.

‘Service’ or ‘Services’ include but are not limited to, resources provided on www.connect.ca (“Website” or “Site”), such as communication forums and product information, in addition to any other services that CAM would provide you via the use of the Website or any other medium, or as otherwise explained below in this Privacy Policy.

‘You’ or ‘your’ refers to the reader, CAM’s client, and any other individual accessing the CAM Website.

How your information is used

CAM collects, uses and discloses personal information in the course of providing services to our clients. Specifically, these purposes include, but are not limited to,:

• to communicate with you either by email and/or telephone and text message (when provided), about products, services or events to which you have registered for,
• to manage our client relationships, including performing conflict checks and credit checks, if necessary, on prospective clients,
• to provide real estate services in the course of business transactions, where the personal information is disclosed to other parties involved in the transfer/mortgage/sale/lease etc.,
• to evaluate client satisfaction through communication with clients and other individuals,
• to comply with legal requirements which mandate the release of personal information to maintain our document system, precedent files, and memorandum bank to protect our clients by checking for internal error and/or theft as needed or as required,
• to issue reminders and update notices about ‘in person’ events you have registered for or RSVP’d for or otherwise, of which we are holding a reservation on your behalf,
• to allow you to utilize certain services available on our Website when you choose to do so,
• to analyze the information so that we can monitor the usage and continuously improve our services, and;
• where applicable, to distribute direct marketing materials concerning our services, developments in the industry, and other company matters.
• data will not be shared with third parties for marketing or promotional purposes.

Types of Information Collected and Used 

When using this Website or receiving CAM’s services, the information that is typically collected includes:

• contact information/identifiers about yourself including but not limited to your name, email address, mailing address, phone number and other personally identifiable information,
• financial information including but not limited to your source of capital, experience and expectations, risk tolerance, and where applicable, warranties and representations regarding your financial resources, and;
• any other information that is necessary in relation to the services we provide to you.

CAM may collect and store information about your location should you provide the permission to do so. This data is used to improve and customize our services to better your experience while using this Website and our services. You may, at any time, enable or disable location services through your device settings.

On our Website, we may monitor traffic patterns, site usage and related site information. This is done in order to optimize our web services. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

You are free to visit our Website without providing us with any Personal Information about yourself. Failing to provide CAM with Personal Information may cause an inability to receive some of our services, such as submitting and maintaining an account. CAM takes necessary steps to ensure the accuracy of the information being held about you. Should there be any changes to your personal information, or should you have been made aware that the information we currently hold on you is inaccurate, we require that you notify us so that we may update your information to be complete and up-to-date.

This Website is not intended for and does not target individuals under 18 years of age. CAM does not knowingly or intentionally collect Personal Information about individuals under 18. If you are a parent or guardian and have been made aware that we have collected Personal Information from your child, please contact us. Personal Information collected on individuals under 18 without parental consent will be removed from our servers.

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Primarily, we collect your personal information directly from you. This personal information may be collected when you complete an account application or provide us with additional forms during the course of your relationship with us.

Processing Personal Data under the General Data Protection Regulation (GDPR) 

Individuals located in the European Economic Area (EEA) have additional rights regarding the processing of their personal data. These rights include (as defined by the GDPR):

• the right to be informed,
• the right of access,
• the right to rectification,
• the right to erasure,
• the right to restrict processing,
• the right to data portability,
• the right to object, and;
• rights in relation to automated decision making and profiling.

Our legal basis for collecting and using you personal data will depend on the data concerned and the specific context in which it was collected. CAM normally processes your personal data for any of the following reasons:

• we have received your consent,
• it is required to perform a contract with you,
• the processing of the personal data is in our legitimate interests and not overridden by your data protection rights, or;
• to comply with a legal obligation.

Should you have any questions or wish to submit a request regarding your personal data, you may contact our Data Protection Officer through admin@connect.ca. Upon submitting your request to exercise your rights under the GDPR, CAM may request additional information from you in order to verify your identity prior to fulfilling your request. Be advised that CAM allows you to unsubsubscribe from the receipt of promotional content at any time.

You have the right to contact your local data protection authority in the EEA should you have a complaint relating to the collection and use of your personal data.

Processing Personal Information under the California Consumer Privacy Act (CCPA) 

California Residents have additional rights available to them under the CCPA in relation to the personal information collected, used and disclosed by CAM, these rights include (as defined by the CCPA):

• the right to be notified of the personal information being collected,
• the right to access personal information being stored,
• the right to opt-out of the sale of personal information,
• the right to request deletion of personal information, and;
• the right to equal services and prices

If you have any questions or would like to request access or deletion of your personal information, please reach out to admin@connect.ca or forward a written letter to the mailing address listed under ‘Contact Us’ in this Privacy Policy.

Cookie Policy

CAM uses cookies and similar technologies to collect certain aggregate and non-personal information about you. When you visit our Website, small text files may be placed on your web browser, your browser remembers specific information to be retrieved and used at a later date. Some of these cookies are transferred to your hard drive for record keeping purposes. CAM may use this information towards improving and updating this Website and to better provide you with our services. 

CAM uses cookies to improve certain aspects of your experience with this Website, such as:

• improving the security of this Site by verifying you upon sign-in,
• personalizing the content we show you, including ads, emails, and landing pages,
• keeping track of your selected preferences (i.e., time zone and language), and;
• any other purposes as described in this Privacy Policy

Advertisements placed on CAM’s Website may use cookies. CAM does not control these advertisers’ use of these cookies and are not covered under this Privacy Policy

You may disable the receipt of cookies on your computer by adjusting the cookies setting, however, some of our services may not function properly if you disable cookies.

Service Providers

CAM may utilize third-party companies and individuals (Service Providers) to better facilitate our services to you, or assist us in analyzing how our services are being used. Such Service Providers are only permitted to use your personal information for the purposes of performing such tasks.

CAM utilizes Hubspot to manage and store its client’s personal information and is operating in compliance with Hubspot’s Privacy Policy. For more information on Hubspot’s privacy practices go to https://legal.hubspot.com/privacy-policy.

This Website uses Google Analytics, a web and mobile analytics tracking tool provided by Google, for audience activity, demographics reporting and remarketing. This allows us to collect information about how our Website is used. Each time you visit this Website our web server collects non-personal information about you such as the domain name or IP address. You can opt-out of Google Analytics by installing a browser plug-in available on Google’s website. 

This Website is integrated with Facebook, Instagram, LinkedIn, and Google Ads to advertise to you on third party websites once you have visited our Site or used our services. By the use of cookies, CAM and its Service Providers will serve you based on your previous CAM Website visits or use of our services.

For more information on the privacy practices for these Service Providers, visit:

• Facebook/Instagram: https://www.facebook.com/privacy/explanation
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Google: https://policies.google.com/privacy?hl=en 

Consent 

In most cases, we shall ask you to specifically consent if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your use of our services, your expectations for CAM to provide you with specific services, and your overall conduct with us.

Transfer of Information

CAM operates internationally, and therefore, may be required to transfer the information collected about you across international borders. This includes transfers from the EEA, UK or USA to Canada for processing and storage. By consenting to this Privacy Policy along with you providing CAM with such information represents your consent to the transfer of information.

Record Retention

CAM retains your information for no longer than necessary to fulfill the purposes as described in this Privacy Policy, unless a longer record retention period is required/permitted as per applicable laws and regulations. You can contact us directly for more information relating to our data protection practices using the contact information under ‘Contact Us’ in this Privacy Policy.

Disclosure of your Personal Information 

CAM does not disclose or sell your personal information to any third-party to enable them to market their products and services. CAM will disclose your personal information:

• when we are required or authorized by law to do so, for example if a court issues a subpoena; when you have consented to the disclosure,
• where it is necessary to establish or collect fees,
• if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our Privacy Policy,
• if the information is already publicly known, or;
• where CAM is involved in a merger, acquisition or asset sale (notice will be provided before you information is transferred and is subject to a different privacy policy).
• when the real estate services we are providing to you require us to give your information to third parties to fulfill the services, your consent will be implied, unless you previously revoked such consent.

Updating Your Information 

CAM takes necessary steps to ensure the accuracy of the information being held about you. Should there be any changes to your personal information, or should you have been made aware that the information we currently hold on you is inaccurate, we require that you notify us so that we may update your information to be complete and up-to-date.

Securing your Information 

CAM takes reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information include:

• premises security,
• restricted access to files that contain personal information,
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access, and;
• internal password and security policies.

Credit Bureaus

To help us make credit decisions about clients and to prevent fraud, check the identity of new clients, and prevent money-laundering, we may, on occasion, request information about you from the files of consumer reporting agencies.

Third Party Sites 

Our Website and services may contain third-party links that direct you to other sites not operated by us. CAM shall not assume any responsibility nor have control over the privacy policies or practices of any third-party sites or services. Links to third-party sites are not governed by this Privacy Policy.

Changes to this Policy 

CAM may update this policy from time to time. The most updated version of this policy will be posted on our Website at www.connect.ca/privacy-policy/. This policy is effective as of the effective date listed above. It is in your best interest to periodically review this Privacy Policy to be advised of any changes.

Communicating with Us 

Be advised that the transmission of information over the internet is not a 100% secure medium. You should be aware of this when contacting us to send personal or confidential information.

Employment Inquiries 

If you are considering an application for employment with us, we need to consider your personal information as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.

Email Communications

To unsubscribe from CAM’’s marketing emails, click on the unsubscribe link in the footer of any message that you have received or contact us here at admin@connect.ca

Access to Your Personal Information 

CAM offers you a general right to access the personal information we have about you in our records. You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees. To exercise this right, forward a written request to the address listed under ‘Requests for Access’ in this Privacy Policy.

Your rights to access your personal information are not absolute. We may deny access when:

• denial of access is required or authorized by law,
• information relates to existing or anticipated legal proceedings against you granting you access would have an unreasonable impact on other people’s privacy,
• protecting our company’s rights and property, or;
• the request is frivolous or vexatious.

If we deny your request for access to your personal information, or refuse a request to correct information, we shall respond to your request with an explanation of the denial. CAM does not use your Social Insurance Number as a way of identifying or organizing the information we hold about you.

Requests for Access

If you have any questions or wish to access your personal information, please write to our Privacy Contact:

Privacy Officer,

CONNECT asset management Corp.,

c/o The Condo Store Realty Inc.,

Liberty Market Building, 171 East Liberty Street, Suite 101

Toronto, Ontario M6K 3P6.

admin@connect.ca

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street, Place du Ville Tower, 3rd Floor

Ottawa, Ontario K1A 1H3 

1.800.282.1376

Contact Us 

If you have any questions about this Privacy Policy, please contact us:

• By email: admin@connect.ca
• By mail: Liberty Market Building - 171 East Liberty Street, Suite 101, Toronto, Ontario M6K 3P6

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