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Privacy

Starlight Group Property Holdings Inc. (“Starlight”, we”, us” or our”) is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable laws.

This Privacy Policy describes how we collect, use, disclose and protect personal information of our individual tenants, customers, website visitors and other individuals we deal with.

This Privacy Policy does not apply to personal information relating to Starlight employees, officers or directors, or to information that is not personal information.

Starlight’s objective is to ensure responsible practices in the collection, use and disclosure of personal information, in accordance with applicable legislation.

Personal Information We Collect

We and our agents and representatives collect personal information in a number of circumstances in the course of operating our business. The personal information we collect includes:

Name, gender, age, address, family status and contact information including telephone number(s) and email address.
Banking and other financial information.
Social insurance number and other identification numbers.
Employment information (past and present).
Information we collect in order to assess your financial situation, such as information about your employment, income, assets and credit history. We may collect this information from third parties, such as your employer, a financial institution or a credit reporting agency.
Information we collect from references, including previous landlords.
Information collected through the use of video surveillance systems, which may be installed in the common areas of our buildings or properties.

How We Use Personal Information

We use personal information to:

Evaluate and process your lease application, including assessing your ability to meet your payment obligations under a lease agreement.
Manage our relationship with you including processing payments, collecting amounts owing to us, enforcing your obligations and communicating about matters relating to our buildings.
Respond to your requests and inquiries.
Communicate with you on ongoing continuous basis regarding investments you have made.
Ensure the safety, security and appropriate use of our buildings and properties.

Disclosure of Your Personal Information

We may share personal information with a co-tenant or guarantor or to any third party payor of your obligations if required under your tenancy agreement or related housing agreement.

We may disclose your contact information to one or more providers of a security alarm system, cable television, telephone, telecommunication, hydro-electricity, water/​hot water, gas and/​or other similar or related service so that they may contact you for the provision of such services.

We may also share personal information with our affiliates (including outside of Canada) for audit, management, legal, billing, strategy or administrative purposes including defending and bringing legal actions.

We transfer personal information to service providers (including affiliates acting in this capacity) that perform services on our behalf, such as, but not limited to, data hosting and processing, website development, analytics, billing, leasing or similar services. Some of these service providers may be located outside of Canada, including in the United States, and your personal information may be processed outside of Canada for the purposes described herein. While outside of Canada, personal information will be subject to foreign laws, which may permit third parties including government and national security agencies to access personal information in certain circumstances.

We may use and disclose personal information in connection with the proposed or actual insuring, financing, securitization, sale, assignment or other transaction of all or part of Starlight or our business or assets (including a lease agreement), for the purposes of evaluating and/​or performing the proposed transaction. Assignees or successors of Starlight or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

We may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law.

Our Website

We use automatic data collection technologies, such as cookies and similar tracking technologies, to track usage patterns on our website. Each time you visit our website, our server records your Internet service provider, IP address, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URL’s you came from. We use this information to optimize our website service. You may be able to set your browser to block or delete cookies, or to notify you before a cookie is set. However, if you block cookies you may not be able to use all of the features of our website.

Your Choices

Starlight generally collects, uses and discloses personal information with your consent, except as permitted or required by law. Consent to the collection, use or disclosure of personal information may be given in various ways, including expressly on a form you may sign or implicitly, when you provide information necessary for a service you have requested. Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes described in this Privacy Policy or otherwise at the time of collection.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. If you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to provide our services.

Security

Personal information is maintained at our offices or on our servers or those of our agents or service providers. We take reasonable steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which may include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents and mandataries of Starlight who require access to your personal information in order to fulfil their job requirements will have access to your personal information.

Cookies

We may also use cookies to enable us to collect data and enhance your experience on our website. Cookies are stored on your hard drive to track and collect information as you interact with our website, and to personalize your experience. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.
You may refuse to accept browser cookies by activating the appropriate setting on your browser. If you do so, note that some parts of the website may not function properly or optimally.


Privacy Policy Changes
This Privacy Policy is effective as of the Effective Date above. We may revise this Privacy Policy from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this policy, we will make reasonable efforts to notify you including by posting the revised Privacy Policy on our website. We recommend that you review this Privacy Policy frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.

Contact Us

For more information about Starlight’s privacy practices, to amend or obtain access to your personal information, to opt-out or withdraw your consent, or if you have privacy-related questions or concerns, please contact:

Chief Legal Officer c/​o Starlight Group Property Holdings Inc.
3280 Bloor Street West
Suite 1400, Centre Tower
Toronto, ON M8X 2X3
Telephone: 416−234−8444
Email:info@starlightinvest.com