VALIANT RENTAL PROPERTIES LIMITED PRIVACY POLICY
FOR THE COLLECTION, USE, DISCLOSURE AND SECURITY
OF PERSONAL INFORMATION

Valiant has been building and servicing its customers since 1992, as one of the largest property management companies in the Durham Region. Valiant offers rental services for its residential, commercial and self-storage rental properties (hereinafter called “Clients”).

Valiant has long been committed to maintaining the accuracy, confidentiality, security
and privacy of client and employee personal information. This is reflected in our privacy and
confidentiality provisions found in various policies.

Privacy of personal information about clients or prospective clients of the properties we manage is a fundamental cornerstone of our role as property managers and landlords. We understand an individual’s right to privacy and we are committed to collecting, using, disclosing and securing your personal information responsibly and for no other purposes beyond the need to efficiently and effectively provide property management services to our Clients.

What is Personal Information?

“Personal Information” means information that is personally identifiable to individuals. This may include, without limitation, the Individual’s name, address, telephone number, e-mail address, social insurance number, employment status, income, credit history, past tenancy history, bank account number(s), co-occupant information (name, date of birth, relationship to prospective tenant), vehicle information including license plate number, intended use of premises, any special needs of Clients, and other information about the client or the client’s family.

This Privacy Policy is based on, and complies with, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), which includes the Ten Privacy Principles outlined in the National Standard of Canada entitled Model Code for the Protection of Personal Information and similar provincial legislation.

This Privacy Policy sets out the ten principles that Valiant follows to ensure that we protect our Client and employee personal information when we collect, use or disclose it in the course of carrying on business activities in Canada. These correspond to similar principles contained in PIPEDA. All of our employees who have access to personal information must adhere to the Valiant Privacy Policy, Non-Disclosure/Confidentiality Agreement and related procedures.

Accountability

Valiant is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our Clients, prospective Clients or others. Through its policies and procedures, Valiant will strive to implement this Privacy Policy throughout all of its operations.

Valiant will seek to include in contractual arrangements with suppliers, consultants, or any other third party contractor provisions requiring them to provide an appropriate level of protection for information transferred to them by Valiant.

Identifying Purposes For The Collection of Personal Information

Valiant will identify the purposes for which it is collecting any personal information by such means as is appropriate in the circumstances. This may include providing disclosure orally, by telephone, or in person, providing disclosure in a contract or in other written information given to a Client, posting a notice on Valiant’s website or any other means deemed appropriate in the circumstances.

In some instances, where the purpose for collecting information is reasonably evident to the person providing the information, the purpose will be implied but not explicitly stated (for instance, on rental applications, when a potential tenant provides us with his or her income and banking information or on Pre-Authorized Payment applications when a unit owner authorizes the condominium corporation to withdraw monthly common charges from a Client’s bank account).

Consent For Collection, Use Or Disclosure of Personal Information

Valiant will seek to obtain consent from a Client before or when it collects, uses or discloses personal information except as described below. Valiant will strive to ensure that Clients understand how their personal information will be used or disclosed.

Consent can be expressed (i.e. given orally, electronically or in writing), implied or given through an authorized representative. Consent may be implicit when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes).

You can withdraw consent at any time, with certain exceptions (for example, subject to any legal or contractual restrictions) and upon reasonable notice to Valiant. Valiant will strive to inform a Client of all implications of withdrawing his or her consent. You may contact Valiant respecting the withdrawal of any previously given consent or any change in the purposes for which information held by Valiant may be used, disclosed or retained. Note that information may be retained by Valiant for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.

Valiant, however, may collect, use or disclose personal information without the Client’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

In order to serve you better, Valiant Clients have access to certain information through its web site www.vrpl.ca which provides general information about the Company and the products and services it offers. Valiant is committed to your privacy and strives to ensure that any information you access or provide through this site remains secure. Valiant may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit our web site. This information is collected using “cookies” and might include the pages you visited, your Internet Protocol address and other site usage statistics. This anonymous information is used for research and analytical purposes only (i.e. evaluating how many visitors our web sites receive or which pages they visit most often). It does not reveal any personal information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.

Limiting Collection Of Personal Information

Valiant will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.

Limiting Use, Disclosure and Retention Of Personal Information

Personal information will only be used or disclosed for the purpose for which it was collected unless a Client has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, Valiant may have a legal duty or right to disclose personal information without a Client’s knowledge or consent with respect to matters that concern the public’s interest.

Accuracy Of Personal Information

Valiant will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Valiant will update or correct any personal information held by it if the Client concerned provides Valiant with particulars, satisfactory to it, of any required updating or correction.

Safeguarding Personal Information

Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.

Valiant has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) using user I.D.’s and passwords are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

Openness Concerning Policies and Practices

Valiant will make information available to Clients and others about the policies and procedures Valiant uses to manage personal information. Clients have access to much of this information through our web site, or through written correspondence with Valiant.

Customer and Employee Access To Personal Information

As a Client, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to Valiant. Valiant will respond to your request as efficiently as possible and will advise of the individual cost, if any, prior to the retrieval of such records. Valiant will not respond to frivolous or vexatious requests for access to information. If Valiant is prohibited from providing such access it will explain the reasons, except where prohibited by law. To make a change to your personal information (as discussed under “Accuracy” above), please make a similar request in writing to the Valiant.

Questions or Concerns

Valiant has policies and procedures to receive, investigate and respond to any questions or concerns respecting this Privacy Policy or the personal information that we hold. Clients may contact Valiant with any questions or concerns or to request access to their personal information.

For more information on Valiant’s commitment to privacy, contact Valiant through one of the following:
Valiant Rental Properties Limited
177 Nonquon Road 20th Floor
Oshawa, ON L1G 3S2
(905) 579-1626
Email: feedback@vrpl.ca