Definitions
“Acts” means the Personal Information Protection Act (Ontario), and the Personal Information Protection and Electronic Documents Act (Canada) and such other privacy laws that may apply to Green Thumb REIT from time to time; “Green Thumb”, “our”, “we”, or the “REIT” means the “Contrast Group” which includes reference to Green Thumb Real Estate Investment (“Green Thumb REIT”), Contrast Asset Management Inc., and those entities associated or affiliated with these companies or which have business, management, or ownership in common with them.
“Privacy Officer” means the individual designated by Contrast to ensure compliance with the Acts and make information about Contrast’s management of personal information available on request.
“Contrast associates” means any employee, contractor, supplier, officer or director of the corporation;
What is Personal Information and What Personal Information is Protected under Canadian Privacy Law?
Personal information as described in Canadian privacy laws is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual. You can be identified from information such as your name, email address, phone number, home address, driver’s license number, passport number, and financial history. You may also be identified from information such as an online identifier, IP address, unique device ID, or website cookie; this type of information becomes personal information when combined with information that further identifies who you are. Certain identifiable information is not protected by Canadian privacy laws such as your business or employment information typically found on a business card. Also, data we collect with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not protected under Canadian privacy laws. When we capitalize “Personal Information” in this privacy policy we are referring to your information that is protected by Canadian Privacy Laws.
How does Contrast Collect Your Personal Information?
Depending on how you do business with us, we may collect Personal Information from the following sources:
• from you through contracts or forms filled out through telephone, e-mail, online or face-to-face interviews;
• from intermediaries contracted by us with whom you have a relationship;
• from your interactions with us;
• for example, as an existing unitholder
• from government and other entities, such as CRA
What Personal Information does Contrast Collect?
We collect Personal Information from individuals who are investors or prospective investors requesting to be kept updated on our business.
With your consent, as an investor we usually collect and maintain your name, residential address, telephone number, e-mail address, social insurance number, identity verification information and banking information.
Personal Information may also include your transaction history with Contrast, customer service inquiries, information requested or provided to you, or responses to surveys.
We may also collect and summarize Personal Information in a format that does not identify you as an individual for statistical and marketing purposes.
We may record phone calls to or from our offices for the purposes of quality assurance control, customer service training, and to record consent and instructions related to business transactions with Contrast. If you have any questions or concerns with the taping of your phone calls, you may contact us in writing or through our website or the Privacy Officer.
It is always your choice whether or not you provide us with your Personal Information. However, a decision to withhold Personal Information may restrict or prevent us from allowing you to invest with us.
We do not permit registration by, nor collect personally identifiable information from any person we know to be under the age of 18.
Does Contrast Share My Personal Information with Other Parties?
With your consent or as permitted or required by law or other regulatory bodies which govern us and our business, we may disclose your information as follows:
1. To those associates within the Contrast that require your Personal Information for the uses set out above;
2. Or for a legitimate business purpose;
3. To the securities dealer, individual dealing representative or finder through whom you purchased our securities and any subsequent dealer or individual representative that assumes custody of, management of, or reporting responsibilities to you regarding, your Contrast investment holdings;
4. To our legal counsel;
5. To our auditors;
6. To a government institution, self-regulating organization, or other person or entity that has asserted its lawful authority to obtain the information;
7. Where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity to comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information;
8. To comply with court rules regarding the production of records and information; and
9. To contracted third party service providers (see below).We will only use and disclose your Personal Information to fulfill the purposes for which it was collected. Any exception will be with your prior consent, or as may be re required by law or other regulatory bodies which govern our business. Also, we will keep your information only for as long as it is needed to fulfill the purposes for which it was collected.
Once your data has been shared with a third party, Contrast no longer has direct control over that information, but we require our partners to agree to follow all state and country privacy laws.
Service Providers
Contrast may share your Personal Information with certain service providers in order to conduct our businesses, provide our products and services to you, verify and validate information and your identity, and to address investor business service matters. Examples of service providers include our bank, legal counsel, accountants and other business advisors, transfer agents, administration service providers, and delivery services. To reduce the risk of fraud or misuse of Personal Information, we will only provide such information as is necessary for the service provider to carry out the service we have contracted with them to provide.
We will use reasonable efforts to ensure that your Personal Information is used in a manner that is consistent with this policy. If you do not wish us to provide your Personal Information to our service providers, we may be unable to provide you with our products or services or properly service your account or carry out a transaction or enter into a business relationship with you.
We will not sell your Personal Information to any organization for any purpose.
What are Cookies and How Does Contrast Use Them?
A cookie is a small file saved on your computer to help store preferences and other information that is used on webpages that you visit. We use cookies on our website so that our webpages “remember” who you are as you navigate from page to page and process any requests you may have. Typically, a cookie will contain a user or session identifier without containing personal information about the user. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We, along with third-party vendors such as Google use cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to track website and app performance.
Tracking
Using cookies when you visit our website, we may automatically collect statistics about your visit. This information does not identify you personally, but rather about your visit to our website. We may monitor statistics such as how many people visit our site, which pages people visit, from which domains our visitors arrive, and which browsers people use. We use these statistics about your visit for aggregation purposes, not to track what specific individuals are doing on our sites. We do this for many reasons, including the following:
1. to recognize new visitors to our websites;
2. to recognize past visitors;
3. to present more personalized content, to improve your website experience, optimize your browser experience, and provide site and service enhancements; and
4. so that we can better understand visitors to our website visitors and their respective interests.
We may also occasionally send you informational e-mails or questionnaires. These e-mails may include links to our website or to the websites of other organizations. To enable us to tailor our communications to your interests, we may track the web links that you click on. This tracked information will only be used to analyze your interest in our communications, and in keeping with Contrast’s privacy policy, will not be shared with any other organizations. Alternatively, if you wish to remain anonymous, you can access the web pages referenced in those e-mails and your visit will not be tracked.
Turning off Cookies and Tracking
Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You can delete cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Click on any of the browser links below for instructions:
1. Microsoft Windows Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-managecookies
2. Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
3. Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=enUS&redirectslug=Enabling+and+disabling+cookies
If you are not using the listed browsers, you should go to the “Help” function for information on where to find your cookie folder.
Your Consent
By using our websites, you consent to the processing of data about you by Google and Contrast in the manner and for the purposes set out in this Privacy Policy.
Other Third-Party Websites and Links
As part of our service, our web site may contain links to other web sites or Internet resources. When you click on one of those links you are contacting another web site or internet resource. Our privacy policy does not cover the privacy practices of the web sites of our partners and affiliates, and we are not responsible for the privacy practices or the content of such web sites, partners, or affiliates. You should be careful to review any privacy policies of such web sites, partners or affiliates. Contrast does require its partners to comply with all privacy and data security policies and regulations.
How Does Contrast Obtain Consent to Collect, Use and Disclose Your Personal Information?
The cornerstone to protecting your privacy is consent. We will only collect, use, and disclose your Personal Information with your consent except where otherwise permitted or required by law, and we will only collect, use, and disclose Personal Information that we reasonably believe is necessary to complete the transaction or provide the service.
We want to ensure we have and maintain your confidence and consent to collect, use, and disclosure your Personal Information for the purposes identified in this Policy and at the time that you provide your Personal Information to Contrast. However, you do have a choice and can refuse or withdraw your consent at any time as follows:
1. You may choose not to provide us with any of your Personal Information. However, if you make this choice, we may not be able to do business with you or provide you with the product, service or information that you requested or that could be offered to you.
2. You may have your Personal Information removed from marketing lists which we use to inform you of new or relevant updates.
3. You may also ask us about your Personal Information and notify us of any corrections that may be necessary.
We need your consent to collect, use and disclosure your Personal Information. If you have already provided us with Personal Information, we would like to continue to use and disclose it for the purposes for which it was collected. If you do not contact us, we will assume that we may continue to do this in accordance with the standards described in this Policy. If you have any questions about our privacy practices or wish to withdraw your consent to the use and disclosure of your Personal Information, please contact us at the phone numbers provided below or email us at privacy@contrastmgmt.com.
Types of Consent
Consent may be expressed or it may be implied in appropriate circumstances.
Implied Consent
In some cases, your consent is implied if we ask you to provide Personal Information with a stated purpose and you comply with our request. Implied consent may be used by us as a basis for extending new product offers to you or delivering documentation, reports and servicing your investment. We will not use your implied consent for the use or disclosure of your sensitive Personal Information such as financial data, other than as required by law, such as reporting your investment or involvement in an investment with us to securities regulatory authorities and the Canada Revenue Agency.
Express Consent
In cases where the information being collected, used or disclosed is of a financial nature or is otherwise sensitive, we will seek your express consent to the use of your Personal Information. By completing and signing a subscription agreement or other transaction agreement and related documentation to purchase our securities or enter into a transaction with us, you are giving us your express consent for us to use the Personal Information provided by you in the ways outlined above or in the documentation provided to you at the time or as required or permitted by law or other rules and regulations governing us and our business.
Withdrawing Your Consent
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent, we will inform you of the consequences of such withdrawal. To withdraw your consent, simply contact us and advise us of what Personal Information you no longer wish us to use. Withdrawal of your consent may result in us being unable to continue to do business with you or to offer you our products or services.
How Does Contrast Protect The Personal Information It Gathers?
Your privacy is important to Contrast. We are committed to respecting your privacy through the protection of your Personal Information given to us when you invest with us, requested to be kept updated, or enter into another commercial transaction or business relationship with us.
The following outlines our commitment to you:
1. Collection, Use, and Disclosure – before collecting your Personal Information, or at the time of collection, we will explain to you the purpose for collecting it and obtain your consent;
2. Responsible Use of Information – our collection of Personal Information is limited to what is reasonable under the circumstances and your information will be used only for the purpose for which it is collected;
3. Security, Retention and Disposal – your Personal Information is kept confidential and secure and is not disclosed to anyone outside of the Contrast without your consent, unless required by law, and your Personal Information will be appropriately disposed of when it is no longer needed; and
4. Access to and Correction – you have the right to access your own Personal Information, and to correct any inaccuracies.
Security and Disclosure of Your Personal Information
We know you are concerned about the security of the information you provide to us. To address this concern, we have developed processes and procedures to keep your Personal Information safe and secure.
We have appropriate safeguards in place depending on the sensitivity of the information, including:
1. Physical: secured storage facilities and premises;
2. Technological: password-protected computers/files, firewalls, and a secured cloud server;
3. Organizational: Contrast associates trained in the importance of safeguarding your Personal Information from loss and unauthorized access and access limited within the Contrast organizations to those associates that require your Personal Information or part of it to carry out the uses outlined above or otherwise communicated to you or for a legitimate business purpose; and
4. Third Parties: in the event we transfer your Personal Information to a third party, we assess their privacy procedures or take steps to require them to protect your Personal Information in a manner consistent with our own internal measures or as required by law.
Although we cannot guarantee against theft, misuse, unauthorized disclosure, loss, alteration or destruction of your Personal Information by a third party, we take reasonable precautions to prevent such unfortunate occurrences. We will strive to keep your Personal Information as accurate and as up-to-date as is necessary for the purposes for which it is collected.
Personal information collected by us may be used, processed, or stored outside of Canada and may be subject to disclosure in accordance with the laws of such foreign jurisdictions, which may be different than the laws in effect in the jurisdiction in which you reside.
Compliance with Canadian Anti-Spam Legislation
Contrast has implemented a series of practices to comply with the consent and unsubscribing provisions for Commercial Electronic Messages (CEMs) in Canada’s Anti-Spam Legislation (CASL). Where consent is required by CASL, Contrast ensures that you have expressly opted-in or have given your implied consent to receive Contrast communications. To be in accordance with CASL, we agree to the following when using your email:
• Not use false or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third-party email marketing services for compliance, if one is used;
• Honour opt-out/unsubscribe requests quickly;
• Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
What are Your Rights to Access and Change Your Personal Information?
Accessing your Personal Information
You may access and verify your Personal Information and find out to whom it has been disclosed. At the time of your request, we will need specific information from you to verify your identity before we can provide you with the Personal Information we hold.
There may be instances when we will not be able to provide you with the Personal Information that you request. Examples are if the Personal Information:
1. Contains references to other persons;
2. Has already been destroyed due to legal requirements or because we no longer needed it for our purposes;
3. Is subject to solicitor-client or litigation privilege; or
4. Contains trade secrets or confidential business information of Contrast and its affiliates or others cannot be disclosed for legal reasons or we are not legally required to disclose it.
Changing your Personal Information
We are committed to maintaining the accuracy of your Personal Information for as long as it is being used for the purposes we have identified. To help us keep your Personal Information up-to-date, we encourage you to notify us of inaccuracies or corrections as often as you wish. Notification of changes such as your address or telephone number will help us provide you with the best possible service.
How Long Does Contrast Retain Personal Information?
We keep your information only as long as we need it for the products and services you’re receiving and for a reasonable time thereafter or to meet any legal requirements. We have retention standards that meet these requirements. We destroy your information when it is no longer needed, or we remove your personally identifiable information from our records.
Subject to legal, audit, or regulatory requirements for continued retention of your information, you can also request that we remove your information from our records.
How You Can Contact Us
If you have questions, concerns, or complaints about your privacy or Personal Information, you may contact us at the address listed below. We will inform you of our complaint procedures and will assist you in resolving the situation. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our practices and procedures.
6-425 Hespeler Road
Suite 210
Cambridge, Ontario
N1R 8J6
Attention: Privacy Officer
Tel: 1-416-800-0344
E-mail: privacy@contrastmgmt.com
We will respond to your request or investigate your concern as quickly as we can.
