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Graywood
Privacy Policy

This Privacy Policy was last modified on October 26, 2018

This website and the individual project websites (collectively, the “Site”) are owned and operated by Graywood Developments Ltd. and/or its subsidiaries or affiliates (“Graywood”, “us”, “we” or “our”). At Graywood, we take the issue of safeguarding privacy very seriously and are committed to protecting the confidentiality and security of the personal information entrusted to us. This Privacy Policy sets out Graywood’s policies and practices with respect to the collection, use and disclosure of personal information.

Our Privacy Policy has been designed to comply with Canada’s Personal Information Protection and Electronic Documents Act and other applicable federal and provincial privacy laws relating to the protection of personal information (collectively, “Privacy Legislation”). All of our employees, contractors, consultants, agents and third-party service providers are bound to comply with this Privacy Policy. By using our Site, you are consenting to the collection and use of information as is outlined in this Privacy Policy.

WHAT INFORMATION WE COLLECT AND HOW WE USE IT

In the course of our business, Graywood may collect “personal information” (as defined under Privacy Legislation) from our current and prospective investors, purchasers and employees, including an individual’s name, address, birth date, phone numbers, mailing addresses, email addresses, income, social insurance or social security number, employment and occupational data, home purchasing preferences, residency, municipal and legal descriptions of property, company affiliations or other personal identification numbers. We may also obtain further personal information, such as financial data and information required to establish that an individual is an “accredited investor” or the equivalent under laws of jurisdictions outside of Canada, in the course of providing services to our investors. Graywood may collect such non-public personal information from online forms, subscription agreements and related documents, through meetings and telephone conversations with investors and purchasers, or from consumer reporting or credit agencies.

Graywood is not responsible for the collection and use of your information by third-party websites, including any websites that may be accessible from links contained on the Site and on the investor site accessible from https://investors.graywoodgroup.com. Graywood encourages you to review the privacy policies of each third-party website you visit.

The personal information collected in the course of Graywood’s business will only be used for the purposes of:

  • providing information and marketing communications to current and prospective purchasers and investors on new developments and in respect of our organization;
  • providing information and services to investors in Graywood sponsored funds, including executing transactions and providing confirmations, tax information and financial statements in connection with such investments;
  • satisfying Graywood’s obligations under applicable legal and regulatory requirements, including any obligations to ensure that each investor’s investment is suitable for such investor and that each investor is a person to whom Graywood is permitted to sell interests to;
  • communicating with an individual in relation to their prospective or current employment with Graywood; and – any other purpose to which a purchaser, investor or employee may consent in the future.

Graywood does not disclose any non-public personal information about prospective, existing or former purchasers, investors or employees to anyone, except as permitted by law and regulation, as authorized by the relevant individual in writing or in accordance with this Privacy Policy. We may share your personal information with third party service providers located in Canada and the United States. For example, we may use service providers to collect and send email or other communications, analyze the effectiveness of our Site, operate certain features of our Site and provide consulting services.

We only share your information with third parties for completion of the above uses, and any third party’s use must adhere to this Privacy Policy and all applicable laws. We do not authorize third parties to use or disclose personal information for their own marketing or any other purposes.

One of our third-party service providers, Juniper Square, Inc. (“Juniper Square”) hosts and operates an investor portal (the “Portal”) on behalf of Graywood, as a result of which Juniper Square has access to, stores and processes all personal information received and collected about users of the Portal. Graywood also furnishes information to Juniper Square about such users for the purpose of hosting and operating the Portal and facilitating the provision of products and services by Graywood. Juniper Square does not direct or control Graywood’s use or storage of personal information about you. Juniper Square’s collection, use and disclosure of your personal information is described in the Juniper Square privacy policy, which is available at http://www.junipersquare.com/legal/privacy_policy.html.

We may also disclose your personal information if we believe in good faith that such disclosure is necessary to protect Graywood’s rights, the rights of other users, or anyone’s safety, including for the detection and prevention of fraud, intellectual property infringement, violations of the Site’s Terms of Use or applicable law, or any other misuse of the Site.

If Graywood or substantially all of Graywood’s assets are acquired, or in the unlikely event that Graywood were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Graywood may continue to use your personal information as set forth in this Privacy Policy (as it may be amended from time to time).

The Site is not directed to, and Graywood does not knowingly collect personal information or any information from, children under the age of 13. If you become aware that your child or any child under your care has provided such information without your consent, please contact Graywood immediately using the contact information provided below.

SAFEGUARDING YOUR PERSONAL INFORMATION

We employ organizational, physical and technological safeguards to restrict access to non-public personal information about investors or purchasers to those employees and agents of Graywood who need to know that information in order to provide our services, and to protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.

We will only keep your personal information on our records so long as it is needed for its identified purpose. Files are destroyed when there is no longer any possibility of them being used for administrative or legal purposes or because we are obligated to do so by law. We will ensure that all reasonable steps are taken in the disposal or destruction of personal information to prevent unauthorized parties from gaining access, including shredding paper records and permanently deleting electronic data.

Some of your information will be stored in, processed in and subject to the laws of the United States, which may not provide the same level protection for your information as Canada, and may be available to the United States government or its agencies under a lawful order made in the United States. By using our Site, you consent to such transfer to, storage in and processing within the United States.

HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION

Graywood will do its best to ensure that your personal information is correct and kept current. With certain limited exceptions as provided in Privacy Legislation, you have the right to access your personal information held by Graywood and, as the case may be, to request that the information be corrected if it is inaccurate, incomplete or collected in violation of the law. You may update or correct information about yourself by emailing us at investors@graywoodgroup.com. In circumstances where your personal information has been provided to Graywood by a third party, we will refer you to that third party.

WITHDRAWING YOUR CONSENT

You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Privacy Policy at any time upon reasonable notice to Graywood in writing, subject to legal or contractual restrictions. The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.

You may also opt out of receiving promotional emails from Graywood by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

COOKIES, WEB BEACONS AND OTHER TRACKING DEVICES

We may use cookies, web beacons (invisible electronic images that can recognize certain types of information on your computer) and other tracking devices on our Site. These devices allow us to measure Site activity to provide a better user experience. Cookies, web beacons and other tracking devices may be used to tell us the time and length of your visit, the pages you look at on our Site, the website you visited just before coming to ours, and the name of your Internet service provider.

Graywood and our third party service providers may use cookies, web beacons and other tracking devices to collect certain information about your visits to our Site or other websites (such as browser type, IP address, which page was visited, and time of day). We may also collect data through Google’s interest-based or third party audience data (such as age, gender and interests). All of the information we collect may be used to evaluate the performance of our Site, the Portal and our online advertising program or to tailor promotions and other marketing messages to you.

Graywood does not use technical measures embedded in the Site to track your activities across other websites or online services, whether you configure your browser’s Do Not Track feature or otherwise. However, the Site does use third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that use such measures.

As you browse www.graywoodgroup.com, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display-advertising partners then enable us to present you with retargeting advertising on other websites based on your previous interaction with www.graywoodgroup.com. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.

You may adjust your browser settings to reject cookies if you so choose. If you wish to view the cookies which reside in your computer or change your browser settings to reject all cookies or ask for your approval before accepting them, use the preferences settings in your browser. If you do decide to disable our cookies, you may not be able to take full advantage of certain features available on our Site.

PRIVACY OFFICER

Graywood has appointed Louise O’Brien as our Privacy Officer. The Privacy Officer is accountable for Graywood’s compliance with the principles of Privacy Legislation and this Privacy Policy.

If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of, your personal information under Graywood’s care and control, please contact the Privacy Officer at:

Louise O’Brien
Graywood Developments LP
200 King St. West, Suite 1602
Toronto, ON M5H 3T4

Email: info@graywoodgroup.com
Phone: 416.599.1930

RIGHT TO FILE A COMPLAINT

If you believe the privacy laws relating to the protection of your personal information or our Privacy Policy have not been respected, you may file a complaint with our Privacy Officer at the address listed above. Graywood will investigate all complaints. If, after an investigation, your complaint is deemed justified, Graywood will take appropriate steps to correct the situation, including, if necessary, amending our policies and practices. If you are not satisfied with the results of the investigation or the corrective measures taken by Graywood, you may exercise the remedies available under law by contacting the Office of the Privacy Commissioner of Canada at the address below:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3

CHANGES TO OUR PRIVACY POLICY

Graywood reserves the right to modify or supplement this Privacy Policy at any time. If we make changes, we will notify you by posting the updated policy and revising the “Last Updated” date above. We encourage you to review this Privacy Policy whenever you use our services and to stay informed about our information practices and how you can help protect your privacy.