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.
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 firstname.lastname@example.org. 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 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
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.
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:
Graywood Developments Ltd.
200 King St. West, Suite 1602
Toronto, ON M5H 3T4
RIGHT TO FILE A COMPLAINT
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3