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Greenwin Inc. considers respecting your privacy an important principle of how business is conducted.  We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide and to the extent necessary to comply with legislation.  We also try to be open and transparent as to how we handle personal information.  This document describes our privacy policies.

Why Is Information About You Collected?

At Greenwin, we gather and use personal information to provide the services that you have requested and to offer additional services we believe you might be interested in.  Providing us with your personal information is always your choice.  However, your decision to withhold certain personal information may prevent us from providing you with the services you require.

 

What is Personal Information?

"Personal Information" includes information that relates to you specifically but does not include the name, title or business address or telephone number of an employee of an organization.

 

What Type of Information Does Greenwin Collect?

For residents and employees, the type of information Greenwin collects and maintains on file may include your name, current address, previous address, electronic address, telephone number, social insurance number, date of birth, marital status, sex, place of employment, annual income, credit history, bank information, health information, and dependent(s)' date of birth.  For business clients, information recorded may include business name, business address, telephone number, name(s) of Owner(s), Officer(s) and Director(s), social insurance number(s), articles of incorporation, description of organization and financial status.

 

We Collect, Use and Disclose Personal Information to:

  • Verify your identity
  • Determine your eligibility for the services you have requested
  • Detect and prevent fraud
  • Deliver the services you have requested
  • Compile statistics, conduct market research and report to regulatory and industry agencies
  • Comply with the law
  • Comply with tax requirements

 

We May Gather Information From the Following Sources:

  • From you on applications or on other forms filled out via telephone, e-mail or face-to-face interviews
  • From agents, brokers, intermediaries, with whom you have or had a relationship
  • From previous landlords, employers or references that you have provided to us
  • From your interactions with us (i.e. through your payment history)
  • From consumer reporting agencies (i.e. your credit history)

 

Use of Video Surveillance and Recordings

Video equipment may be installed and operating in common areas of the residential complex in which your rental unit is located.  The video equipment may have special capabilities that will allow it to capture sound recordings along with images. Other special capabilities that the video equipment may possess includes, but is not limited to, zoom, facial recognition, or night-vision features.

The video equipment will be operating at all times.  Surveillance of the video recordings may occur at any time. 

The purpose of the use of such equipment is to ensure your safety, security and reasonable enjoyment and that of the other tenants, to ensure you have access to the premises, equipment and services that our clients have agreed to provide, to preserve our clients' property, and to deter crime.

Where required by law, signs will be posted informing you that video equipment is operating and recording personal information about you.  Also posted on those signs will be the contact information for our Information Officer whom you can contact if you have questions regarding the video recordings or if you wish to have access to recorded images of you.

 

What is Captured by the Video Recordings

Your image, movements, actions, or other identifiable information about you, may be captured by the video equipment.  Where video equipment captures audio recordings, any sounds or communications you make may be recorded.    

 

Retention and Destruction of Personal Information Recorded by Video Equipment

The recordings captured by the video equipment along with the video equipment will be stored in a secured location.  Access to the location and recordings is limited.  Hardware is either under supervision or secured in a locked or restricted area.  Recordings will be kept for 35-45 days before being destroyed.   

 

Use of Audio Equipment and Recordings

There are circumstances under which the employer may make audio recordings of its employees, contractors, or tenants.  There are several purposes for making the recordings; they include: situations where there are work-related performance issues, to ensure the safety of the workplace, to ensure productivity, and to prevent harassment.  

Audio recordings may be made during meetings, interviews, or telephone calls between the employer and an employee. Audio equipment may be operating at other times.  Information recorded by the audio equipment may capture communications of any of the following persons: the employer, employee, tenants, contractors, and the general public.

 

Retention and Destruction of Personal Information Recorded by Audio Equipment

Audio recordings will be kept for 35-45 days before being destroyed.  The recordings may be kept for a longer period if there are on-going issues related to the employment relationship, if required by law, or if litigation is contemplated. The audio recordings will be stored in a secured location.  Access to the location and recordings is limited.  Hardware is either under supervision or secured in a locked or restricted area.  

Disclosure of Personal Information Recorded by Video or Audio Equipment

We may disclose your personal information without your knowledge or consent under certain circumstances.  Those circumstances include: if the disclosure is required by law, provided to our lawyers, for the purpose of collecting a debt you owe to us, in compliance with a subpoena, warrant, or issued order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records.

Disclosure may also be made to a government institution that has made a request for the information, identified its lawful authority to obtain the information and indicated that: it suspects that the information relates to national security, the defence of Canada or the conduct of international affairs, the disclosure is requested for the purpose of carrying out any investigation relating to the enforcement, gathering intelligence for the purpose of enforcing, or enforcing any law of any jurisdiction, or the disclosure is requested for the purpose of administering any law of Canada or a province. Disclosure may be made by an investigative body if the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.

Upon our initiative, we may disclose the information to an investigative body or a government institution if we have reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of the laws of any jurisdiction that has been, is being or is about to be committed, or if we suspect that the information relates to national security, the defence of Canada or the conduct of international affairs. 

If information regarding an identifiable individual is disclosed to a person who needs the information because of an emergency that threatens the life, health or security of an individual and, if the individual whom the information is about is alive, we will inform that individual in writing of the disclosure without delay.

 

When Do We Disclose Information?

We keep your personal information confidential except when authorized by you or when required or permitted by law.

Our employees, in the course of daily operations, may be required to access your personal information.  As a condition of their employment, all employees of Greenwin and our clients are required to maintain the confidentiality of personal and client information at all times and failing to do so would result in disciplinary measures which may include dismissal.

Outside service providers may, in the course of performing services, require access to personal information. These service providers may include, but are not limited to banks, payroll companies, benefit and insurance companies.  When we communicate with these suppliers, they are given only the information necessary to perform those services. 

A complete list of persons or business entities to whom your personal information may be provided and who may, in turn, send Commercial Electronic Messages (CEMs) to you is attached as a schedule to this privacy policy under the heading: "Third Party Disclosure".  At this time, we have taken steps to generally prohibit third parties from using your personal information for the purpose of sending you (CEMs) unless same are exempt from restrictions of, and are otherwise sent in full compliance with, Canada's Anti-Spam Legislation (CASL).  Third Parties who may send CEMs are listed in the disclosure schedule appended to this privacy policy.

 

For Applicants

We may provide an Applicant's name, new address and move in date to a third party telecommunications or service or utility provider, if the Applicant is accepted as a tenant, in order to enable that third party to contact the tenant in regard to the provision of en-suite services.  By completing a rental application form and a Consent to Disclosure form you agree to us collecting this information about your suitability to be a tenant.  Your information is subject to transfer to Third Parties in the same manner as that set out above. 

 

How Do We Protect Your Personal Information?

We understand the importance of protecting personal information.  For that reason, paper information and electronic hardware is retained either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.  Reputable companies transmit paper information through sealed, addressed envelopes or boxes.

 

How Long Do We Retain Personal Information?

Your personal information is retained only as long as we need it to effectively provide services to you, and for a reasonable length of time thereafter to meet any potential obligations or legal or government requirements.  We destroy paper files containing personal information by shredding.  We remove electronic information by deleting it, and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.

 

Accessing Personal Information?

You have the right to access, verify and amend your personal information unless:

  • The information is protected by solicitor-client privilege
  • The information was collected for purposes related to the detection and prevention of fraud
  • The information was generated in the course of a formal dispute resolution process
  • The information would likely reveal personal information about another individual

Should you require access to your personal information, the request would need to be made in writing to Greenwin's Privacy Officer  Your request would be responded to as quickly as possible.  If for some reason we cannot respond immediately, you would be advised.  A nominal fee may apply.

 

For more information, to make enquiries or to file a complaint, please contact:

Kris Boyce
Privacy Officer
Greenwin Inc.
19 Lesmill Road
Toronto, Ontario, M3B 2T3

Telephone: 416-487-3883
E-Mail: privacy@greenwin.ca
Website: www.greenwin.ca

For general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of privacy legislation in the private sector.  The Commissioner also acts as an ombudsman for privacy disputes.  The Information and Privacy Commissioner can be reached at:

112 Kent Street,
Ottawa, Ontario, K1A 1H3

Telephone:     613-995-8210
Toll Free:        800-282-1376 
Fax:                 613-994-6850
TTY:                613-992-9190
Website:         www.privcom.gc.ca

 

Schedule "A": Third Party Disclosure List

Below is the list of Third Parties that Greenwin provides personal information to. Consequently, you may receive CEMs from these suppliers.

 

Rogers Cable Communications Inc.

855 York Mills Rd.
Toronto, Ontario, M3B 1Z1
Website: www.rogers.com

Bell Canada

100 Wynford Drive
Don Mills, Ontario, M3C 4B4
Website: bell.ca