PRIVACY POLICY

We process your Personal Information based on:

• Your provision of consent (where applicable),
• exceptions to the consent requirement as outlined in the law;
• your contract with us;
• your business relationship with us; and

in line with legal or regulatory requirements or guidance.

We collect Personal Information necessary to operate our business and to provide the information and services of your choice. With limited exceptions, we collect your Personal Information directly from you through different forms and contracts. Collection of Personal Information is usually conducted via email, websites, phone, fax, in person, or through marketing campaigns. From time to time, we utilize publicly accessible information where necessary to verify information provided by you.

If you choose to use any application or functionality that we make available to you, your Personal Information will be collected not only by us, but also by our service providers; as such, policies relevant to the provision of their tools or services may apply in addition to ours.

When you disclose to us the Personal Information of another person for use in connection with our services, such as personal or professional references, you must be authorized to entrust that Personal Information to us.

We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:

• Administering our properties.
• Acquisition and disposition of properties and asset management.
• Conducting due diligence processes.
• Engaging vendors as needed for the maintenance and upkeep of Skyline properties and for utility management (i.e., submetering).
• Recording calls to process your requests or complaints and for quality assurance, customer support, service improvement, staff training, analytics and, where applicable, for dispute resolution processes, to defend claims against us and use it as evidence in relevant proceedings, and as otherwise required for our debt collection process.
• Taking actions required to make our properties sustainable (including, for example, installing and monitoring sensors and EV chargers).
• Conducting events and marketing activities.
• Obtaining and managing leads (tenant prospects).
• Determining the feasibility of entering or renewing lease relationships.
• Verifying your identity when applying to rent an apartment, property, unit, or space or otherwise when seeking to enter a business relationship with us.
• Connecting you with our partners (i.e., tenant insurance providers) to facilitate the lease process for you.
• Establishing the need for indemnifiers or guarantors and determining their suitability.
• Managing the lease relationship (with tenants and indemnifiers or guarantors) or the business relationship.
• Processing surveys (such as the Net Promoter Score survey, which is used to measure your customer experience).
• Communicating with you as needed, prior to, during, and after the end of your relationship with us, including, for example, to provide notice of entry when required or to send you birthday cards.
• Managing any requests and complaints in connection with your relationship with us.
• Setting up payment methods, managing your payments, payment plans, and the debt collection process.
• Providing answers to general inquiries and information relevant to your lease or business relationship with us.
• Verifying your compliance with the lease agreement.
• Conducting unit inspections and ensuring that rental units are kept in adequate conditions.
• Processing accommodation requests.
• Activating emergency procedures when needed (Emergencies may include natural disasters, power failures, viral outbreaks, fires, medical or social assistance for tenants, among others).
• Operating social assistance programs such as Skyline’s Refugee Assistance Program, the RISE program, carrying out wellness checks, and aiding tenants in need of assistance (i.e., via gift cards).
• Administering social housing and the relationship with the relevant municipality and government authorities.
• Managing behavior against our policies or against the law.
• Handling incident reports and claims, such as legal claims based on personal injury, property damage, human rights complaints.
• Initiating legal procedures when required and defending our claims.
• Complying with access and disclosure requests.

Additionally, we process your Personal Information for business purposes like record-keeping, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.

In line with our Processing of Personal Information for the purposes listed above, we conduct tasks (“Processing Activities”) that are required to provide you information and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose.

The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.

Note that Processing Activities and Personal Information collected, used, and disclosed may change from time to time.

1. Service Providers and Partners: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information. Some of the categories of service providers and partners with whom we share your Personal Information include property managers, real estate brokers, utility providers, marketing management, advertising partners, lead management providers, property listing sites, technology vendors, analytics providers, credit reporting partners, credit agencies and bureaus, appraisers, lenders, environmental assessment consultants, financial and similar institutions, consultants, auditors, mail services, record-keeping providers, trades people, submetering vendors, insurance partners, etcetera. Where you express interest, we will connect you to our partners for the provision of additional products or services (i.e., tenant insurance, cable, and internet providers), in which case disclosure of Personal Information will be required.
2. By default, many of our properties are set up for the provision of services and utilities by specific providers (such as Bell, Rogers, or similar depending on geographic location). If you are a tenant, this means that we need to share information about you with them such as your name, unit number, contact number, and move-in date for the purpose of setting up your account. For billing purposes, we share your information with utility manager providers. That information includes, for example, your name, unit number, move in date, move out date, and email address.
3. Other Companies within the Group: Specific circumstances, such as mortgage financing and refinancing processes for our properties demand that we share your Personal Information, including leases and Personal Information included in rent rolls with other entities of the Skyline Group of Companies, which may have to disclose that information to government agencies and financial or credit institutions. Furthermore, if we determine that Processing of Personal Information by another entity within the Skyline Group of Companies would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with other entity within Skyline Group of Companies, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
4. Government bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations. For example, where you are being audited by Canada Revenue Agency, they may request that we disclose some information about you including your lease and relevant rent roll.
5. Third Parties: In some situations, for instance, where we act as property managers for specific buildings, we will be required to share your Personal Information with building owners. In other cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law. Examples of third parties seeking your information include your power or attorney, legal aid lawyers, public guardian trustees and, in certain occasions, third-party auditors.
6. Business Partners: Subject to applicable contractual provisions, we disclose Personal Information required to assess the viability of a business transaction (such as acquisitions and dispositions) as authorized by law.