PRIVACY POLICY

Last Updated: February 12, 2024

Skyline Apartment Real Estate Investment Trust, Skyline Real Estate Limited Partnership, including its operating division, Skyline Living, and their respective subsidiaries (collectively “we”, “us”) are committed to safeguarding the Personal Information you entrust to us. This privacy policy will inform you about the Personal Information we process and how we process it.

We process your Personal Information in accordance with applicable privacy legislation, which includes the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and provincial legislation deemed substantially similar to PIPEDA (privacy legislation applicable to the private sector in British Columbia, Alberta, and Quebec). 

  REPORT A PRIVACY INCIDENT          PRIVACY RIGHT REQUEST         SUBMIT A PRIVACY COMPLAINT

1. Scope

This privacy policy applies to Personal Information of lease applicants, tenants, indemnifiers or guarantors, vendors, and business partners processed by us. “Processing” Personal Information means collecting, using, and/or disclosing it.


  • If you are an investor, please note that, in addition to this privacy policy, Skyline Wealth’s privacy policy will be applicable to you (https://skylinewealth.ca/privacy-policy/) as Skyline Apartment Real Estate Investment Trust employs their services to Process investor data.

  • In connection with acquisitions, dispositions, and asset management, we use Skyline Mortgage Finance Inc. for mortgage financing and refinancing purposes. Their privacy policy is available here: https://www.skylinegroupofcompanies.ca/our-businesses/skyline-mortgage/

  • Furthermore, for the maintenance and administration of electric vehicles, we use the services of Skyline Clean Energy Fund. To access their privacy policy, please visit https://www.skylineenergy.ca/privacy-policy/

  • If you are a Skyline employee, please refer to the internal privacy policy.

 

Personal Information encompasses information about identifiable individuals. Beyond standard elements considered Personal Information (like your name, email, address, phone number, etc.), what makes you identifiable is sharing different pieces of data that, alone or in conjunction with other data, allow us to unequivocally identify you. By way of illustration, your name without further data elements like an address or postal code is unlikely to be categorized as Personal Information because other people may have the same name, as such we may not be able to identify you with certainty.

2. Processing of Personal Information

2.1.  Legal Bases

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.


2.2.  Collection of Personal Information

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.

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.


2.3.  Processing Purposes

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, staff training, analytics and, where applicable, for dispute resolution processes.
  • 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 Skyline Living.
  • 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 Skyline Living.
  • 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.


2.4.  Processing Activities, Profiling and Tracking

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.

APPLICATION, LEASE, AND RELATIONSHIP MANAGEMENT

Personal Information

Processing of Personal Information is required for the assessment of rental applications, lease execution, renewal and termination, and the management of the lifecycle of our relationship with you, including, for example, supervising move-ins and move-outs, protecting your quiet enjoyment of the rental unit, verifying your compliance with the lease, managing requests and complaints, payment administration, emergency management, and any other activities derived from the relationship with our tenants.

All Personal Information provided during the lease application, lease execution, and during the lifecycle of your relationship with us, including information about references and indemnifiers or guarantors where applicable.

Sensitive categories: Financial information, Personal Information required for identity verification, health information (where provided by you in connection with different requests or to be added to the list of tenants requiring assistance in case of emergency or where incidentally Processed in the course of your relationship with us), credit checks and information used to verify your suitability to rent the unit you applied for, Personal Information provided in relation to the RISE and refugee assistance programs and other social initiatives that may require an understanding of grounds protected under Human Rights Codes for the purpose of providing the relevant social assistance.

LEASE AND INDEMNIFIER AGREEMENT/GUARANTOR ENFORCEMENT

Processing of Personal Information is required to ensure that tenant obligations derived from the lease are complied with. By way of illustration, this process encompasses consistent communication with tenants and, when the non-compliance is related to failure to pay rent or monies owed to us, it also involves payment plans, reporting to credit agencies and legal actions if and where needed.

MANAGEMENT OF SOCIAL PROGRAMS

We aim to understand social issues impacting the communities where we operate. As part of our commitment to the welfare of these communities, we run social programs to assist our tenants. These programs require Processing of Personal Information.

MARKETING ADMINISTRATION

Personal Information

Processing of Personal Information is required for conversion of leads, management of applicant and tenant requests, administration of websites, management of communications, analytics and metrics, change management pertaining to applicant and tenant requests and management of all events and marketing activities that take place in our properties.

Name, email, phone number, address, age, province, preferences (contact method, language), social media information (where linked by you), user activity (information about your interaction with our systems including website sessions, interaction with advertisements and social networks, and call recordings), personal testimonies, metadata.

 

BUILDING AND BUSINESS OPERATIONS

Personal Information

Processing of Personal Information is required for managing our properties and our business. Activities in this category include utility management, procurement administration, fire and life safety activities, housing agreements administration, sustainability, security, complying with legal and regulatory obligations, handling rent increases, managing unlawful conduct in our properties, handling claims against us, and conducting general business operations.

 

All information mentioned previously.

Sensitive categories: Health information of tenants who indicate that they require assistance in case of emergency (added to emergency list) or that is incidentally obtained; Personal Information required to administer social housing; Personal Information related to criminal activities; Personal Information related to human rights claims and, under certain circumstances, video footage.

ACQUISITIONS, DISPOSITIONS, ASSET MANAGEMENT AND BUSINESS DEVELOPMENT

Personal Information processed to obtain, dispose, and manage properties may include Personal Information included in rent rolls, tenant files, pictures (such as those included in appraisal reports), video footage, and Personal Information derived from due diligence processes carried out to verify the feasibility of a business transaction or to comply with legal and regulatory obligations.

OTHER INFORMATION OF RELEVANCE

  • Our Processing Activities require communication and sharing of Personal Information within the Skyline Group of Companies. For example, the financial component of your business relationship with may require sharing Personal Information with Skyline Group of Companies’ finance department; activities such as acquisitions require the involvement of Skyline Mortgage Financing Inc. for mortgage financing purposes; management of investor data is conducted through Skyline Wealth; and electric vehicle chargers available in some properties are administered and maintained by Skyline Clean Energy.
  • If you contact us over the phone, your call may be recorded. 
  •  PROFILING: Profiling means the collection and use of Personal Information to assess specific characteristics of an individual, in particular to analyze that person’s work performance, economic situation, health, personal preferences, interests, or behavior. In Processing sensitive Personal Information, we abide by our non-discrimination policy. We do not have fully automated processes.

Regarding marketing, we document your preferences, such as information, products, or services you may be interested in. You can always opt-out from our marketing communications by using the link available in emails you receive from us or by contacting us at customerservice@skylineliving.ca

  •   TRACKING: We track the lifecycle of our relationship with you in our database. We also track your user activity to enable our systems to recognize your browser or device and to provide, market, and improve our offerings. To this end, we and our service providers use cookies and similar technologies (pixels and beacons). To learn about cookies, visit https://allaboutcookies.org/.

2.5.  Sharing Personal Information
  1. Service Providers: 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 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: 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.
  5. Access Requests by Third Parties: In some 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, for instance, your power or attorney, legal aid lawyers, public guardian trustees and, under specific circumstances, 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.

 


3. Storage of Data, International Transfers and Transfers Outside of Quebec

Your Personal Information may be processed outside of Canada. If you are a Quebec resident, please be advised that your Personal Information is processed outside of Quebec. Personal Information may be accessed, transferred, or transit through other countries due to the nature of the Internet and based on the hosting location of some of our service providers. Access from other countries may also be required for maintenance, security, or support management.

4. Retention of Personal Information

We will keep your Personal Information for the period required to provide you with products or services, or otherwise to manage the business relationship, and for a more extended period where required or authorized by law, regulation, or guidance.

5. Security

We understand that the security of your Personal Information is essential; because of that, we employ a range of prevention and detection tools and methods to safeguard against the loss, unauthorized access, and unauthorized disclosure of the Personal Information we hold. Additionally, we implement administrative measures, such as contractual provisions, to ensure that the parties we share your Personal Information with are subject to legal and technical requirements to protect it.

6. Your Rights

You are entitled to access and rectification of the Personal Information we hold about you. If you are a Quebec resident, you may be entitled to additional rights. To exercise your rights, please use one of the following mechanisms:

Email: privacy@skylinegrp.ca

Mail: Please direct your communication to

Martin Castellan
Co-founder, Chief Administrative Officer & Privacy Officer

Attention: Legal - Privacy & Data Security
301 – 5 Douglas Street,
Guelph, ON
N1H 2S8

In connection to the exercise of your rights, we reserve the right to communicate with you to verify your identity and relationship with us, respond to questions you may have during the process, follow up with you and clarify the boundaries of the request where necessary, and to let you know about the progress of your request.

7. Changes to this Privacy Policy

This Privacy Policy is subject to changes as deemed necessary by us.