PRIVACY

Spotlight Development Inc. (“Spotlight”, “we”, “us” or “our”) is committed to maintaining the accuracy, security, and privacy of personal information in accordance with applicable laws.

This Privacy Policy describes how we collect, use, disclose, and protect personal information of our individual tenants, customers, website visitors, and other individuals we deal with.

This Privacy Policy does not apply to personal information relating to Spotlight employees, officers, or directors, or to information that is not personal information.

Spotlight’s objective is to ensure responsible practices in the collection, use, and disclosure of personal information, in accordance with applicable legislation.

Personal Information We Collect
We and our agents and representatives collect personal information in a number of circumstances in the course of operating our business. The personal information we collect includes:

Name, gender, age, address, family status, and contact information including telephone number(s) and email address.
Banking and other financial information.
Social insurance number and other identification numbers.
Employment information (past and present).
Information we collect in order to assess your financial situation, such as employment, income, assets, and credit history (including from third parties like employers, financial institutions, or credit agencies).
Information collected from references, including previous landlords.
Information collected through video surveillance systems, which may be installed in common areas of our properties.

How We Use Personal Information

We use personal information to:

Evaluate and process lease applications, including assessing payment abilities under lease agreements.
Manage our relationship with you, including processing payments, collecting amounts owed, enforcing obligations, and communicating about matters related to our properties.
Respond to requests and inquiries.
Communicate continuously regarding investments or services.
Ensure the safety, security, and appropriate use of our buildings and properties.

Disclosure of Personal Information
We may disclose personal information in the following circumstances:

To co-tenants, guarantors, or third-party payors as required under tenancy agreements.
To service providers (e.g., utilities, telecommunications, or cable) for service provision.
To affiliates for management, legal, billing, strategy, or administrative purposes (including outside Canada, subject to applicable laws).
To service providers for hosting, analytics, leasing, and other services (which may include processing outside Canada).
As part of transactions, such as financing, securitization, sale, or assignment of Spotlight or its assets.
As required by legal, regulatory, audit, and security needs, or as permitted by law.

Our Website
We use automatic data collection technologies like cookies to track website usage. Data collected includes IP address, date and time of visit, pages visited, and referring URLs. This data is used to optimize our website services. You may block cookies through browser settings, though certain website features may not function optimally.

Your Choices
Spotlight generally collects, uses, and discloses personal information with consent, except where permitted or required by law. Consent may be given explicitly or implicitly through the provision of information.

You may withdraw your consent at any time, subject to contractual and legal restrictions and reasonable notice. However, withdrawing consent may impact our ability to provide certain services.

Security

Personal information is stored securely at our offices, servers, or those of our service providers. We implement reasonable physical, electronic, and procedural safeguards to protect personal information from unauthorized access, loss, or misuse.

Cookies
We may use cookies to enhance your website experience. Cookies store data on your hard drive to track website interactions. You may refuse cookies through browser settings, though some features may not work as intended.

Privacy Policy Changes
This Privacy Policy is effective as of January 24, 2025. We may revise this policy from time to time. Material changes will be communicated, and the updated policy will be posted on our website. Your continued provision of personal information or use of services constitutes acceptance of any changes.

Contact Us
For more information about Spotlight’s privacy practices, to amend or access your personal information, opt-out, or withdraw consent, please contact:

Chief Operating Officer, David Hanick
david@spotlightdevelopment.com

Last updated: January 24, 2025