City Flats Asset Management Inc. (“Cityflats”) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information we hold. This privacy policy (“Privacy Policy”) outlines how we manage your personal information and safeguard your privacy.

Your Privacy Rights

All Canadian businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (the “Act”). The Act gives you rights concerning the privacy of your personal information.

Cityflats is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy, and trained our staff about our Privacy Policy and practices.

Why Does Cityflats Need Personal Information?

Cityflats collects personal information to:

• establish relationships with clients, suppliers, and other entities;
• market and promote its products and services;
• respond to enquiries, questions, comments and testimonials submitted by clients and prospective clients through this website, social media or otherwise;
• detect and protect Cityflats and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with Cityflats policies and contractual obligations;
• as permitted by, and to comply with, any legal or regulatory requirements or provisions; and for any other purpose to which you consent.

What Personal Information Do We Collect?

Personal information is any information that identifies you, or by which your identity could be inferred.

How Do We Collect Your Personal Information?

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you. Depending on the nature of our relationship, sometimes we may obtain information about you from other sources, for example from a government agency or registry.

Consent

In most cases, we will ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent.

Use of Your Information

We use your personal information to provide our products and services to you, to administer our client marketing databases and to include you in any direct marketing activities. If you tell us that you no longer wish to receive information about our products or services, we will not send you any further material.

Disclosure of Your Personal Information

Under certain circumstances, Cityflats will disclose your personal information:

• when you have consented to the disclosure;
• when we are required or authorized by law to do so, for example, if a court issues a subpoena
• if we engage a third party to provide administrative services to us (like an accountant or a computer file storage company) and the third party is bound by our Privacy Policy or a similar privacy policy;
• and if the information is Publicly Available Personal Information, as that term is defined under the Act.

Updating Your Information

Since we use your personal information to provide products and services to you, it is important that the information be accurate and up-to-date. If during the course of our relationship, any of your information changes, please inform us so that we can make any necessary changes.

How Is My Personal Information Stored and Protected?

Cityflats takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;
• restricted access to personal information;
• deploying and ensuring that service providers deploy technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• and internal password and security policies.

Where Personal Information is sent to a third party for processing we ensure, through our contacts with them, that all Personal Information is kept secure.

Access to Your Personal Information

You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be passed on to you by us.

Correcting Errors

If Cityflats holds information about you and you can establish that it is not accurate, complete and up-to-date, Cityflats will take reasonable steps to correct it.

Can I Be Denied Access to My Personal Information?

Your rights to access your personal information are not absolute. We may deny access when:

• it is required or authorized by law;
• to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;

Where Do We Store Your Personal Information?

Your Personal Information is stored in secured locations and on servers controlled by Cityflats or its service providers, located

either at our offices or at the offices of our service providers.

• to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record;

• or the information was generated in the course of a formal dispute resolution process. If we deny your request for access to,

or refuse a request to correct information, we shall explain why.

Can I Request Anonymity?

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website).

Communicating With Us

You should be aware that, like most other methods of communication, e-mail and other forms of electronic communication are not 100% secure mediums; you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

Since Cityflats regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access

If you have any questions or wish to access your personal information, please write to our Privacy Contact at:

City Flats Asset Management Inc.

302-177 Wellington St.

Kingston, ON K7L 3E3

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street,

Ottawa Ontario, K1A 1H3

1.800.282.1376.

Website

Our website (https://www.cityflats.ca/ and others that we may operate from time to time, in this Privacy Policy the “Website”) contains links to other sites, which are not governed by this Privacy Policy. On our Website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

Effective Date

This Privacy Policy was last updated on February 13, 2023.