ONTARIO AOYUAN PROPERTY LIMITED

PRIVACY POLICY

This policy statement (the “policy”) sets out the privacy policies and practices for Ontario Aoyuan Property Limited and its subsidiaries and affiliates (collectively, “Aoyuan”) with respect to the collection, use and disclosure of personal information. This policy may be updated by Aoyuan giving reasonable notice of the revised Policy (including by e-mail or by posting at Aoyuan’s website at www.m2mcondos.com and this Policy may be supplemented or modified by agreements entered into between Aoyuan and an individual from time to time.

Personal information is any information about an identifiable individual, as defined under the Personal Information Protection Act (ON) or other applicable laws.
1.  Privacy Officer

The Privacy Officer is responsible for ensuring Aoyuan’s compliance with this policy statement.

Ontario Aoyuan Property Limited

1800-145 King Street West, Toronto, M5H 1J8,

Attention: Privacy Officer

Tel: 416-363-6688

Fax: 416-214-3251

Email: Toronto@aoyuangroup.com

2.  Collection, Use and Disclosure Purposes

Except where otherwise required or permitted by law, Aoyuan will inform individuals of the purposes for the collection, use or disclosure of the individual’s personal information, prior to collecting, using or disclosing that personal information.

Aoyuan collects information from customers and potential customers through various means including guest registration sign-up sheets, campaign registrations, web-form registrations, purchase and sale agreements and customer survey responses. The type of information collected will vary depending on the means through which an individual submits his/her personal information. The type of information collected may include an individual’s name, residential address, e-mail address, home phone number, occupation, employment status, age group, current residential ownership details, whether first time buyer, financial and credit information, real estate investment purposes and preferences, preferred marketing mediums and specific comments. For security reasons, Aoyuan may also utilize video surveillance to monitor its premises, sales centres, and building sites from time to time.

Aoyuan uses information collected from customers and potential customers to provide products or services to customers, to provide products or services to its buildings for the benefit of customers, to respond to requests for information regarding Aoyuan’s products and services, for input on preferred features for future developments, mailing contacts for Aoyuan publications and newsletters, special events marketing and other marketing research activities, and for additional purposes that may be identified at or before the time that the information is collected. Aoyuan also uses personal information from purchasers for accounting and transaction completion purposes. Aoyuan may disclose personal information to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.

Aoyuan may use cookies on its website (“Site”). A cookie is a small text file sent from a Web server and placed on an individual’s computer’s hard drive. A cookie is generally used to enhance an individual’s browsing experience. Individuals can choose to set their browser to detect and reject cookies, to accept cookies from all sites, or to prompt them whenever a site wants to send them a cookie. Individual’s can check their browser’s “Help” files to learn how to do this. If individuals choose to refuse cookies, they may not be able to access some of the interactive features on Aoyuan’s Site. Cookies used by Aoyuan do not give it access to anything on an individual’s hard drive and cannot do anything to a computer.

Cookies used by Aoyuan are encrypted for security purposes to make any information in the cookie unreadable to anyone outside of Aoyuan. Aoyuan uses two types of cookies: session cookies (temporary) or persistent cookies (longer-term continuing use).

Session cookies may be used to support on–line feedback/discussion, forms and registration and ‘e–commerce/shopping cart’ transactions. They are used only during an individual’s online session and expire when the individual closes his or her browser. Without session cookies, moving around the Site could be much slower.

Persistent cookies are different from session cookies because they are stored on an individual’s computer’s hard drive for some length of time. They are usually used if an individual wants Aoyuan to remember information about that person’s Web preferences and passwords for automatic log–in purposes.

In addition, Aoyuan uses other normal Internet tracking tools associated with standard Internet protocols and web–based systems to collect certain system information. This system information is typically stored in log files and the information is used for aggregate reporting. Aggregate reporting includes total number of visitors, most visited sections, peak traffic times, etc. Log files are simply transaction records web servers maintain.  Those logs are used for recording information, such as:

  • service provider IP addresses;
  • browser versions;
  • referring websites;
  • search terms used;
  • average number of pages requested;
  • average duration of visit;
  • total visitor traffic.

Aoyuan uses aggregate information gathered from an individual’s visit to better design and administer its Site. This information supplies Aoyuan with a broad picture of how people use its Site in order to help the management of Aoyuan’s systems and to better serve Aoyuan’s audience. “Aggregate information” is information that is not specific to identifiable individual. Because this aggregate information does not identify an individual, it does not constitute personal information. Aoyuan reserves the right to use aggregate information in any manner it sees fit in the course of fulfilling its business objectives, subject to any obligations that may apply to Aoyuan and the particular information.

Aoyuan is not responsible for the privacy practices of other websites to which it has links. Aoyuan encourages individuals to read the privacy statements of each and every website that requests personal information from them.

Requirements for consent to collection, use, or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, Aoyuan will take into account both the sensitivity of the personal information at issue and the purposes for which Aoyuan will use the information. Consent may be express, implied (including through use of opt-out consent where appropriate), or deemed. For example, if an individual provides his/her mailing address and requests for information regarding a particular product, consent to use the address to mail product information to the individual is implied.

On giving reasonable written notice to Aoyuan, an individual may withdraw consent to the collection, use or disclosure of his or her personal information. Upon receipt of this withdrawal, Aoyuan will notify the individual of the likely consequences of withdrawing his or her consent. Except where otherwise required or permitted by law, Aoyuan will then stop collecting, using or disclosing the individual’s personal information.

3.Limits to the Collection of Personal Information

 Except where required or permitted by law, Aoyuan will limit the collection of personal information to that which is necessary to fulfill the purposes for which it is collected. Personal information will be collected by fair and lawful means.

4.  Use, Disclosure and Retention

 Aoyuan will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Once the information is no longer required to fulfill its intended purposes, and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed, erased or made anonymous.

By “opting-in” the individual has given express consent to Aoyuan sending mail, emails, text or social media (WeChat or Facebook) messages through the information provided, promotional messages such as newsletters, announcements, press releases and event invitations regarding their current and future products and services.

By “opting-in” the individual consents to receiving calls or text or social media (WeChat or Facebook) messages by the selected means of contact by or on behalf of members of Aoyuan at that number to discuss t current and future products and services.

Individuals may withdraw their consent at any time.

Aoyuan may be reached by email at Toronto@aoyuangroup.com, or at the following mailing address: Ontario Aoyuan Property Limited, 1800-145 King Street West, Toronto, M5H 1J8, Attention: Marketing.

Aoyuan may disclose certain personal information to third party service providers and to affiliated entities in order to carry out work on behalf of Aoyuan. Prior to making this disclosure, Aoyuan will take appropriate steps to ensure that such recipients safeguard the personal information and use the information only for authorized purposes.

5.  Accuracy

Aoyuan will make reasonable efforts to ensure that any personal information collected by it, or on its behalf, is accurate and complete if the personal information is likely to be used by Aoyuan to make a decision that affects the individual to whom the personal information relates or if the information is likely to be disclosed to a third party.

6.  Security

 Aoyuan will protect personal information with security safeguards appropriate to the sensitivity of the information. Security safeguards are employed to protect personal information against loss, theft and unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. The nature of these safeguards will vary depending on the sensitivity of the personal information that has been collected. The methods of safeguards include:

  • Physical security measures such as locked filing cabinets and areas
  • Security clearances and limiting access on a “need-to-know” basis
  • Technological measures such as the use of passwords

Aoyuan will inform employees about Aoyuan’s policies and procedures for protecting personal information and employees will be required to conform to Aoyuan’s Privacy Policy.

7.  Openness

Upon request, Aoyuan will make information available about its personal information policies and practices, and its complaint process.

8.  Individual Access

Upon written request, with sufficient detail to enable Aoyuan to identify the individual and the personal information being sought, Aoyuan will inform an individual of the existence, use and disclosure of his or her personal information under Aoyuan’s control and will provide access to that information, unless otherwise prohibited or permitted by law. Aoyuan will respond to all requests within 30 days. Aoyuan may extend the time limit for a further 30 days, or, for a longer period, with the Privacy Commissioner’s permission or as otherwise permitted by law.

Upon written request, an individual may request Aoyuan to correct an error or omission in the personal information that is under Aoyuan’s control. If Aoyuan is satisfied on reasonable grounds that a correction should be made, it will amend the information as requested as soon as reasonably possible, and it will send the corrected information to each organization to which it has disclosed that information during the year prior to the date of correction.

9.  Challenging Compliance
An individual may direct a complaint concerning compliance with the Policy to Aoyuan’s Privacy Officer.

The complaint must be in writing via email or letter. Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the complaint. The format of this investigation will vary depending on the circumstances and may or may not involve an interview of the complainant and/or Aoyuan employees conducted by the Privacy Officer.

Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, that the complaint is either: (a) denied (if, in the Privacy Officer’s opinion, it has no merit); or (b) allowed (if, in the Privacy Officer’s opinion, the complaint is valid).

If the Privacy Officer allows the complaint, Aoyuan will take appropriate measure necessary to rectify the source of the complaint.

Updating this Privacy Policy

 Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. Aoyuan reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy.

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