Privacy

(Effective 29-Mar-2019)

New: The Company’s name was formerly European Commercial Real Estate Investment Trust (ECREIT). The website Terms of Use, Cookie Statement and Privacy Policy have been updated.

By submitting information or documents to us during our transactions together, you acknowledge that your Personal Information will be processed in the manner described below.

1. Who are we and what do we do?

We are European Residential Real Estate Investment Trust (“ERES REIT”, the “Company”, “we”, “us” or “our”), a publicly traded (TSX-V: ERE.UN) unincorporated, open-ended real estate investment trust located at 11 Church St., Toronto, ON, Canada, M5E 1W1.  We are accountable for the Personal Information (PII) belonging to individuals that has been entrusted to us. We are committed to protecting individuals’ privacy through practices that limit the collection, use, disclosure, disposition and destruction of Personal Information to what is necessary for the effective operation of our business in Canada, which is to:

• Provide Unitholders with long-term, stable returns, while growing distributable income and Unit value through accretive acquisitions and strong financial management.

2. Definition and examples of Personal Information

Personal Information (“PII”), as defined under PIPEDA, includes any factual or subjective information, recorded or not, about an identifiable individual. Some examples of Personal Information we may collect from you are:

• name, personal address, telephone number(s), personal email address, etc.

3. Purpose(s) for the collection, use and disclosure of your Personal Information

We (or authorized third parties on our behalf) collect and process Personal Information from individuals as categorized below. This may include past, present and prospective:

• Unitholders

• Visitors to this website

• Trustees

• Vendors

We may use (or instruct a third party to use) your Personal Information in the following ways:

1. To provide you with the service(s) you requested;
2. To fulfil an agreement with you;
3. For market research purposes and in order that we may keep you informed (by post, telephone, email, fax or other electronic means) of products and services offered by us and our selected third parties which may be of interest to you. (If you do not wish to be kept informed in this way, please advise us by any convenient means);
4. For statistical analysis relating to the use of our website;
5. We may record telephone conversations to offer you additional security, resolve complaints and improve our service standards. Conversations may also be monitored for staff training purposes.

4. Consent

We collect, use and disclose Personal Information with the knowledge of individuals and their implied or express/explicit consent (except where consent is not required by law, as per below).

If we intend to collect, use or disclose your PII for purposes other than described above, or use your previously collected PII for a new purpose than initially collected, we will inform you and/or obtain consent (unless not required to do so by law).

There are certain limited circumstances where we may (or are required to) collect, use or disclose your PII without your knowledge or consent. E.g. By law, we do not require your consent to use or disclose relevant PII in our records for the purpose of collecting a debt you owe to us, if the information is for the purpose of acting in an emergency that threatens the life, health, or security of an individual, from witness statements where necessary for assessing, processing, or settling an insurance claim, etc.

Your previously granted consent may be withdrawn at any time by notifying the Privacy Officer in writing privacy@ERESreit.com.

5. How do we collect Personal Information relating to you?

We (or a third party on our behalf) may collect information about you in the following ways:

1. directly from you when you visit our website www.eresreit.com, which may include information you provide to us by means of contact forms on the website.
2. from publicly available sources of information.
3. from authorities or public bodies, when legally authorized to do so.
4. otherwise, when you visit our website www.eresreit.com by means of cookies. If we use cookies, information about collection and processing is communicated in a separate Cookie Statement located on our website www.eresreit.com. Website data may include traffic data, location data, web logs and other communication data, and any resources you may access.

6. Do I have to provide my Personal Information?

In most circumstances you are not obligated to provide us with any Personal Information unless we enter into an agreement together. When you make inquiries, we will do our best to use the information you provide, however, in cases where we do not receive adequate information, we may not be able to fulfil the inquiry.

7. With whom do we share your Personal Information?

We may disclose your Personal Information to third party recipients in connection with the above purposes, including:

• to third parties who we engage to provide services to us, such as professional advisers, auditors, insurance companies and outsourced service providers including software and applications providers and consultants, third party brokers, lawyers, etc.;

• to our asset manager, its affiliates and their respective service providers from time to time;

• to our share registrar and its service providers;

• to other members of our corporate group;

• to financial intermediaries and lenders;

• to business partners or investors; or

• to competent regulatory authorities and bodies as requested or required by law.

8. How long will we retain your Personal Information?

We will retain your Personal Information for as long as it is necessary to fulfill the purpose for which it was collected and to comply with applicable laws. After the PII is no longer necessary either for the purpose for which it was collected or to comply with laws and retention periods, it will be securely destroyed, erased, or made anonymous.

9. How do we protect your Personal Information? 

We use physical, technical and organisational security measures to ensure a level of security appropriate to the specific risks that we have identified for the sensitivity of the Personal Information we maintain. E.g. physical locks, secure destruction, system security, encryption, data minimization, etc. Our handling of your Personal Information will respect its confidential nature at all times from the time of its collection until its ultimate disposal or destruction.

10. Access to & Accuracy of your Personal Information

Access to your Personal Information held by us may be requested by contacting the Privacy Officer in writing. Upon such written request, you will: (a) be informed of the existence, use and disclosure of your PII and (b) be given access to that PII. Any questions with regard to requesting access to Personal Information may be addressed to the Privacy Officer.

We make reasonable efforts to maintain the accuracy, completeness and currency of your PII held by us as is necessary to fulfill the purpose for which it was collected and is to be used. We may from time to time ask you to confirm the accuracy of your PII for such purpose(s).

11. Changes to our Privacy Policy

The Company reserves the right to change this Privacy Policy from time to time. If we make a material change, this Privacy Policy will be updated accordingly. We recommend that you periodically review this Privacy Policy, which is available on our website www.ERESreit.com, so that you are aware of any changes. Your continued reading of the Policy and use of our site following the posting of any changes to this Privacy Policy will constitute your acceptance of these changes.

12. Responsibility for compliance with our Privacy Policy

Our Privacy Officer is responsible for overseeing the Company’s compliance with this Policy and may be contacted at:

Contact:

Privacy Officer
ERES REIT, 11 Church Street, Suite 401, Toronto, ON M5E 1W1 Canada
privacy@eresreit.com

13. Questions or concerns about our privacy practices

PIPEDA requires private-sector organizations to collect, use or disclose your Personal Information by fair and lawful means, with your consent, and only for purposes that are stated and reasonable. Please address any questions or concerns about our compliance with this Policy or our privacy practices generally to the Privacy Officer.

If you remain unsatisfied after discussing the matter with our Privacy Officer, you may contact the Privacy Commissioner of Canada at:

Office of the Privacy Commissioner of Canada – 30, Victoria Street, Gatineau, QC, K1A 1H3 Canada

Toll-free: 1-800-282-1376 Phone: (819) 994-5444 TTY: (819) 994-6591  www.priv.gc.ca