Arcturus Realty Corporation and its affiliates (“Arcturus”) recognize the importance of privacy and the sensitivity of personal information. This Privacy Policy outlines how we manage personal information whether received in writing, over the telephone, or online. Use of our web site constitutes acceptance of and agreement with this Privacy Policy.
Why Arcturus Collects and Maintains Personal Information
The collection of personal information is integral to Arcturus’ role as a manager of real estate. In such circumstances, if we did not collect personal information we could not provide our services to you or your organization and administer our client databases.
What Personal Information is Collected
"Personal information" is any information that is not publicly available and identifies an individual, or by which an individual's identity could be deduced. For example, in performing certain aspects of our property management and facility management services, Arcturus collects the names, postal addresses, telephone numbers and e-mail addresses of individuals. Please note that "personal information" does not include either aggregate information used for statistical purposes that does not allow an individual to be identified, information about a visit to our web site which is not linked to an individual, information about a computer's operating system and web browser software (this technical information is verified to ensure that our web site is optimized to serve our customers) or, the name, title or business address or phone telephone number of an employee of an organization.
How Personal Information is Collected
Wherever possible, Arcturus collects personal information in a direct active fashion via the execution of applications, forms and other similar documentation.
How Consent is Obtained
In most cases, Arcturus obtains consent in writing to its collection, use, or disclosure of personal information. In some limited circumstances, Arcturus may accept oral consent or consent may be implied through conduct. Consent can be withdrawn at any time by following the directions at the end of this policy.
Use and Disclosure of Personal Information
Personal information provided to Arcturus will remain confidential to Arcturus and its business partners. All of Arcturus’ business partners are required to provide a level of privacy protection comparable to that provided in this policy and are not permitted to use personal information for any other purpose. Arcturus does not sell, rent or trade in personal information.
Arcturus retains personal information for only a period of time which is reasonable under the circumstances, and once personal information is no longer required, it is deleted.
Arcturus will disclose personal information:
- when required or authorized by law to do so;
- when consent to the disclosure has been obtained;
- where it is necessary to establish or collect fees.
Safeguards
Arcturus protects personal information by using appropriate security safeguards to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal. Among the steps taken to protect information are:
- premises security;
- access to personal information is restricted to only those with a need to know;
- deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
- internal password and security policies;
- secure disposal of personal information no longer needed; and
- screening and training of personnel together with appropriate contractual arrangements to protect personal information.
Arcturus cannot, however, guarantee that loss, misuse or unauthorized use will never occur.
Updating Information
Arcturus should be contacted via the process described at the end of this policy and be advised of changes that need to be made to personal information about you or your organization that Arcturus currently has on file.
Access to and Correction of Personal Information
If you wish to access, request a correction to, or have Arcturus discontinue maintenance of any personal information we hold about you or your organization, contact us by using the process described at the end of this policy. Summary information is available on request and Arcturus will attempt to respond to the request within 30 days of receipt. More detailed requests, which require archive or other retrieval costs may be subject to our normal professional and disbursement fees and may require a longer response period.
Arcturus attempts to ensure that personal information it holds is accurate, complete and up-to-date for the purposes for which it is used. If Arcturus holds information about you or your organization, which is established to be inaccurate, incomplete or out of date, Arcturus will take reasonable steps to make corrections.
Denial of Access to Personal Information
We may deny access when:
- denial of access is required or authorized by law;
- information relates to existing or anticipated legal proceedings against you or your organization;
- the information was generated as a result of a formal dispute resolution process including a court case;
- granting you access would have an unreasonable impact on other people's privacy, security or proprietary information;
- protecting Arcturus' rights and property;
- the request is frivolous or vexatious or generates costs which are prohibitively expensive.
If we deny your request for access to, or refuse a request to correct information, we shall do so in writing and explain why.
Communicating with Us
You should be aware that any channel of communication, such as e-mail, is not 100% secure, and you should be aware of this when contacting us to send personal or confidential information using e-mail.
Web Site
For your convenience our web site may contain links to other sites, which are not governed by this Privacy Policy. Our site may also be referenced on or accessible through links contained on other sites, including sites of third party e-procurement networks. However, we have not investigated, and are not responsible for, the privacy practices or content of those sites. Their policies and protections may be different than those offered by Arcturus. We encourage you to investigate and review the privacy practices of those sites prior to use.
On our web site, like most other commercial web sites, 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 of your identifiable personal information.
When you interact with our web site, we may use a browser feature, known as a "cookie" (which is a small computer file), to verify non-identifiable information about visitors to our web site and measure visitor traffic patterns. We do this to maintain the best possible web site. When you first visit our web site, the web site manager may have implemented a program that creates a small computer file stored on your computer's hard drive. We ensure that the minimum information required is placed in the cookie only so that we can recognize returning web site visitors. The cookie does not contain personal information and we will not combine information in the cookie with personal information that would enable us to identify you individually. On subsequent visits to the web site, our server communicates with your computer, reads the cookie, recognizes and confirms that you are a returning visitor. Our server uses this information to provide you with a "short cut" that facilitates the quickest, most efficient and best possible web site experience.
Most browser software allows you to delete cookies. You should consult your ISP for information on how to delete cookies. This may interfere with our ability to personalize your experience at our web site and be recognized, or may slow down performance.
Changes to this Privacy Policy
Since Arcturus regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. A copy of all amendments will be on file at our offices and we will post those changes on our site. Regardless of any changes we make to our Privacy Policy, we will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information unless you give us your consent to do otherwise.
Requests for Access
If you have any questions, complaints or wish to access your personal information, please write to our Chief Privacy Officer at:
Arcturus Realty Corporation
425 Bloor Street East, Suite 400
Toronto, ON, Canada M4W 3R4
Last Update: August 12, 2009