Effective as of August, 2025
The Centrecorp Management Services Limited (“Centrecorp”, “we”, “our”, and “us”) understands the importance of protecting the personal information of individuals and the importance of securing confidential information of all types. We have created this Privacy Policy (the “Policy”) to demonstrate our commitment to protecting your privacy. This Policy explains:
- what personal information we collect and why we collect it;
- how we use your personal information;
- who we share your personal information with; and
- the choices you have to access, update, and remove your personal information.
Centrecorp as authorized agent for the North American Property Group, a privately owned real estate developer and investor who develops, owns, invests in, and/or manages multi-family apartment buildings, single-family rental projects, retail shopping centres, office buildings, residential developments, and other properties. The types of personal information that we collect and use depends on our line of business and the purpose of your interaction with us. This Policy applies to Centrecop’s collection, use, and disclosure of personal information obtained through this website (“Site”), and through our interactions with you in all our lines of business, including when you visit our properties. This personal information may be obtained directly from you or collected from third parties that have the right to disclose this information to us.
Our Policy regarding how personal information entrusted to us is collected, used, disclosed, or retained reflects the principles set forth in Canada’s Personal Information Protection and Electronic Documents Act, SC 2000, c 5, and any other applicable provincial/state privacy laws that may directly apply to us.
Please note that Centrecorp reserves the right to update or change this Policy at any time. We will notify you of any changes by posting an updated Policy on this Site or as otherwise required in accordance with provincial/state requirements. The most current version of this Policy will govern Centrecorp’s use of your personal information. By continuing to access the Site after changes are made to this Policy, you agree to be bound by the revised terms.
- Consent for Personal Information. By providing Centrecorp with your personal information, including through our Site or any of our forms, you consent to the collection, use, and disclosure of such information in accordance with this Policy or for the purposes identified to you at the time you provided the personal information. Any secondary use of the personal information will only be processed with your express consent, except as required by law. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name and address are provided as part of a rental or leasing application form or when you make a request or inquiry. You have the opportunity to withdraw your consent, or to opt-out at any time. If you wish to withdraw your consent or to opt-out at any time, please contact us as set out in Section 9 below.
- What Information Do We Collect and Why Do We Collect It? The types of information that Centrecorp collects include the following:
2.1. Login Information. If you register for an account on our Site in order to explore investing opportunities with respect to one of real estate developments, you may be asked to provide certain basic information, such as your name, email address, username, password, mailing address, and phone number. We may collect your login credentials for the purpose of the administration of your account. The legal basis for the collection and processing of this information is your express consent and to provide services to you such as to contact you regarding your investments.
2.2. Payment Information and Applications. While we currently do not collect any payment information, in the future if we may collect payment information for the purpose of processing rental payments and the management of lease arrangements from tenants and unitholders, as well as payments for ancillary services provided by our suppliers and vendors. At the point where payment information is collected, our Policy and/or application forms will detail, what information is collected and how this information will be used.
2.3. Communications. You may provide us with contact information for the purpose of receiving marketing communications, including your name, email, and phone number. You can unsubscribe from these communications any time by using the unsubscribe mechanism at the bottom of our emails (if applicable) or by contacting us as set out in Section 9 below. Centrecorp may use your contact information to send you newsletters, emails and other information requested by you regarding Centrecorp news, developments and property updates.
2.4. Customer Service. When you contact us with a comment, question, or complaint, you may be asked for information that identifies you (such as your name, address, and a phone number) along with additional information we need to help us promptly answer your question. The legal basis for the collection and processing of this information is to respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service, product and service offerings, and promotions.
2.5. Device Information. When you visit the Site, we may automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with our Site. The legal basis for the collection and processing of this information is our legitimate business interests, which in this case is to enable us to properly administer our Site and our business and to improve customer service.
Please note that this is not a comprehensive list of the purposes for which we collect personal information. It is an overview of the activities that Centrecorp engages in when we collect, use, or disclose personal information and the reasons why we collect such information.
- Methods of Collection. Centrecorp collects personal information through the following methods:
3.1. Direct Interactions. You may give us your personal information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes, but is not limited to, personal information you provide when you: (i) create an investor profile with us; (ii) sign-up to receive our communications; (iii) contact us with a question, comment, or complaint; or (iv) provide us with feedback.
3.2. Cookies and Automatic Data Collection Technologies. As you interact with our Site, we may automatically collect technical data about your equipment, browsing actions, and patterns by using “cookies” and other similar tracking technologies. A cookie is a small text file sent from a website and stored on the user’s computer by the user’s web browser. Upon visiting a site that uses cookies, a cookie is downloaded onto your computer or mobile device. The next time you visit that site, your device will remember useful information such as preferences, visited pages, or logging in options. Cookies are widely used to add functionality to websites, or to ensure they work more efficiently. Our Site may rely on cookies to optimize the user experience and ensure the Site functions properly. Most web browsers allow some control to restrict or block cookies through the browser settings. However, if you disable cookies you may find this affects your ability to use certain parts of our Site. For more information about cookies please visit https://www.aboutcookies.org. In all circumstances, Centrecorp will comply with provincial and state requirements regarding the use of cookies, including any requirements to “opt-in”.
The information we collect when you visit our Site helps us analyze and improve the performance of our digital services and provides a more personalized service when you browse our Site. We may use third party advertising partners to provide Site users with relevant ads and Google Analytics for web statistical analysis. You may opt out of being tracked by Google Analytics by disabling or refusing the cookies, or by installing the Google Analytics opt-out browser add-on located at https://tools.google.com/dlpage/gaoptout.
Depending on your geographic location, we may be required by law to provide you with specific notice or obtain your opt-in consent before using certain advertising and analytics cookies to provide you with interest-based advertising. You can opt-out of interest-based advertising by visiting the opt-out tool made available by the Digital Advertising Alliance of Canada at https://youradchoices.ca/choices/.
- Use and Disclosure of Personal Information
4.1. Personal information submitted to Centrecorp, including through Centrecorp’s Site or a prescribed form, is kept confidential unless disclosed in accordance with your express consent or legal requirements. In any event, any personal information provided on any Centrecorp platform by a user is voluntary. Please note that revoking your consent may result in not being able to access or utilize certain Centrecorp features, or services. While not currently used, in the event that Centrecorp employs the use of AI or machine learning tools to process information, there are certain risks associated with the operation of such tool and the protection of information used through these tools.
4.2. Centrecorp collects and processes personal information in accordance with this Policy. Personal information provided by users will not be sold, shared, or rented to outside the organization, except as set out in this Policy. Centrecorp reserves the right to contact any user at any time to forward information, respond to questions, or provide notification of any changes to our services or our policies.
4.3. Service Provider Arrangements. Centrecorp currently uses outside service providers with respect to its Site and services including the operation of the Site. To the extent that any personal information is provided to these third party service providers, Centrecorp requires that the provider be bound by obligations consistent with this Policy and that such providers only collect, use, or disclose users’ personal information for the purposes of providing Centrecorp services. If any third party collects your personal information, then they will have their own policies regarding the use of personal information and we advise users that their policies should be reviewed carefully as they may differ from this Policy.
Cross-Border Transfers. Personal information we manage may be transferred, processed, and stored outside of your province of residence, including Quebec, and in a country other than the country in which you provided the information, including the United States and other countries. While we take measures to appropriately safeguard and protect your personal information, your personal information may be subject to the legal jurisdiction of foreign countries and governmental authorities.
4.4. Sale of Business. We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or substantially all of Centrecop’s assets or as part of a corporate reorganization or other change in corporate control. We may also transfer records containing information that we have about you to a new property manager if a property is sold or no longer managed by Centrecop.
4.5. Legal. NADG may disclose your personal information to meet its legal obligations, including: (i) to fulfill its regulatory reporting obligations; (ii) in response to a search warrant or other legally valid inquiry or order; (iii) to an investigative body in the case of a breach of an agreement or contravention of law; (iv) where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property; or (v) as otherwise required or permitted by applicable laws.
- Your Rights and Access
5.1. Accuracy. Centrecorp strives to collect and maintain the most accurate personal information available. However, if you demonstrate that your personal information in our records is inaccurate, you have the right to request the update and correction of such inaccuracies in accordance with Section 5.3 below.
5.2. Right to Access. You have the right to access personal information that Centrecorp processes about you. You can request from us information about:
- the personal information we hold about you;
- the categories of personal information concerned;
- the purposes of the processing;
- details to whom your personal information has been/will be disclosed;
- how long we retain your personal information;
- if we did not collect the information directly from you, information about the source; and
- how to lodge a complaint with the correct supervisory authority.
5.3. Right to Request the Update and Correction of Inaccuracies. You have the right to request the update and correction of inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by applicable laws. You may request the updating and correction of inaccuracies in your personal information we have in our custody or control by emailing or writing to us at the contact information set out in Section 9 below. We may require certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
5.4. Right to Request Deletion. You have the right to request that we delete/erase your personal information in accordance with applicable laws.
- Links to Other Sites. Our Site may contain links to other sites that Centrecorp does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have any control over such websites, and, therefore, we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, or otherwise treat your personal information.
- Security and Breach. Centrecorp has employed administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. It is important to remember that no method of transmitting or storing data is completely secure. Mail, voice communications, faxes, and data transmissions over the Internet are all susceptible to possible loss, misrouting, interception, and misuse of the information being communicated or transmitted. You can prevent unauthorized access to your account and personal information by selecting and securing your password properly and limiting access to your computer, device, and browser. You should always log out after accessing your account. Centrecorp shall provide users with reasonable assistance in complying with applicable laws with respect to any unauthorized use, access, or disclosure of personal information.
- Retention. Centrecorp only retains personal information for as long as it is necessary for the purposes for which it was collected. When personal information is no longer required for these purposes, it is securely destroyed or deleted. For further details on our data retention periods, please contact us.
- Access, Questions, and Concerns. For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact our Privacy Officer, who can be reached by email at legal@nadg.com, by mail at Legal Services, 2851 John Street, Suite 1, Markham, Ontario, L3R 5R7 or by phone at (905) 477-9200.