Privacy Policy

BRIXTON PRIVACY STATEMENT

This Privacy Statement has been adopted by Brixton Commercial, and all its associated and related
companies, (referred to collectively as “BRIXTON”).

At BRIXTON, your privacy is very important to us. We want you to feel secure about any private
information you provide to us. As part of our ongoing effort to keep you informed about our privacy
practices, we have prepared this policy to inform you about BRIXTON’s commitment to ensuring
that the Personal Information obtained during our activities remains accurate and confidential.

The provision of Personal Information to BRIXTON means that the person concerned agrees and
consents that we may collect, use, and disclose their Personal Information in accordance with this
Policy. In addition, where appropriate, specific authorizations or consents may be obtained from
time to time.

In most cases and subject to legal and contractual restrictions, an individual is free to refuse or
withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that
certain services can only be offered if a person provides Personal Information to BRIXTON.
Consequently, if an individual chooses not to provide us with any required Personal Information, we
may not be able to offer the services requested. We will inform you of the consequences of the
withdrawal of consent.

WHAT IS “PERSONAL INFORMATION”?

BRIXTON endeavours to ensure that any Personal Information provided and, in its possession, is as
accurate, current, and complete as necessary for the purposes for which we use that information. If
we become aware that Personal Information is inaccurate, incomplete, or out of date, BRIXTON will
revise the Personal Information and, if necessary, use its best efforts to inform third parties which
were provided with inaccurate information so that those third parties may also correct their
records. Your personal information is retained only if we need it to effectively provide products and
services to you, and for a reasonable length of time thereafter, in case we need to complete
obligations to you, or meet any potential legal and/or government requirements. BRIXTON shall use
care when storing or destroying your personal information to prevent unauthorized access.

WHY BRIXTON MAY COLLECT PERSONAL INFORMATION

BRIXTON may collect and use the Personal Information provided verbally or in writing (including via
electronic media) by customers, consultants, strategic partners, agents, distributors, suppliers,
contractors, and other companies (including their employees) to:

  • Market and sell BRIXTON exclusive listings and services.
  • Conduct, process, and complete real estate transactions.
  • Communicate with, and provide information to, BRIXTON customers and others about new products, services and offers that may be of interest to individuals.
  • Manage our relationship with, among others, BRIXTON customers, consultants, strategic partners, agents, distributors, suppliers, contractors, and other companies.
  • Determining customer eligibility for financing properties and services, including identifying guarantors; assessing applications and conducting initial and periodic credit checks.
  • Where circumstances require, collecting amounts outstanding from customers and those providing security for customers.
  • Meeting legal and regulatory requirements; and such other purposes consistent with these purposes.

The personal information we ask for will depend upon which product or service you seek to obtain.
All information is collected on a voluntary basis both online or offline, over the telephone, or faceto-face meetings and visits. BRIXTON generally collects such information using Registration Forms,
Questionnaires and Surveys, Agreements of Purchase and Sale and Lease and related real estate
transaction documents.

Knowing you better helps us understand your needs ultimately providing you with the service you
expect.

BRIXTON only collects, uses, and discloses Personal Information for purposes that would be
considered reasonable in the circumstances and only such information as is required for the
purposes of providing products, services, or information to customers. We use only fair and lawful
methods to collect Personal Information.

Our use of Personal Information is limited to the purposes described in this Policy and BRIXTON
does not sell, trade, barter, exchange or disclose for consideration any Personal Information it has
obtained. BRIXTON also does not provide Personal Information to any non-affiliated company for
marketing or solicitation purposes unless you have given your consent to such use and disclosure.

WHEN BRIXTON MAY DISCLOSE YOUR PERSONAL INFORMATION

BRIXTON may disclose your Personal Information to individuals or organizations:

  • Who are other BRIXTON companies (where permitted by law) that wish to tell you about their products or services or to inform you about other opportunities, and their related service providers, except when you indicate otherwise.
  • Who are credit bureaus or Personal Information agents involved in determining initial and ongoing customer eligibility for products and services.
  • Who are advisers of the person concerned (e.g., lawyers, inspectors, etc.) or who work for such advisors.
  • Involved in
    • Providing, managing, or administering products or services intended to inform individuals about BRIXTON products or services.
    • Maintaining, reviewing, and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems.
    • A transfer of all or part of the assets or business of BRIXTON, including in connection with the securitization, sale, assignment and/or financing of our transactions; or
    • A corporate re-organization of BRIXTON or any corporation owned by BRIXTON.

In the event sensitive Personal Information is provided to BRIXTON, we will not disclose such
Personal Information unless it is required to provide a customer with products or services.
Where BRIXTON discloses Personal Information to organizations that perform services on its behalf,
we will require those service providers to use such information solely for the purposes of providing
services to the person concerned or BRIXTON and to have appropriate safeguards for the protection
of that Personal Information.
Where Personal Information may be subject to transfer to another organization in contemplation of
a merger, sale of BRIXTON assets or BRIXTON business units or change of ownership of all or part of
BRIXTON, we will do this only if the parties have entered into an agreement under which the
collection, use and disclosure of the information (including any Personal Information) is restricted
to those purposes that relate to the business transaction, including a determination whether or not
to proceed with the business transaction, and is to be used by the parties to carry out and complete
the business transaction.

Please note that there are circumstances where the use and/or disclosure of Personal Information
may be justified or permitted or where BRIXTON is obliged to disclose information without consent.
Such circumstances may include:

  • Where required by law or by order or requirement of a court, administrative agency, or governmental tribunal.
  • Where BRIXTON believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group.
  • Where it is necessary to establish or collect monies owing to BRIXTON.
  • Where it is necessary to permit BRIXTON to pursue available remedies or limit any damages that we may sustain; or
  • Where the information is public.
  • Where obliged or permitted to disclose information without consent, BRIXTON will not disclose more information than is required.

CONSENT

Unless permitted by law, no Personal Information is collected, without first obtaining the consent of
the individual concerned to the collection, use and disclosure of that information. However, we may
seek consent to use and disclose Personal Information after it has been collected in those cases
where BRIXTON wishes to use the information for a purpose not identified in this Privacy Statement
or not previously identified or for which the individual concerned has not previously consented.

ACCESSING YOUR PERSONAL INFORMATION

BRIXTON permits the reasonable right of access and review of Personal Information held by us
about an individual and will endeavour to provide the information in question within a reasonable
time and no later than 30 days following the request. To guard against fraudulent requests for
access, we may require sufficient information to allow us to confirm that the person making the
request is authorized to do so before granting access or making corrections.

We will provide information from our records in a form that is easy to understand. BRIXTON
reserves the right not to change any Personal Information but will append any alternative text the
individual concerned believes to be appropriate.


BRIXTON reserves the right to decline to provide access to Personal Information where the
information requested:

  • Would disclose
    • Personal Information, including opinions, about another individual or about a deceased individual; or
    • trade secrets or other business confidential information that may harm BRIXTON or the competitive position of a third party
  • Is subject to solicitor-client or litigation privilege.
  • Is not readily retrievable and the burden or cost of providing would be disproportionate to
  • the nature or value of the information.
  • Does not exist, is not held, or cannot be found by BRIXTON.
  • Could reasonably result in
    • Serious harm to the treatment or recovery of the individual concerned
    • Serious emotional harm to the individual concerned or another individual, or
    • Serious bodily harm to another individual;
  • May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or May be restricted under applicable legislation. Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure. BRIXTON will not respond to repetitious or vexatious requests for access and in making such a determination, we will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information. BRIXTON will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.

As you browse BRIXTON’s website, advertising cookies will be placed on your computer so that we
can understand what you are interested in. Our display advertising partners then enable us to
present you with retargeting advertising on other sites based on your previous interaction with
BRIXTON’s website. The techniques our partners employ does not collect personal information such
as your name, email address, postal address, or telephone number. You can manage your cookie
settings within your browser’s configuration.

COMMENTS AND QUESTIONS

Updated versions of this Privacy Statement will be posted on BRIXTON’s website at
www.brixtoncommercial.com/privacy, or you can direct any queries about this Privacy Statement to
the Privacy Officer at BRIXTON Realty Inc., Brokerage at the telephone, email address or mailing
address listed below.
For more information, to make enquiries, to file a complaint, or to withdraw your consent where
you wish to do so, please contact –

BRIXTON COMMERCIAL

71 Villarboit, Unit 1
Vaughan, Ontario L4K 4K2
Telephone: (416) 492-8700

Email: [email protected]