Privacy Policy

At Anthem Properties Group Ltd., we are committed to protecting your Personal Information and complying with applicable data protection and privacy laws. This Privacy Policy governs use of Personal Information by Anthem Properties Group Ltd. and its affiliates (collectively, “Anthem”) whether such information is collected via our website anthemproperties.com, other websites and customer portals operated by Anthem (collectively, the “Sites”) or otherwise, including through provision of our services (collectively, the “Services”).

This Privacy Policy is designed to help you understand the types of information we obtain from you and how we use, disclose and protect that information. In this Privacy Policy, each of the terms “we”, “our” and “us” refers to Anthem and each of the terms “you”, “user”, and “your” refer to a visitor of the Sites or a user of our Services.

By submitting Personal Information to us or by otherwise using any of our Services or our Sites, you acknowledge and agree that your Personal Information may be used and disclosed by us in accordance with this Privacy Policy. In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as your name, image, address, date of birth, contact information (including home telephone number and personal e-mail address), employment status, and income, the processing of which is subject to applicable data protection laws (which may include data privacy laws in Canada and certain U.S. states). Please note that not all information that you share with us is considered Personal Information. For example, personal information in Canada does not include information to enable an individual at a place of business to be contacted, such as their name, position name or title, business telephone number, business address, or business email address. Information about you that does not qualify as “personal information” or “personal data” under applicable data protection laws is not covered by this Privacy Policy.

Further, if you are not of the age of majority in your place of residence, please do not use the Sites or our Services.

We recommend that you take the time to read this Privacy Policy so that you understand how we handle Personal Information. We may update or modify this Privacy Policy at any time by posting the revised Privacy Policy to the Sites and, if we have your contact details, notifying you of those updates. We will include a “last revised” date on the Privacy Policy as displayed on the Sites and strongly encourage you to refer back to the Privacy Policy periodically.

1. How we Collect and Use Personal Information

We collect Personal Information from you for specific and limited purposes, where you consent to the collection, in order to meet our contractual commitments to you and to comply with our legal obligations. When collecting Personal Information from you, we will identify the purpose for collecting your Personal Information at the time we request it and will not use or disclose your Personal Information other than for the purpose for which it was collected, without your prior consent or as otherwise permitted by applicable data protection and privacy laws. We endeavor to collect the minimum amount of Personal Information required to fulfil the purpose for which it was collected.

If you choose to withhold any Personal Information requested by us or withdraw your consent, it may not be possible for us to provide the Services to you or respond to your query.

We collect and use your Personal Information in a variety of ways, including for the following purposes:

• Providing Services and Sharing Information. Your Personal Information may be collected and used by Anthem to provide Services to you or via our Sites, or otherwise. Your Personal Information may be used by Anthem so that we can share information about Anthem, the Sites and our Services with you and to maintain appropriate records for our internal administrative purposes. We may use your Personal Information to communicate with inquiries for information, service requests, employment opportunities or other issues as they relate to your use of the Sites and the Services.
• Project Information. For certain projects being promoted via the Sites, we may permit you to register your interest in such projects and to obtain further information about the project by completing a form and making a submission via the Sites. You may also provide your Personal Information to us by completing a form in one of our properties. In these cases, we will use the information obtained for the purpose of facilitating communication with you about the registered project and any future Anthem projects. We may also use the information to allow us to tailor our future projects to meet your interests.
• Service/Warranty Requests: If you choose to contact Anthem through the Sites with service or warranty related requests, your Personal Information will be used to respond to and address your service and warranty requests, including providing your Personal Information to our agents or contractors to complete any applicable warranty or service related work.
• Protection Purposes: We may also use your Personal Information to detect, prevent or investigate security breaches or fraud, to protect our business and to maintain appropriate records for internal administrative purposes, including analyzing and monitoring usage of our Sites.
• Service Analysis, Automated Collection: We automatically record certain information when you use our Sites. We may use permanent cookies or server-side artifacts to help us track use of our services by users, including casual visitors to the Sites—such as the number and frequency of visits to our pages and which parts of our Sites are visited.

Note that much of this information is not considered Personal Information, under applicable laws. Accordingly, we will comply with our legal obligations regarding such information.

Wherever you have given us your consent to use your Personal Information, you may withdraw your consent at any time by contacting our Privacy Officer at privacy@anthemproperties.com. You may no longer be able to access some or all of our Sites or the Services if you withdraw your consent.

2. Our Disclosure of Personal Information

Anthem may disclose your Personal Information with your express consent, for debt collection purposes, for loss or fraud prevention purposes or for Anthem’s other legitimate interests. Anthem may further disclose Personal Information if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. We will use reasonable efforts to ensure that require that any third party to whom Personal Information is disclosed provides a comparable level of protection for your Personal Information, as provided in this Privacy Policy.

We also share some of your Personal Information with third parties in order to offer the Services to you, including sending information to third party service providers that help us to operate our Sites including website hosting, data analysis, event logging, information technology, customer service, user analytics, and email delivery and messaging. We will also share your Personal Information with third party providers of marketing services who will assist us with promotional services. Depending on where you live, this sharing of Personal Information could be considered a “sale” or commercial sharing of data. Some of our third-party marketing service providers allow users to opt out manually – for example, you may opt out of Google Analytics by going to https://www.google.com/policies/privacy/partners and downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Additionally, Anthem reserves the right to disclose and to transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, merger, amalgamation, or any other type of acquisition, disposition, or financing of all or any portion of Anthem or any of the assets or shares of Anthem, provided that the third party represents that it will continue to use the information for the purposes set out in this Privacy Policy and in accordance with applicable privacy laws. Anthem also reserves the right to aggregate and anonymize Personal Information (or other information) stored on its system and use such aggregated and anonymized Personal Information (or other information) as it sees fit.

3. Consent

It is important to us that we collect, use or disclose your Personal Information only where we have your consent to do so or as provided in this Policy. Depending on the sensitivity of the Personal Information, your consent may be express, implied or deemed. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you contact us about our Services, we will assume your consent to the collection, use and disclosure of your Personal Information for purposes related to your request or for other purposes identified to you at the relevant time. Deemed consent is consent we assume in the event that you do not exercise an opt-out mechanism offered to you.

By submitting your Personal Information to us or obtaining our Services, you consent to the collection, use and disclosure of your Personal Information in the manner described in this Policy. To the extent that we are required by applicable laws to obtain your explicit consent for the collection, use or disclosure of your Personal Information in accordance with this Policy, such consent will be requested at the appropriate time. Further, if we plan to use or disclose your Personal Information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure. However, we may collect, use or disclose your Personal Information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the office of our Privacy Officer using the contact information set out below. In some circumstances, a change or withdrawal of consent may limit our ability to provide Services to you or your ability to access certain areas of our Sites.

We assume, unless you advise us otherwise, that by receiving a copy of this Policy or by continuing to deal with us, you have consented to the collection, use and disclosure of your Personal Information as explained in this Policy.

4. Retention of Personal Information

We routinely destroy Personal Information that is no longer required for the purposes for which it was collected, in accordance with applicable laws.

5. Accuracy of Personal Information

Anthem takes reasonable steps to ensure that any Personal Information in our custody is accurate and up to date for the purposes for which the Personal Information is to be used by Anthem. In most instances, we rely on users of our Services to notify us of any changes to their Personal Information provided by them.

6. How we protect your Personal Information

Anthem uses reasonable and appropriate measures, including encryption software, designed to help you secure your Personal Information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the Personal Information collected by us are authorized to do so. Unauthorized use of Personal Information by anyone affiliated with Anthem is prohibited and constitutes grounds for disciplinary action.

Anthem is not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks. Anthem also is not responsible for any failure by you to eliminate malware. These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.

7. Location of Personal Information

Personal information we collect is stored and processed by us and our third party service providers primarily in Canada, regardless of where you are located.

8. Links to Third Party Sites

The use of our Sites may lead you to third party websites. Those organizations are separate and distinct from Anthem and have their own separate privacy policies. We are not responsible in any way for how any third party collects, uses or discloses your Personal Information, so it is important to familiarize yourself with the privacy policies of these websites before providing your Personal Information to them.

9. Cookies and similar technologies

We use cookies on the Sites to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Sites and otherwise to improve our Sites on an ongoing basis. The Sites also use cookies to provide users with certain features and preference settings. A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. It functions as your identification card. It is not a program and cannot be executed as code or deliver viruses. Cookies can also customize the site to your particular interests or store your Personal Information – like passwords or user IDs. If a site ever greets you with your name, chances are it is using a cookie to do so.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie – this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser. The alerts will be quite frequent, however, and may eventually become annoying. You can use the Sites without cookies, but you may have to re-enter information each time you visit.

Note that we also use cookies for cross-device tracking and cross-contextual advertising purposes. These cookies are disclosed to our advertising providers, who use them to serve targeted advertising to devices connected to you via cross-device tracking. For example, when you visit our Sites, Google Analytics adds a cookie to distinguish you from other users and track your behavior across our Sites. We use this information to improve the user experience of the Sites. The cookie lasts for up to 2 years. You can read about this in the Google Analytics Privacy Policy.

With your permission, the Sites utilize the Conversion Tracking Pixel service of Meta Platforms Inc. on Facebook (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remains anonymous. This means we cannot see the collected data of any individual user.

However, the collected data is saved and processed by Facebook. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/.

Meta Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside of Facebook. In addition, a cookie will be saved to your computer for these purposes. Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/

Similarly, we may also collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our service, the website that referred you to one of our Sites, the web pages you requested and the subject of the ads you click or scroll over, and use such information to evaluate service performance and service quality and to optimize the user’s experience of our Sites. To collect this information, we use cookies, web beacons and similar technologies.

10. Direct Marketing

We are committed to complying with Canada’s Anti-Spam Legislation. Where we have your consent or it is lawful to do so, we may provide you with direct marketing communications about our Services which may be of interest to you. Such information may be sent to you by post, email, telephone or SMS.

You may sign up to receive marketing or promotional communications from us. Where you have opted in, we may use your Personal Information to inform you about us and our services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

• using the unsubscribe feature found in our emails and other electronic communications; or
• contacting us via email at info@anthemproperties.com.

11. Data Privacy Laws Outside of Canada

As of the “Last Revised” date indicated on this page, Anthem is not subject to the General Data Protection Regulation of the European Union or the United Kingdom, nor to any state-level data privacy laws of the U.S. in effect as of that date (including California, Connecticut, Colorado, Iowa, Montana, Oregon, Texas, Utah, or Virginia). Our Services are hosted in North America, and we transfer and process Personal Information from and to the United States and Canada. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. or Canadian laws, then please note that you are transferring your Personal Information outside of those regions to the United States and to Canada for storage and processing. We may also transfer your Personal Information from North America to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including Personal Information, on or to our Services, you consent to such transfer, storage, and processing.

Additionally, we may share certain Personal Information for cross-context behavioral advertising to show you targeted advertisements; however, we do not knowingly “sell” or “share” (as those terms are defined by U.S. data privacy laws) Personal Information about consumers under the age of 16.

12. Opt-Out Preferences

Note that some web browsers and mobile applications include Do-Not-Track (“DNT”) features or settings which allow users to signal their preferences with respect to the collection of data regarding their online activities. As of the “Last Revised” date below, no uniform technology standard for recognizing and implementing DNT signals has been adopted. As such, our Services do not currently respond to DNT features, settings, or signals

13. Your Rights

Upon written request to our Privacy Officer at @privacy@anthemproperties.com, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to that Personal Information. Anthem provides an opportunity for individuals to challenge the accuracy and completeness of their Personal Information and have it amended as appropriate.

14. Contacting us

Accountability with respect to your Personal Information is important to Anthem. In the event that you have any questions (including how Personal Information is managed by Anthem), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our Privacy Officer at privacy@anthemproperties.com.