Welcome Co cares about protecting your personal information. This policy explains what we collect, how we use it, when we share it, and the choices you have. It applies to individuals and third parties who interact with us (for example, applicants, tenants, website visitors, vendors).

We follow Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and any provincial privacy laws that apply.

Privacy Officer: Todd Main — privacy@welcomeco.ca

1) What this policy covers

This policy sets the minimum standards Welcome Co uses to protect personal information. If a law requires stronger protection, we follow the law.

In limited cases, we may collect, use, or share information without consent (for example, for legal, medical, or security reasons; to prevent fraud; or for law-enforcement purposes). We only do this when allowed by law.

2) Key terms

  • Personal Information: Anything that identifies you or could identify you (e.g., contact details, ID numbers, financial and employment info, background checks, medical notes, opinions about you). Information about minors is treated as sensitive.
  • Sensitive Personal Information: Data most people expect to keep private (e.g., health, genetic/biometric data, racial or ethnic origin, sexual orientation, political or religious views, union membership, and any personal information about a minor).
  • Collect: Get information from you or others.
  • Use: Handle information inside Welcome Co.
  • Disclosure/Share: Make information available outside Welcome Co.
  • Consent: Your agreement (express or implied) to collect, use, or share your information.

3) Who is responsible

Welcome Co is responsible for personal information under our control. Our Privacy Officer:

  • Maintains our privacy practices and trains staff
  • Answers questions, requests, and complaints
  • Monitors changes in privacy laws
  • Oversees safeguards, audits, and breach response
  • Coordinates with regulators when needed
  • All Team Members and contractors must follow this policy.

4) What we collect and where it comes from

We only collect what we need for clear, legitimate purposes (see next section). We may collect information:

Directly from you, for example:

  • Phone, email, chat, SMS, website forms, Resident portal accounts
  • Rental (offer to lease) and employment applications
  • In-person meetings or property visits

Automatically, via our website:

  • Cookies and similar tools (see “Cookies” below)

From other sources, when allowed:

  • Credit and collection agencies
  • Current/previous landlords and employers
  • Government agencies and public records
  • Utility and service providers
  • Advertising partners and social media platforms

5) Why we collect and use your information (our purposes)

Typical reasons include:

  • Verifying your identity
  • Processing rental and employment applications (including background and credit checks)
  • Contacting you for WelcomeCo business (e.g., arranging viewings, managing waitlists)
  • Setting up utilities and services (e.g., internet, electricity, gas, phone, alarms)
  • Managing properties and leases (e.g., parking authorization, tenant relations)
  • Handling legal matters (e.g., recovering rent or damages)
  • Doing due diligence on properties and related transactions
  • Meeting legal, tax, and regulatory obligations
  • Completing financial transactions (acquisitions, dispositions, financing)
  • Internal record-keeping, accounting, financial reporting, audits, risk assessments, and investigations

We may update this list as our business or legal obligations change.

6) Your consent

We ask for your knowledge and consent before collecting, using, or sharing your information, unless the law allows an exception (for example, to prevent fraud or respond to lawful requests).

Sometimes consent is express (you say “yes” or sign a form). Sometimes it’s implied (your actions reasonably show agreement), except for Sensitive Personal Information, which generally requires express consent.

If we want to use your information for a new purpose not covered here and not otherwise allowed by law, we’ll tell you and ask for your consent first.

You can withdraw consent at any time, subject to legal or contractual limits. Contact our Privacy Officer to learn the implications and proceed.

7) Limiting what we collect, use, share, and keep

  • We collect only what we need for the purposes above.
  • We use and share information only for those purposes, unless you consent or the law allows otherwise.
  • We keep information only as long as needed. Some records must be kept longer for legal, tax, or audit reasons (for example, we may keep former tenant records for several years). When information is no longer required, we securely destroy, anonymize, or de-identify it.

8) Keeping information accurate

We aim to keep your information accurate and up to date for the purposes we use it. Please let us know if your information changes.

9) How we protect your information

We apply safeguards that match the sensitivity of the information, including:

  • Physical: locked cabinets, secure offices
  • Organizational: limited access, confidentiality obligations
  • Technical: passwords, encryption, other security controls

10) Being open about our practices

At or before collection and anytime you ask, we can tell you:

  • Where your information came from (unless this would compromise a lawful investigation)
  • How we collected it
  • Your rights to access, correct, or withdraw consent and how to do so
  • When an agent collects information for Welcome Co
  • The third parties we must share information with for the listed purposes

We’ll also provide the Privacy Officer’s contact details on request.

11) Your rights: access and correction

You can request:

  • Confirmation that we have information about you and what it is used for
  • A list of types of Welcome Co Team Members who have had access
  • The applicable retention period
  • A copy of your information (subject to legal limits)

You can ask us to correct inaccurate or incomplete information. If we can’t make a change you request, you can ask us to attach a statement of disagreement to your file.

How to request: Email the Privacy Officer. We’ll respond within 30 days or let you know if more time is needed, as permitted by law.

In some situations, we may be legally required to refuse access (for example, if it would reveal another person’s information or confidential details). If we refuse, we’ll explain why, unless the law restricts us from doing so.

12) When we share information

We don’t share your personal information except:

  • With your express consent
  • To provide the service or carry out the purpose for which it was collected
  • When required or permitted by law or regulation
  • To authorized government representatives for law enforcement or regulatory purposes
  • To comply with court orders, warrants, or other lawful processes
  • In emergencies to protect someone’s safety
  • In compassionate situations (e.g., to contact family or friends of someone injured, ill, or deceased)

Third-party requests must be made in writing to the Privacy Officer.

13) Video surveillance and audio recordings

We may use video cameras in common areas of our buildings. They may operate at all times and include features like zoom or night vision. Surveillance of recordings may occur at any time. Where required, signs will tell you that recording is in progress.

We may also make audio recordings during meetings, interviews, or phone calls for purposes such as quality control, training, safety, or resolving disputes. We may share recordings with law enforcement when appropriate and legally permitted.

14) Cookies on our website

We and our vendors (including advertising networks and social media partners) use cookies to:

  • Make the site work (e.g., forms, saving preferences)
  • Improve performance and your experience
  • Show content or ads tailored to you

Some cookies track information over time and across sites.

Your choices: On your first visit, we’ll ask which cookies you want to allow (except those strictly necessary). You can change your choices anytime. Blocking some cookies may affect site features or performance.

Types of cookies:

  • Necessary: Required for the site to function; do not collect personal information.
  • Functional: Enable extra features and personalization; may be set by us or our vendors.
  • Performance: Help us measure and improve the site; data is aggregated and anonymous.
  • Targeting: Set by partners to build a profile of interests and show relevant ads; may involve unique identifiers.

15) Changes to this policy

We may update this policy from time to time. Changes take effect when posted on our website.

16) How to contact us

Privacy Officer: Todd Main

Email: privacy@welcomeco.ca

If you’re not satisfied with our response, you may contact:

  • Privacy Commissioner of Canada — 112 Kent Street, Ottawa, Ontario, K1A 1H3
  • Privacy Commissioner of Alberta — Suite 2460, 801 6 Avenue SW, Calgary, Alberta, T2P 3W2