Privacy Policy

Brookfield Homes Ontario Limited and its subsidiaries (hereinafter "Brookfield Homes"), respects the privacy of its clients, prospective clients and others and are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that Brookfield Homes continues to meet its commitment to your privacy.  The following sections, read as a whole, comprise the Brookfield Homes Privacy Policy:

Introduction

Brookfield Homes Ontario Limited is a homebuilder and land developer for a number of high quality communities. In the course of providing these products and services, Brookfield Homes may collect, with their consent, certain personal information from its clients, prospective clients and others.

"Personal Information" means information about an identifiable individual. This may include without limitation, the individual's name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.  This Privacy Policy is based on, and complies with, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the National Standard of Canada entitled Model Code for the Protection of Personal Information and similar provincial legislation.

This Privacy Policy sets out the ten principles that Brookfield Homes follows to ensure that we protect our clients' and employees' personal information when we collect, use or disclose it in the course of carrying on commercial activities in Canada. These correspond to similar principles contained in PIPEDA. All of our employees who have access to personal information must adhere to the Brookfield Homes Privacy Policy and related procedures.

Brookfield Homes' Dedication to the the Ten Principles of Privacy

The following ten principles govern our actions as they relate to the use of personal information of our clients, prospective clients and others:

Principle 1 - Accountability
Principle 2 - Identifying Purposes
Principle 3 - Consent
Principle 4 - Limiting Collection
Principle 5 - Limiting Use, Disclosure and Retention
Principle 6 - Accuracy
Principle 7 - Safeguards
Principle 8 - Openness
Principle 9 - Individual Access
Principle 10 - Questions and Concerns

Principle 1 - Accountability

Brookfield Homes is accountable for all personal information in its possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients, prospective clients or others. To this end, Brookfield Homes has appointed a Privacy Officer who has ultimate responsibility for ensuring compliance within Brookfield Homes and by all Brookfield Homes employees. Through its policies and procedures, Brookfield Homes will strive to implement this Privacy Policy throughout all of its operations.

Principle 2 - Identifying Purposes

Brookfield Homes will identify the purposes for which it is collecting any personal information by such means as is appropriate in the circumstances. This may include providing disclosure orally, by telephone, or in person, providing disclosure in a customer sales contract or in other written information given to a customer, posting a notice on Brookfield Homes' website or any other means deemed appropriate in the circumstances.  Note: In some instances, where the purpose for collecting information is reasonably evident to the person providing the information, the purpose will be implied but not explicitly stated (for instance, when a potential client provides us with his or her contact information in a model house or showroom).

Principle 3 - Consent

Brookfield Homes will seek to obtain consent from its clients before or when it collects, uses or discloses their personal information except as described below. Brookfield Homes will strive to ensure that individuals understand how their personal information will be used or disclosed.  Consent can be expressed (i.e. given orally, electronically or in writing), implied or given through an authorized representative. Consent may be implicit when the purposes are not stated expressly but are implied by the circumstances of the transaction or follow logically from other expressly stated purposes). You can withdraw consent at any time, with certain exceptions (for example, subject to any legal or contractual restrictions) and upon reasonable notice to Brookfield Homes. Brookfield Homes will strive to inform an individual of all implications of withdrawing their consent. Clients, prospective clients and others may contact Brookfield Homes' Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by Brookfield Homes may be used, disclosed or retained. Note that information may be retained by Brookfield Homes for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.  Brookfield Homes, however, may collect, use or disclose personal information without the client's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

Principle 4 - Limiting Collection

Brookfield Homes will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention

Personal information will only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, Brookfield Homes may have a legal duty or right to disclose personal information without client knowledge or consent with respect to matters that concern the company's or the public's interest.

Principle 6 - Accuracy

Brookfield Homes will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Brookfield Homes will update or correct any personal information held by it if the individual concerned provides Brookfield Homes with particulars, satisfactory to it, of any required updating or correction.

Principle 7 - Safeguarding Personal Information

Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.  Brookfield Homes has controls in place to maintain the security of its information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

Principle 8 - Openness

Brookfield Homes will make information available to its clients and others about the policies and procedures Brookfield Homes uses to manage personal information. Clients have access to much of this information through our web site, or through written correspondence with Brookfield Homes' Privacy Officer.

Principle 9 - Individual Access

As a client or prospective client, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate.  If you would like to view the personal information held in your file, please make a written request to Brookfield Homes' Privacy Officer. Brookfield Homes will respond to your request as efficiently as possible and will advise of the individual cost, if any, prior to the retrieval of such records. Brookfield Homes will not respond to frivolous or vexations requests for access to information. If Brookfield Homes is prohibited from providing such access we will explain the reasons, except where prohibited by law. To make a change to your personal information (as discussed under 'Accuracy' above), please make a similar request in writing to the Privacy Officer.

Principle 10 - Questions or Concerns

Brookfield Homes has policies and procedures to receive, investigate and respond to any questions or concerns respecting this Privacy Policy or the personal information that we hold. Clients may contact the Brookfield Homes' Privacy Officer with any questions or concerns or to request access to their personal information.

Specific Information about our Use and Disclosure of Your Personal Information:

The Kind of Information We Collect:

Brookfield Homes gathers and uses personal information as described below. Providing us with your personal information is your choice; however, we may not be able to provide you with certain products or services if you do not provide us with certain information. For example, we may not be able to provide you with certain products or services if we do not have your contact information.  The nature of our relationship with you will determine the kind of personal information we might ask for.  Information that is typically required to provide you with our products and services includes, but is not limited to:

Name
Address
E-mail address
Phone Number(s) and Fax Number
Buying range
Home preferences and requirements
Products and Purchase Information

In addition, other information as set out in the definition of personal information (above), may also be collected from time to time.  Brookfield Homes may keep a file with your contact history to be used for client inquiry purposes so that we may ensure that you are satisfied with the products and services which we have provided to you.

How Your Information Is Used

At Brookfield Homes we use your personal information as follows:

To provide you with information regarding the sale (or potential sale) of our Homes
To construt our Homes.

Some services may be provided by third party suppliers to better serve your needs.

Brookfield Homes will keep a record of the purposes for which any information is collected and will not use, retain or disclose that information for other purposes. If it proposes to use, retain or disclose the information for different purposes, it will identify those purposes to the person who has provided the information and will obtain his or her consent before using the information for such purpose.

When Do We Disclose or Share Your Personal Information?

(i) When Authorized By You

Many of the services offered by Brookfield Homes require us to obtain personal information about you in order to perform the services we have been engaged by you to provide. We will use and disclose this information to provide programs to meet your needs and objectives.

(ii) With Brookfield Homes Service Suppliers

We may engage and coordinate third party suppliers to provide you with certain services offered through Brookfield Homes. We use third party suppliers to provide services such as home-related maintenance and construction services.  Such suppliers are only given the information that is needed to provide the specific service for which we contract them to provide. The information that is given to these service providers is generally limited to name, address, phone number, homes preferences and requirements and product information.  Suppliers are required to protect the confidentiality of your personal information, and they are prohibited from doing anything with this information that we have not authorized them to do.

(iii) When Required or Permitted By Law

The type of information we are legally required to disclose usually relates to government tax reporting requirements. However in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information. Brookfield Homes may also disclose information without your consent when permitted by law including in situations involving medical emergencies, collection of a debt and suspicion of illegal activities.

Web Site (Security)

In order to serve you better, Brookfield Homes offers clients access to certain information through its web sites. http://www.brookfieldhomes.ca provides general information about the Company and the products and services it offers. Included in this website is the option to register on-line to receive more information about a certain community. If you visit the Company website, please refer to the Brookfield Homes Web Site Privacy Policy which can be found under Terms and Conditions.  Brookfield Homes is committed to your privacy and strives to ensure that any information you access or provide through this site remains secure.

Anonymous Information

Brookfield Homes may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our web servers may record certain information automatically when you visit our web site. This information is collected using "cookies" and might include the pages you visited, your Internet Protocol address and other site usage statistics. This anonymous information is used for research and analytical purposes only (ie. evaluating how many visitors our web sites receive or which pages they visit most often). It does not reveal any personal information about you, the user.  This aggregate data may be disclosed to third parties, but never with personally identifying information.

Contact Information (Questions, Concerns and Complaints)

If you have any questions or concerns about your personal information, or about the Brookfield Homes Privacy Policy, please contact our Privacy Officer using the contact information below:

Contact Information: Privacy Officer, Brookfield Homes, 181 Bay Street, Suite 330, P.O. Box 763, Toronto, ON, M5J 2T3; (email) privacyofficer@brookfieldhomes.com