Privacy Policy

Last Updated: May 26, 2023

Introduction

Your privacy is important to Leno Developments and its corporate subsidiaries and affiliates (collectively, “Leno Developments”). This Privacy Policy explains how Leno Developments collects, uses, discloses, and retains personal information, including information collected through websites and correspondence and when providing services.

Table of Contents

Your Consent

Personal Information

How Leno Developments Collects Your Personal Information

How Leno Developments Uses Personal Information

How Leno Developments Discloses Personal Information

Your Right to Withdraw

Location of Personal Information

Retention of Personal Information

Protection of Personal Information

Accuracy and Access to Personal Information

Non-Personal Information

Other Websites and Businesses

Social Media

Children and Personal Information

Other Matters

Contacting Us

Your Consent

By providing Leno Developments with your personal information, you consent to the collection, use, disclosure, and retention of that information by Leno Developments and other members of Leno Developments in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to the relevant Leno Developments, but then you might not be able to proceed with your intended interactions or transactions with Leno Developments or otherwise receive the full benefit of their services.

Please refer to Section 6 of this Privacy Policy to learn about your options for withdrawing your consent.

Personal Information

In this Privacy Policy, “personal information” means information about an identifiable individual that allows someone to identify or contact you (e.g., your mailing address, telephone number, or email address) or other information defined by applicable law as “personal information,” “personally identifiable information,” or “personal data,” but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.

How Leno Developments Collects Your Personal Information

Information You Provide

You may be asked to voluntarily give your personal information to Leno Developments when you interact with Leno Developments, including when you subscribe to a newsletter, request information, or use a service provided by Leno Developments. In those circumstances, you can choose not to provide certain requested personal information, but then you might not be able to proceed with your intended interaction or transaction with Leno Developments or otherwise receive the full benefit of the desired service.

For example, Leno Developments may collect:

Contact information (such as name, email address, postal address, and phone number) when you make an inquiry or contact us, including when you visit a Leno Developments presentation center.

Contact information, banking information, employment information, government-issued identification information, and other personal information reasonably required by us to satisfy our reporting and legal compliance obligations when you use our services, including when you enter into a purchase and sale agreement or rental agreement for a property developed or managed by us.

Contact information, banking information, employment information, government-issued identification information, and other personal information reasonably required by us to satisfy our reporting and legal compliance obligations when you invest in a Leno Developments property or provide a personal guarantee for an investment in a Leno Developments property.

Contact information, employment information, and government-issued identification information when you apply for an employment opportunity with us.

Contact information and government-issued identification information when you participate in a Leno Developments promotion, sweepstakes, contest, or survey.

Contact information, communications preferences, and correspondence you send to us.

In those circumstances, you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of Leno Developments’ websites or otherwise receive the full benefit of our products and services.

If you give Leno Developments the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to Leno Developments and to Leno Developments’ use, disclosure, and retention of the personal information.

Automated Collection

Leno Developments may use technologies to automatically collect certain information regarding your use of Leno Developments’ websites, products, or services, such as the dates and times that you access a Leno Developments website or a service, the browsers, operating systems, software, devices, and networks that you use to access the website or service, and details of your use of the website or service.

Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and Leno Developments will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.

Property Development and Management

In some circumstances, Leno Developments may collect personal information from third parties in connection with the development or management of a Leno Developments property. For example, Leno Developments may collect personal information from brokers or referrals in connection with a property purchase or sale, or Leno Developments may collect personal information from a property manager in connection with a property rental. Leno Developments will only collect your personal information from a third party if we have obtained your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so.

Information from Other Sources

Leno Developments may collect personal information from various publicly available sources, such as if you interact with a Leno Developments social media account or if you submit rezoning or other public submissions that may be relevant to a Leno Developments property.

How Leno Developments Uses Personal Information

General

Leno Developments may use your personal information for various purposes in connection with our relationship with you and as otherwise set out in this Privacy Policy or permitted by applicable law, including:

To contact and correspond with you regarding your transactions and your use of Leno Developments’ products and services and to provide you with customer care services.

To facilitate your interactions and transactions with Leno Developments.

To provide services to you.

To process and respond to your inquiries, requests, and other communications.

To provide you with information (including by email and other electronic messages) regarding Leno Developments and its business and services and services offered by other businesses, to the extent permitted by applicable law.

To administer and facilitate your participation in contests and promotions related to Leno Developments.

To maintain, protect, and improve Leno Developments’ services and to develop new services.

To develop, deliver, and improve Leno Developments’ products, services, and advertising.

To protect and enforce Leno Developments’ legal rights, interests, and remedies and to protect the business, operations, and customers of Leno Developments or other persons.

Leno Developments may combine your personal information collected by Leno Developments through various sources.

Leno Developments may use your personal information to create non-personal information, and Leno Developments may then use, disclose, transfer, and retain the non-personal information as set out below in this Privacy Policy.

Leno Developments

Each Leno Developments may share your personal information with the entire Leno Developments group, and Leno Developments may develop, maintain, and share a confidential profile for you for use by each Leno Developments to provide information and services to you, to facilitate your dealings with each Leno Developments, and as otherwise set out in this Privacy Policy.

Cookies and Other Technologies

Leno Developments’ websites, online services, email messages, and advertisements may use “cookies” and other similar technologies, such as web beacons, pixel or gif tags, and action tags. Those technologies collect information that assists Leno Developments in improving products and services, advertising, and customer communications.

For example, Leno Developments may use information collected through cookies and similar technologies to recognize a user of Leno Developments’ websites and supplement our confidential profile for that user, determine a user’s general location to tailor the website content to that user’s location, track use of the websites, offer personalized web page content, information, and advertisements, and otherwise facilitate and improve the website experience. You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of Leno Developments’ websites. Information about how Google uses cookies and how you can limit or disable certain kinds of cookies on your personal computer or mobile device is available here:

https://www.google.com/policies/privacy/partners/ and https://www.google.com/policies/technologies/ads/.

Leno Developments may use web beacons, pixels or gif tags, and action tags to confirm that email messages have been delivered and opened. You may opt out of receiving emails in accordance with this Privacy Policy.

Information provided by cookies may be collected and processed by Leno Developments or by its third-party service providers.

How Leno Developments Discloses Personal Information General

Leno Developments discloses your personal information for purposes relating to or arising from your relationship and transactions with Leno Developments and as otherwise set out in this Privacy Policy or permitted by applicable law.

Specific Consents

Leno Developments may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Leno Developments.

Property Development

If a Leno Developments collects your personal information in connection with a specific property development or if you otherwise consent to the use of your personal information in connection with a specific property development, then Leno Developments may share your personal information with third parties related to that property development (such as sales partners, brokers, investors, governmental authorities, or lenders), and in those circumstances, Leno Developments has no control over, or responsibility or liability for, the use, disclosure, or retention of your personal information by those third parties, and the use, disclosure, and retention of the disclosed information by those third parties are not subject to this Privacy Policy.

Referred Transactions

If a Leno Developments refers you to an independent business (e.g., a sales partner, broker, or investor) for a proposed transaction (e.g., a purchase of a property), then Leno Developments may disclose your personal information to the independent business to facilitate the proposed transaction, and in those circumstances, Leno Developments has no control over, or responsibility or liability for, the use, disclosure, or retention of your personal information by the independent business, and the use, disclosure, and retention of the disclosed information by the independent business are not subject to this Privacy Policy.

Suppliers and Service Providers

Each Leno Developments may disclose your personal information to its suppliers and service providers (including property managers) to assist Leno Developments in the provision of information and services to you, to provide services to Leno Developments, to assist Leno Developments in using your personal information as set out in this Privacy Policy, and as otherwise permitted by applicable law.

Business Partners and Other Third Parties

In some circumstances, Leno Developments may share personal information with its business partners, such as strategic business partners who provide products and services that enhance your experience with us or that may be of interest to you, and other third parties. Leno Developments will only disclose your personal information to a third party if we have obtained your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so.

Law Enforcement/Legal Disclosures

Each Leno Developments may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant, or court or arbitral order or litigation disclosure obligation. Each Leno Developments may disclose your personal information to law enforcement agencies or other independent organizations if Leno Developments reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement, or other issues of public importance, or if Leno Developments reasonably believes the disclosure is necessary or appropriate to protect and enforce Leno Developments’ legal rights, interests, and remedies or to protect the rights, interests, business, operations, or customers of Leno Developments or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service, or other agreements that govern access to or use of any of Leno Developments’ services). Leno Developments has no control over, or responsibility or liability for, the use, disclosure, or retention of your personal information by the agencies, independent organizations, or other persons to whom Leno Developments discloses the information in the foregoing circumstances, and the use, disclosure, and retention of the disclosed information by those agencies, independent organizations, or other persons are not subject to this Privacy Policy.

Business Transactions

Leno Developments may disclose your personal information in connection with a proposed or actual business transaction in which Leno Developments is involved (e.g., a corporate amalgamation, reorganization, merger, or acquisition, or the sale or transfer of some or all of Leno Developments’ business or assets), but Leno Developments will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

Your Right to Withdraw Consent

When you interact with Leno Developments, you consent to the collection, use, disclosure, and retention of personal information as set out in this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in some circumstances, Leno Developments may have to limit the products and services provided to you.

Withdrawing your consent for integral purposes. You may withdraw your consent for purposes that are integral to the provision of Leno Developments’ products and services, but then you might not be able to proceed with your intended interactions or transactions with Leno Developments or otherwise receive the full benefit of Leno Developments’ products and services.

Withdrawing your consent for additional purposes. You may also withdraw your consent for purposes that are not integral to the provision of Leno Developments’ products and services. Withdrawing your consent for additional purposes that are not integral to the provision of Leno Developments’ products and services will not impact the provision of those products and services to you. Those additional purposes include:

To communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you.

To administer and facilitate your participation in sweepstakes, contests, and other promotions related to Leno Developments.

To conduct surveys on the quality of Leno Developments’ products and services.

To withdraw your consent, you may contact us at the contact information set out at the end of this Privacy Policy.

Location of Personal Information

Leno Developments and its service providers may process, store, and use your personal information at facilities in Canada, the United States, the United Kingdom, and other countries. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside and might permit courts, government, law enforcement agencies, regulatory agencies, and security authorities to access your personal information without notice. By providing your personal information to Leno Developments, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.

Retention of Personal Information

Leno Developments will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Leno Developments’ legal obligations or enforce or protect Leno Developments’ legal rights, or a longer period required or permitted by applicable law. Leno Developments will delete or dispose of your personal information, or depersonalize the information, when Leno Developments is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.

Protection of Personal Information

Leno Developments uses reasonable safeguards – including administrative, physical, and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Leno Developments’ possession or under Leno Developments’ control to help protect the information from unauthorized access, collection, use, disclosure, deletion, or similar risks. Nevertheless, security risks cannot be eliminated, and Leno Developments cannot guarantee that your personal information will not be accessed, used, disclosed, or deleted in ways not otherwise described in this Privacy Policy.

Accuracy and Access to Personal Information

Leno Developments will rely on you to ensure that the personal information you provide to Leno Developments is as accurate, complete, and up to date as necessary for the purposes for which Leno Developments uses the personal information. You will promptly notify Leno Developments of any changes to the personal information you provide to Leno Developments using the procedures made available for that purpose by Leno Developments or by contacting Leno Developments’ Privacy Officer using the contact information noted below.

You may reasonably request access to your personal information collected by Leno Developments and information about Leno Developments’ use, disclosure, and retention of that personal information by submitting a written request to Leno Developments’ Privacy Officer using the contact information noted below. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information, and you will be entitled to verify the accuracy and completeness of your personal information and to have the information corrected as appropriate. You may be required to pay a reasonable fee for access to your personal information. Leno Developments may decline to process a request that is unreasonably repetitive, frivolous, vexatious, or impracticable, or if Leno Developments reasonably believes that the requested access would infringe or jeopardize the privacy of other persons or violate any applicable law or legal requirement, or for other reasons permitted by applicable law.

Non-Personal Information

Leno Developments may use personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Leno Developments may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then Leno Developments will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with your personal information.

Other Websites and Businesses

Leno Developments’ websites and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. Leno Developments has no responsibility or liability for, or control over, those other websites, online services, or businesses, their products or services, or their collection, use, disclosure, or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure, and retention of your personal information by those websites, online services, and independent businesses. If you have questions about how those websites, online services, or independent businesses collect, use, disclose, or retain personal information, please contact the owner or operator of the website, service, or business.

Social Media

When you use certain aspects of Leno Developments’ websites or other services or post information to other social media sites (e.g., there may be links to Leno Developments’ social media pages), the personal information that you post or share in connection with these third-party sites is visible to other persons and can be read, collected, used, and disclosed by other persons, including to send unsolicited messages. As will be evident, in such a case, you will be leaving Leno Developments’ website and going to the third party’s website. Any information provided to such third-party social networking sites and other sites is governed by their privacy policies, which you may read on the applicable site. You are solely responsible for the personal information you choose to post or share in those situations. Leno Developments has no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information you disclose in those situations, and the use, disclosure, and retention of the disclosed information are not subject to this Privacy Policy.

Children and Personal Information

Leno Developments does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian. If Leno Developments learns that it has collected or received personal information from a child where parental confirmation was required, Leno Developments will delete that information. If you believe Leno Developments might have any information from or about a child where parental consent was required, please contact Leno Developments’ Privacy Officer using the contact information set out at the end of this Privacy Policy.

Other Matters

Disclaimers, Liability Exclusions/Limitations, and Disputes: The agreements (including any website terms of use) that you accept when you apply, register for, order, or use Leno Developments’ products and services contain important provisions, including provisions disclaiming, limiting, or excluding the liability of Leno Developments and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or Leno Developments’ collection, use, disclosure, and retention of your personal information and has the same force and effect as if they were reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.

Changes to this Privacy Policy: Leno Developments may change this Privacy Policy as it applies to Leno Developments from time to time by posting a new version of this Privacy Policy on Leno Developments’ websites. Leno Developments’ collection, use, disclosure, and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with Leno Developments after any change to this Privacy Policy will signify your consent to the collection, use, disclosure, and retention of your personal information by Leno Developments as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.

English Language: You and Leno Developments have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language.

Notices to You: You consent to Leno Developments sending you emails (to the email addresses you provide to Leno Developments) regarding this Privacy Policy and related matters.

Contacting Us

If you have any comments or questions about this Privacy Policy or how Leno Developments deals with your personal information, please contact Leno Developments’ Privacy Officer by mail or email at:

Leone Homes – Privacy Officer

8551 Leslie Road
Richmond British Columbia V6X 1E6

Email: [email protected]

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