Isle of Mann Construction Ltd., Isle of Mann Capital Corporation, Isle of Mann Development Corporation, Isle of Mann Management Services Inc. and Isle of Mann Property Group Ltd. (collectively “Isle of Mann” or “IOM”) is a leading, vertically integrated real estate services company providing investment management, property management, asset management, development services and financial services to clients across Canada and the U.S. Privacy has always been treated as a priority at Isle of Mann and we have taken formal steps to promote responsible and transparent practices in the management of Personal Information in accordance with various privacy information protection statutes. This Privacy Policy describes IOM’s policies regarding the collection, Use, Disclosure, and retention of Personal Information.

We ensure that our employees sign a code of business conduct that requires the safeguarding and proper use of confidential information, including Personal Information. We also have appropriate controls on the protection of Personal Information within our systems and websites and ensure that our employees are required to respect privacy of Personal Information at all times.

Isle of Mann will continue to review and amend its Privacy Policy to ensure it remains current with the changing environment and regulations and it may be supplemented or modified by agreements entered into between IOM and an individual or organization from time to time.

Summary of Principles

1. Accountability
Isle of Mann is responsible for Personal Information under its control and shall designate one or more individuals who are accountable for the company’s compliance with the Privacy Policy.

2. Collection and Purpose of Personal Information
Isle of Mann shall identify the Purposes for which Personal Information is collected at or before the time the information is collected.

3. Consent for Collection, Use or Disclosure of Personal Information
The knowledge and implicit or explicit consent of the individual are required for the collection, Use or Disclosure of Personal Information, except where inappropriate or not required.

4. Limiting Collection of Personal Information
The collection of Personal Information shall be limited to that which is necessary for the Purposes identified by Isle of Mann. Information shall be collected by fair and lawful means.

5. Limiting Use, Disclosure and Retention of Personal Information
Isle of Mann shall limit the Use and Disclosure of Personal Information to those Purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Isle of Mann shall retain Personal Information only as long as necessary for the fulfillment of those Purposes, or as required or permitted by law.

6. Accuracy of Personal Information
Personal Information shall be as accurate, complete and up-to-date as necessary for the Purposes for which it is to be Used.

7. Security Safeguards
Isle of Mann shall protect Personal Information by the use of security safeguards appropriate to the sensitivity of the information.

8. Openness Concerning Policies and Practices
Isle of Mann will make available to customers, employees and other parties with whom it does business, specific information about its policies and practices relating to the management of Personal Information.

9. Access to Personal Information
Upon written request by an individual, Isle of Mann shall inform the individual of the existence, Use and Disclosure of his or her Personal Information and shall give the individual access to the information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the Privacy Policy to the designated individual or individuals accountable for Isle of Mann’s compliance.

Scope and Application

The ten principles outlined form the basis of the IOM Privacy Policy and are interrelated. Isle of Mann shall adhere to the ten principles as a whole, which must be read in conjunction with accompanying commentary which is tailored to reflect the specific circumstances of IOM.

The Privacy Policy applies to Personal Information about Isle of Mann’s customers, suppliers, employees or other individuals that is collected, Used or Disclosed by IOM and to the management of Personal Information in any form, whether oral, electronic or written.

This Privacy Policy applies to all Isle of Mann’s operating groups including Development, Construction, Asset Management, Property Management, Investment Management, Real Estate Finance and Venture Capital.

Definitions

DISCLOSE and its corollaries DISCLOSED or DISCLOSURE means any time Personal Information is transferred or disclosed to a third party outside Isle of Mann.

IOM AFFILIATE means any corporation which Isle of Mann deems, at its sole discretion, to have a direct business relationship or connection.

PERSONAL INFORMATION means any information about an identifiable individual, such as a customer, supplier, employee or other individual, but does not include:

  1. an individual’s business contact information including the name, position name or title, business telephone number, business address, business e-mail, and business fax number, of an individual;
  2. other information about an individual that is publicly available information as designated under applicable privacy laws, such as information available from a public registry;
  3. aggregated information that cannot be associated with a specific individual.

PURPOSES means the purposes for the collection, Use, or Disclosure of Personal Information that have been identified to an individual by Isle of Mann, including the purposes described in this Privacy Policy.

USE means use which occurs any time Personal Information is accessed, used, processed, copied, manipulated, altered, deleted or stored.

Principle 1: Accountability

Isle of Mann is responsible for the Personal Information under its control, and we have designated a Privacy Officer who is responsible for our compliance with this Privacy Policy and with applicable laws. Other individuals within Isle of Mann may be delegated to act on behalf of the Privacy Officer and IOM shall use appropriate means to provide a comparable level of protection while information is being Disclosed to and Used by a third party service provider.

You may contact our Privacy Officer as follows:

Isle of Mann Property Group
Attention: Director, Operations & General Counsel
Address: 15336-31 Avenue, Suite 401 Surrey, BC V3Z 0X2
Phone: +1 604 535 1628
Fax: +1 604 535 1627
Email: Corporate@IOMPropertyGroup.com

Principle 2: Collection and Purpose of Personal Information

Isle of Mann shall identify the Purposes for which Personal Information is collected at or before the time the information is collected (such Purposes identified before the time the Personal Information is collected shall include those Purposes disclosed within this Privacy Policy).

Isle of Mann collects Personal Information for the following Purposes:

a. To establish and maintain commercial relationships and provide ongoing service;
b. To manage and develop IOM’s business and operations, including employee and personnel matters; and
c. To meet legal and regulatory requirements.

Isle of Mann collects Personal Information for these Purposes through various means including, but not limited to:

General

a. email and other correspondence that is sent to Isle of Mann;
b. from third party service providers in connection with the Purposes;
c. website forms;
d. verbal discussions;

Asset & Property Management

a. applications for tenancy including credit applications (may collect credit-related or other information about the individual from a third party credit reporting agencies, banks, references, etc.);
b. applications for specialized services and memberships, such as parking, fitness facilities or golf club memberships;
c. leases and other associated agreements entered into with Isle of Mann or an approved IOM Affiliate company;
d. commercial agreements entered into with Isle of Mann;
e. emergency or incident reporting including video and other surveillance for investigative, insurance and risk management purposes;
f. video surveillance, swipe cards and other information for general security purposes;

Investment Management

a. commercial agreements entered into with Isle of Mann or an approved IOM Affiliate;

Employment

a. resumes & personal references provided in applications of employment;
b. employment forms.

Principle 3: Consent for Collection, Use or Disclosure of Personal Information

The knowledge and implicit or explicit consent of an individual is required for the collection, Use or Disclosure of Personal Information, except where inappropriate or not required by applicable privacy laws. Requirements for consent to collection, Use, or Disclosure of Personal Information vary depending on circumstances and on the type of Personal Information that is intended to be collected, Used, or Disclosed.

a. In obtaining consent, Isle of Mann shall use reasonable efforts to ensure that an individual is advised of the Purposes for which the Personal Information will be Used or Disclosed.
b. Generally, Isle of Mann will seek consent at the same time that it collects the information. However, IOM may seek consent to Use and Disclose Personal Information after it has been collected, but before it has been Used or Disclosed for a new Purpose.
c. Isle of Mann will require individuals to consent to the collection, Use or Disclosure of Personal Information as a condition of the supply of a service or employment if such collection, Use or Disclosure is required to fulfill the identified Purposes.
d. In determining whether consent is required and, if so, which form of consent is appropriate, Isle of Mann will take into account both the sensitivity of the Personal Information and the Purposes for which Isle of Mann will Use the information. Consent may be express or implied (including through use of “opt-out” consent where appropriate). For example, if an individual provides his/her mailing address and requests information regarding a particular service, consent to Use the address to provide the requested information may be implied.
e. In general, the use of services by an individual constitutes implied consent for Isle of Mann to collect, Use and Disclose Personal Information for all identified Purposes.
f. Isle of Mann can collect, Use and Disclose employee Personal Information without the consent of the individual where the collection, Use or Disclosure is reasonable for the purposes of establishing, managing or terminating an employment relationship between Isle of Mann and the individual and the individual has been advised of these Purposes (such Purposes shall include those Purposes disclosed within this Privacy Policy).
g. On giving reasonable written notice to Isle of Mann, an individual may withdraw consent to the collection, Use, or Disclosure of his or her Personal Information subject to legal or contractual restrictions. Upon notice of withdrawal of consent, Isle of Mann will notify the individual of the likely consequences of withdrawing his or her consent and, except where otherwise required or permitted by law, Isle of Mann will stop collecting, Using, or Disclosing the Personal Information as requested.

If a person provides Isle of Mann or its third party service providers or agents with Personal Information about an individual, the person represents that it has all necessary authority and/or has obtained all necessary consents from such individual to enable IOM to collect, Use, and Disclose such Personal Information for the Purposes set forth in this Privacy Policy.

Isle of Mann may collect, Use or Disclose Personal Information in certain limited circumstances without the knowledge and consent of the individual. Examples of this include:

a. Isle of Mann may collect or Use Personal Information if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill, mentally incapacitated, or in the case of an emergency where the life, health or security of an individual is threatened.
b. Isle of Mann may Disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may otherwise be required or permitted by law.
c. Isle of Mann may collect, Use or Disclose Personal Information without the knowledge and consent of the individual if seeking consent of the individual is reasonably expected to compromise the availability or the accuracy of Personal Information reasonably required for an investigation or a proceeding such as in the case of an investigation of a breach of agreement or contravention of federal, provincial, or state law.

Principle 4: Limiting Collection of Personal Information

Except where required or permitted by law, Isle of Mann will limit the collection of Personal Information to the Personal Information that is necessary to fulfill the Purposes. Isle of Mann will collect Personal Information by fair and lawful means.

a. Isle of Mann primarily collects Personal Information directly from its customers, suppliers or employees.
b. Isle of Mann may also collect Personal Information from other sources including credit agencies, employers or personal references, or other third parties who represent that they have a right to disclose the information.

Principle 5: Limiting Use, Disclosure and Retention of Personal Information

Isle of Mann shall limit the Use and Disclosure of Personal Information to those Purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Isle of Mann shall retain Personal Information only as long as necessary for the fulfillment of those Purposes or as required or permitted by law.

Use of Personal Information

Isle of Mann Uses Personal Information collected from customers, potential customers, and other individuals as follows:

a. to respond to requests for information regarding Isle of Mann’s products and services;
b. to determine whether to provide products or services to a customer or potential customer, such as assessing and confirming the accuracy of information provided in applications for tenancy and assessing creditworthiness, or to determine whether to establish a commercial relationship with suppliers or other third parties;
c. to communicate with customers when required, outside of regular business channels;
d. to establish, manage, or terminate our relationship with and to provide services and products to customers, including to issue invoices, to collect and process payments, and to fulfill contractual obligations;
e. to distribute any Isle of Mann publications that may be provided to individuals other than at business addresses;
f. to detect and protect against fraud, theft, breach of contract, or non-compliance with an obligation by customers, tenants, or others;
g. as required or permitted by law;
h. for additional Purposes that may be identified at or before the time that the information is collected or for new Purposes to which an individual has consented.

Access to Personal Information is limited to those employees and third-party service providers of Isle of Mann who require access in connection with the Purposes.

Disclosure of Personal Information

Isle of Mann may Disclose certain Personal Information to third parties or to affiliated entities as reasonably required in connection with the Purposes, as otherwise consented to by an individual, or where required or permitted by law, including as follows:

a. to an organization or individual retained by Isle of Mann, inside or outside your country of residence (e.g., Canada or the United States of America), to assist in respect of any Purposes, such as third-party service providers engaged by Isle of Mann to provide data processing services, facilities management services, call centre operations, processing and sending of mail-outs, or building maintenance;
b. a credit reporting agency;
c. references for customers;
d. Isle of Mann’s branded tenant service response system;
e. to an organization or individual retained by Isle of Mann to evaluate an individual’s or organization’s creditworthiness or to collect debts outstanding on an account;
f. to a financial institution in connection with the assignment of a right to receive payment, the provision of security, or other financing arrangements;
g. to a person who, in the reasonable judgment of Isle of Mann, is providing or seeking the information as the agent of the individual for whom the information is sought;
h. to legal, accounting, financial, insurance, and other advisors as reasonably required in connection with the Purposes or the operation of its business;
i. to law enforcement agencies in connection with the investigation of unlawful acts;
j. to governmental or regulatory agencies as required or permitted by law;
k. to a third party in connection with the sale, reorganization, or financing of all or part of Isle of Mann’s business or operations, including for due diligence purposes in connection with any such proposed transaction;
l. for additional Purposes that may be identified at or before the time that the information is collected or Disclosed or for new Purposes to which an individual has consented.

In addition, Isle of Mann may Disclose Personal Information about its employees:

a. for normal personnel and benefits administration;
b. where reasonable for the purposes of establishing, managing, or terminating an employment relationship between Isle of Mann and the individual and the individual has been advised of these Purposes (such Purposes shall include those Purposes disclosed within this Privacy Policy);
c. to third party service providers inside and outside your country of residence as provided in this Privacy Policy;
d. where the employee consents to such Disclosure or Disclosure is required or permitted by law.

In respect of Personal Information Disclosed to third parties, Isle of Mann takes appropriate steps, where permitted by law, to ensure that such third parties Use the Personal Information only in connection with the Purposes and safeguard the Personal Information against unauthorized Use or Disclosure. While Personal Information is being processed outside your country of residence by third party service providers on behalf of Isle of Mann, the Personal Information may be accessed by the courts, law enforcement and national security authorities of the foreign country where it is being processed.

Only Isle of Mann’s employees, whose duties reasonably so require, are granted access to Personal Information about customers and employees.

Retention of Personal Information

Isle of Mann shall keep Personal Information only as long as it remains necessary or relevant for the Purposes or as required or permitted by law. Depending on the circumstances, where Personal Information has been Used to make a decision about an individual, Isle of Mann will retain the information for a reasonable period of time (including a year were required by applicable privacy laws) so that the individual has a sufficient opportunity to obtain access to it.

Once Personal Information is no longer required to fulfill the Purposes and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.

Principle 6: Accuracy of Personal Information

Isle of Mann will take appropriate steps to ensure that Personal Information collected by IOM is accurate and complete as reasonably required in connection with the Purposes, including where Personal Information is likely to be Used by IOM to make a decision that affects the individual to whom the Personal Information relates or if the Personal Information is likely to be Disclosed to a third party.

Principle 7: Security Safeguards

Isle of Mann stores Personal Information at our premises or at the premises of our third-party service providers and will protect this information by security safeguards appropriate to the sensitivity of the information.

a. Isle of Mann takes steps to ensure the security of Personal Information, regardless of the format in which it is held, while in its custody is appropriate to the sensitivity of the information, including physical security measures (such as the use of locked cabinets and storage facilities) and technological security measures (such as the use of passwords and encryption).
b. All Isle of Mann employees with access to Personal Information are required to respect the confidentiality of that information.
c. Isle of Mann will take appropriate steps to protect Personal Information Disclosed to third parties, such as by contractual agreements stipulating the confidentiality and security of the information and the Purpose for which it is to be Used.

Principle 8: Openness Concerning Policies and Practices

Isle of Mann will make available to customers, suppliers, employees and other individuals specific information about its policies and practices relating to the management of Personal Information.

Isle of Mann will make a reasonable effort to assist individuals and respond as accurately and completely as practically possible.

Principle 9: Access to Personal Information

Upon written request by an individual, Isle of Mann shall inform the individual of the existence, Use and Disclosure of his or her Personal Information by or in the custody of IOM, and shall give the individual access to the information, except where providing such information or access is not required or is prohibited by law. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

a. An individual may, upon written request to Isle of Mann’s Privacy Officer, access the Personal Information about the individual that is in the custody of IOM. Within 30 days of such request (or such longer time as permitted by law), IOM will inform the individual of existence, Use, and Disclosure of such information.
b. An individual may, upon written request to Isle of Mann, request a correction to an error or omission in any Personal Information that is under IOM’s control. Isle of Mann will, as appropriate, amend the information as requested and use its best efforts to send the corrected Personal Information to each third party to which it has Disclosed the information during the preceding year.
c. The written request must provide sufficient detail to enable Isle of Mann, with a reasonable effort, to identify the individual and the Personal Information or correction being sought.

An individual’s rights to access his or her Personal Information are not absolute. Isle of Mann may deny access when denial of access is required or permitted by law, including but not limited to if granting an individual access would reveal:

a. Personal Information about a third party, or information which could reasonably be expected to threaten the life or security of an individual;
b. confidential commercial information;
c. Personal Information which is protected by solicitor/attorney-client privilege; or
d. Personal Information collected relating to an investigation.

If we deny an individual’s request for access to, or refuse a request to correct Personal Information, we will explain why, to the extent permitted by law.

Principle 10: Challenging Compliance

An individual may, upon written request, address a challenge concerning Isle of Mann’s compliance with the Privacy Policy to our Privacy Officer.

If you have any questions or concerns about this Privacy Policy or about the collection, Use, or Disclosure of your Personal Information by Isle of Mann, please contact our Privacy Officer.

Privacy for Visitors to IOMPropertyGroup.com

Isle of Mann respects your right to privacy. The following guidelines dictate the manner in which Isle of Mann protects the privacy of its visitors to our website and by accessing, browsing or using this website, you acknowledge that you have read, understand and agree with the provisions contained herein.

Website Administration

When you visit the Isle of Mann website, some information may be collected automatically by the software that operates our website (i.e. the site from which you linked, your Internet Service Provider, the time and date of your visit). Our servers do not track, collect, or distribute personal information about visitors to our website. This information is used by our technical engineers to compile aggregate statistics about the total number of daily visitors to our site, the pages most frequently visited, and how long people stay at each page. None of the information that we report allows for the personal identification of individuals.

Links

The Isle of Mann site contains links to other websites; however, we cannot be responsible for the privacy practices or the content of such websites.