Royal Bay and its worldwide related, associated, affiliated and subsidiary entities, such as Apex, Excel, Meadows, Latoria South and GableCraft (collectively referred to as “Royal Bay”, and also is referred to in this policy as “we”, “us”, or “our”) is committed to protecting and maintaining the privacy, accuracy, confidentiality, security and ethical use of Personal Information entrusted to us by our customers, prospective customers and residents of communities and developments for which we provide services as managing developer.
Our Privacy Policy applies to the collection, use, retention, maintenance and disclosure of Personal Information that Royal Bay obtains from contact with our customers, prospective customers and residents of land developments for which we are both the land owner and managing developer, or are acting as managing developer on behalf of another land owner or developer. When we process Personal Information, we do so in accordance with our Privacy Policy and with the standards required by provincial and federal privacy and data protection laws.
In addition, our Privacy Policy outlines the principles and practices we follow to protect Personal Information in accordance with the provisions of the applicable privacy protection legislation that Royal Bay is subject to. It also provides procedures for our customers, prospective customers and residents to access or update their Personal Information or make a complaint regarding the handling of their Personal Information. Our Privacy Policy is also applicable to any person providing products and/or services on behalf of Royal Bay.
We may choose to update or amend our Privacy Policy at any time to reflect changes in our legal or regulatory obligations, or in the manner in which we deal with your Personal Information. We will post any revised version of this Privacy Policy on our websites (http://gablecrafthomes.ca/ and https://liveatroyalbay.ca/ ) and we encourage you to refer back to our website on a regular basis. This Privacy Policy was last updated on February 18, 2020.
What Is Personal Information?
“Personal Information” means information about an identifiable individual. This includes an individual’s name, contact and mailing information, employment information, credit information, building plan information, insurance information, municipal and legal description of property and any preferences or information collected within surveys, registration or ballot forms.
We collect Personal Information to enable us to communicate and interact with you and also to provide our products and services to our customers, prospective customers and residents in the course of our business activities.
We do not treat business contact information as Personal Information.
Advertising and Analytics
About Our Use of Remarketing with Google Analytics
We also use Google Analytics to study the browsing behaviour of visitors to our website site. This is a website analytics service provided by Google Inc. Google Analytics collects information (via cookies) on an anonymous basis, such as the number of visitors to our website, their country, region and city of origin, the type of browser and operating system they are using, the date, time and duration of visits, the pages consulted, and what other websites they visited prior to coming to this site. Our use of Google Analytics includes the Demographics and Interest Reporting component. This allows us to show remarketing advertisements for content or products that are most likely to interest you. We also use the Display Network Impressions Reporting component of Google Analytics, this allows us to collect information to evaluate how successful advertisements are.
Please note that you may opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout) or by configuring your browser settings to block the use of cookies.
Facebook Conversion Tracking Pixel
We may also from time to time utilize the Conversion Tracking Pixel service of Facebook. This tool enables us to follow and understand the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement and allows us to understand and deliver ads that are more relevant to you. The data that is collected remains anonymous, which means we are not able to see the personal data of any particular individual user. However, the collected data is saved and processed by Facebook. Therefore, Facebook may be able to connect that data to your Facebook account and use the data for their own advertising purposes in accordance with Facebook’s own data use policy found at: https://www.facebook.com/about/privacy/). You can opt-out of Facebook’s use of cookies and the Conversion Tracking Pixel by clicking here: https://www.facebook.com/help/568137493302217.
The 10 Privacy Principles that Guide Our Protection of Personal Information
Principle #1 – Accountability and Protection of Personal Information
Royal Bay is responsible for Personal Information under its control, including Personal Information that is not in Royal Bay’s custody.
Accountability for compliance with our Privacy Policy rests with the Senior Management of Royal Bay but all employees are trained to appreciate the importance of privacy and confidentiality of Personal Information and are required to comply with the provisions of this Privacy Policy as a condition of their employment. Royal Bay has designated the following person to act as Privacy Officer:
Stuart Craven, Privacy Officer
Apex Limited Partnership
Email Address: scraven@excelhomes.ca
Senior Management and the Privacy Officer may designate other individuals to assist with compliance of this Privacy Policy.
Principle #2 – Identifying Purposes for Collection, Uses and Disclosure
Royal Bay collects, uses, retains and discloses Personal Information as necessary to establish and manage our relationship with our customers, prospective customers and residents to provide our
products and services. Specifically, we may collect, use, retain and disclose Personal Information for the following (“identified purposes”):
- When you purchase a lot in a community where we are the managing developer;
- When you register or contact us through our corporate or community websites via an email message or other media;
- When you visit sales centres or show homes within a community where we are the managing developer, and fill out an event form, survey or draw so as to interact and contact us;
- To welcome you to Royal Bay and communicate about any of our products and services as a managing developer, and/or to the communities where we are the managing developer;
- To thank you for contacting us;
- To establish and maintain a customer relationship;
- To provide information necessary to build your home;
- To provide necessary financial information;
- To enter into a home building contract with you (the “Contract”);
- To assess and provide ongoing maintenance and customer care relating to your home;
- To communicate with you after your home is built and your use of any of our related products and services;
- To contact you after your home is built regarding warranty services.
- To register your home with any government incentive plans or benefits that may exist; and
- To comply with legal and regulatory requirements.
If you would like to receive further details regarding the identified purposes, please contact our Privacy Officer.
Royal Bay does not use Personal Information to make automated decisions.
We do reserve the right to collate/process and disseminate statistics based on the aggregation of data held in our files, provided that information relating to any individual customer, prospective customer or resident will not be identified from the resulting analysis.
Certain Royal Bay employees, contractors, consultants or agents may be given access to Personal Information in so far as their duties require access for the identified purposes. Their access to customer, prospective customer or resident Personal Information is on a need to know basis.
Principle #3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
Your knowledge and consent is required for the collection, use or disclosure of Personal Information, except where inappropriate, or where required or permitted by law.
Your consent
Your consent to the collection, use and disclosure of Personal Information may be implied or expressed. You are deemed to provide implicit consent if the consent can reasonably be inferred from your action or inaction, including when you voluntarily provide the Personal Information to us for one of the identified purposes. For example, when you enter into a Contract with Royal Bay, or you submit a registration or survey form to Royal Bay, we will assume your consent has been provided to the collection, use and disclosure of your Personal Information for the identified purposes as set out in this Privacy Policy.
Please note that Royal Bay does not sell, trade or rent Personal Information to any organization for any purpose. However, we may share your information with builder(s), contractor(s), consultant(s) and/or trade(s) as necessary to provide you with information and/or services relevant to you.
If we plan to use or disclose your Personal Information for a purpose not for one of the identified purposes, we will take steps to advise you of that purpose and obtain your express consent prior to such use or disclosure. Your express consent may be provided orally, electronically or in writing.
Withdrawing your consent
You may withdraw your consent at any time to our collection, use or disclosure of your Personal Information, subject to any legal or contractual restrictions and with reasonable notice. In order to withdraw consent, you must provide notice, in writing, to the Royal Bay Privacy Officer identified under Principle #1. Upon receipt of such notice Royal Bay may inform you of the likely consequences to you of withdrawing consent, for example you may not be notified about new communities, upcoming events, associated developer or builder information, programs, maintenance initiatives, etc.
Principle #4 – Limiting Collection, Use and Disclosure of Personal Information
Our collection, use and disclosure of Personal Information shall be limited to the identified purposes as set out in this Privacy Policy.
Royal Bay collects most Personal Information directly from its customers, and occasionally from third parties such as builders, realtors, mortgage brokers, financial institutions, consultants or contractors.
Similarly, our customers’ Personal Information may be disclosed for identified purposes to necessary third parties, such as any government incentive plans or benefits, and contractors, trades, mortgage brokers or financial institutions.
Principle #5 – Retention
Personal Information shall be retained by Royal Bay for as long as reasonably necessary to fulfill identified purposes or as may be required by law.
Principle #6 – Accuracy
It is important that Personal Information collected by Royal Bay and in its records are accurate, complete, and up-to-date as is reasonably necessary for the identified purposes. If your Personal Information changes during the course of your relationship with us, please keep us informed of such changes and we will update that record.
Principle #7 – Security Standards
Royal Bay will use reasonable methods to protect the security of Personal Information in its custody and under its control, with physical, administrative and technological safeguards, as appropriate.
Royal Bay will take steps to protect Personal Information disclosed to third parties , including by limiting the purposes for which the Personal Information can be used.
Royal Bay uses sales management software that utilizes cloud storage of data in the U.S. We have satisfied ourselves that the data is secure and properly protected to the standards required by the applicable legislation. While the information is in another jurisdiction it may be accessed by foreign courts, law enforcement and national security authorities.
Principle #8 – Openness Concerning Policies and Practices
Royal Bay will take steps to make specific information about the principles and practices relating to its handling of Personal Information available on request. This Privacy Policy is available online or in hard copy format from our Head Office.
Principle #9 – Customers’ Access to Personal Information
You are entitled to request access to the Personal Information which we hold about you. You are entitled to challenge the accuracy and completeness of this Personal Information and request to have it amended, if appropriate.
How can I request access to my Personal Information?
To request access to your Personal Information, you can make a written request to the Privacy Officer. Upon presenting satisfactory identification and sufficient detail, Royal Bay will take steps to gather the Personal Information requested.
Within 30 days of receiving your request, Royal Bay will provide a written response detailing whether access will be given to all or part of the requested Personal Information and explain the reasons for the refusal, should any part of the access request be refused. Note that the 30 day period may be extended in some circumstances, including where permitted by law.
When an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, Royal Bay will take steps to amend the information as required, subject to any applicable legal limitations.
Principle #10 – Challenging Compliance, Handling Customer Inquiries
Royal Bay will take steps to investigate all complaints concerning compliance with this Privacy Policy. If a complaint is found to be justified, Royal Bay may take appropriate measures, including, if necessary, amending its policies and practices.
If you feel that your concerns have not been adequately addressed, Royal Bay will provide you with information regarding alternative complaint procedures that may be available to you. You may be advised to seek advice from the Office of the Information and Privacy Commissioner for British Columbia at 250-387-5629 or at info@oipc.bc.ca.
Please note that Royal Bay may seek external legal advice where appropriate before providing a final response to individual complaints.