RPMS Privacy Policy

Effective Date: December, 2025

Introduction

This Privacy Policy (the “Policy”) describes the practices of RPMS Property Management Services Inc. and its affiliates (collectively, “RPMS”) in relation to the collection, use, retention, disclosure and protection of information about an identifiable individual (“Personal Information”). In particular, this Policy applies to Personal Information RPMS collects about individuals who:

(a) are prospective, current or former residents, occupants, guarantors or third-party payors of rent;
(b) are prospective employees or board members;
(c) are prospective, current or former investors;
(d) are prospective, current or former vendors, suppliers, consultants, contractors, service providers or advisors (collectively, “service providers”);
(e) visit RPMS’s properties or offices;
(f) request services from RPMS;
(g) visit RPMS website, including https://rpmsi.ca ;
(h) use RPMS mobile or web applications; or
(i) otherwise interact with us.

This Policy was created to inform you of RPMS’s commitment to protecting your Personal Information and is based on the fair information principles and relevant requirements contained in applicable data protection laws. This Policy also includes information regarding RPMS’s compliance with Canada’s Anti-Spam Legislation (CASL).

How RPMS Uses the Personal Information

RPMS uses Personal Information for the following purposes:

(a) to determine your suitability for a lease, including creditworthiness;
(b) to analyze tenant demographics, including age and income, to understand its market and the demand for its products and services, including which buildings, locations, and amenities are desirable by different segments and how these demographic factors impact tenant turnover and occupancy, and to generate related market insights, analyze benchmarking data, for statistical analysis and to create usage data, and for other legitimate internal business purposes;
(c) to schedule property viewings;
(d) to administer your lease agreement and tenancy; including to communicate with you, process rent payments, to confirm payment of utility bills, to facilitate the set-up, switch-over or closing of utility accounts, to repay security deposits and to collect debts;
(e) to maintain the safety and good condition of our rental properties and to assess and arrange for maintenance or repairs (please see “Use of Video Surveillance, Recordings and Photographs” below regarding RPMS’s use of photographs and videos for this purpose);
(f) to enforce the terms of your lease agreement, including collection of any judgment that may be obtained against you as a consequence of a breach of your lease agreement (or other related agreement);
(g) to communicate with you regarding your job application and/or process information related to a job application or offer of employment;
(h) to communicate with employees and administer the employment relationship;
(i) to communicate with board members, administer their appointment and for governance and regulatory purposes;
(j) to communicate with service providers and administer and enforce contracts;
(k) to communicate with you by email, phone or mail about RPMS’s services, events, surveys, and other information that may be relevant to you;
(l) to protect RPMS’s assets, business, properties, residents, occupants, employees and other individuals;
(m) to facilitate actual or potential business transactions, such as the sale of assets or business or any financing;
(n) for internal control, business continuity and internal/external auditing;
(o) RPMS uses video recordings to protect residents, occupants, guarantors, visitors, employees, job applicants, service providers and other individuals who visit RPMS’s rental properties or offices, and for the purposes described in the “Use of Video Surveillance, Recordings and Photographs” section below;
(p) RPMS uses audio recordings for quality assurance and training purposes, as further described in the “Audio Equipment and Recordings” section below;
(q) RPMS uses cookies, pixels and similar technologies to improve the display and content of RPMS’s websites and to understand how users interact with RPMS’s websites. RPMS may also use this information for advertising purposes. To learn more about RPMS’s use of these technologies and how to manage your preferences, please see the “Cookies and Similar Technologies” section below;
(r) to respond to your request or inquiry;
(s) to document and investigate incidents;
(t) to investigate, resolve or defend any complaint, dispute, claim or investigation;
(u) to comply with a legal obligation;
(v) for other legitimate business activities, including for:

business planning purposes, such as internal analyses, strategic planning, forecasting, and reporting, including the assessment of tenant demographics, turnover rates, market demand, and market trends to improve RPMS’s products, services, and operations;
marketing/promotional purposes;
collecting and analyzing Personal Information to monitor, maintain, and improve RPMS’s properties, services, and tenant experience;
processing personal data to manage day-to-day business activities, such as internal reporting, business planning, and ensuring the efficient operation of services;
processing data to assess and manage business risks, including compliance with internal policies and procedures;

(w) for other purposes that may be communicated separately; and
(x) as otherwise required or permitted by law.

Use of Artificial Intelligence (AI) and Analytics

RPMS may use artificial intelligence (AI) technologies and advanced analytics to enhance its services, improve operational efficiency, and better understand the needs of residents, applicants, and other individuals interacting with RPMS. These technologies may be used for purposes such as:

Analyzing patterns in rental applications, maintenance requests, or website usage to improve service delivery and property management.
Detecting and preventing fraudulent activity or security threats.
Personalizing communications, marketing, or service offerings based on user preferences and behaviors.

Any personal information processed by AI or analytics tools will be handled in accordance with this Privacy Policy and applicable data protection laws. RPMS will take reasonable steps to ensure that the use of such technologies does not result in discriminatory or unfair outcomes.

Automated Decision-Making and Profiling

RPMS may use automated decision-making processes, including profiling, in certain circumstances, such as:

Screening rental applications to assess eligibility and creditworthiness.
Prioritizing maintenance requests based on urgency and available resources.
Evaluating job applications using automated tools to identify candidates who meet specific criteria.

Where automated decision-making is used, RPMS will:

Clearly inform individuals when a decision that significantly affects them is made solely by automated means.
Provide meaningful information about the logic involved, as well as the significance and potential consequences of such processing.
Allow individuals to request human intervention, express their point of view, and contest the decision, where required by law.

Anonymized, De-identified, and Aggregated Personal Information

RPMS may anonymize, de-identify, or aggregate Personal Information so that it does not directly or indirectly reveal your identity or relate to any identifiable individual. This de-identified and aggregated information may be used by RPMS to understand its market and the demand for its products and services; to create new products or services; to improve its existing products and services; to create and analyze benchmarking data; for statistical analysis and to create usage data; and for other legitimate internal business purposes.

Who RPMS Shares Your Personal Information With

RPMS may share your Personal Information with others, such as:

(a) RPMS’s affiliates;

(b) RPMS’s service providers, who may use Personal Information on RPMS’s behalf in connection with the purposes listed above, including to communicate with you directly;

(d) External auditors;

(e) any co-resident, occupant, guarantor or third-party payor of your rent if required under your lease agreement or related housing agreement;

(f) through public directories of residents maintained by RPMS (e.g., by the front door);

(g) credit reporting agencies to evaluate your credit worthiness in connection with an application for lease;

(h) former and current employers, former and current landlords, personal references, and present banking institution, all of whom are named by you in documents submitted to RPMS so that RPMS may contact them as part of the process of evaluating your lease or job application, as the case may be;

(i) third parties to enforce the terms of your lease agreement (or any related agreement), including collection of any judgment that may be obtained against you as a consequence of a breach of your lease agreement (or any related agreement);

(j) providers of any security alarm system, cable television, telephone, telecommunication, internet and internet connectivity, hydro-electricity, water/hot water, gas and/or other similar or related services that are available and outlined in the lease agreement. These third-party providers are restricted to using your Personal Information in order to fulfill other than for the purpose of contacting you for the provision of such services, and all of whom are disclosed on Schedule “A” of this Policy from time to time;

(k) governmental authorities when required to comply with RPMSs legal obligations (for example, RPMS may disclose your Personal Information to Canada Customs & Revenue Agency, to whose attention the T-5 interest income tax information return and/or the NR4 non-resident withholding tax information return is submitted (where applicable));

(l) after-hours technology and customer service providers who may have access to such Personal Information incidentally through their administration and servicing of software used by RPMS in business operations;

(m) third-parties in connection with a disposition of your building, an assignment of your lease agreement (or other related agreement) or to obtain financing;

(n) advisors or potential buyers or financiers (debt or equity) in connection with an actual or potential business transaction, such as the sale of assets or business or any financing; and

(o) other third-parties where you further consent to such disclosure or as otherwise required or permitted by law.

Consenting to RPMS’s Collection, Use and Disclosure of Your Personal Information

In most cases, the collection, use or disclosure of your Personal Information by RPMS requires your knowledge and consent. At certain times, your consent for the collection, use and disclosure of your Personal Information may be implied from the manner in which it is collected. For example, when you provide RPMS with your Personal Information in connection with a lease or job application, you have implicitly consented to RPMS collecting, utilizing and disclosing your Personal Information in a manner necessary to determine your suitability for, and administer, your lease or to communicate and process your job application. In other cases, your acknowledgement of this Privacy Policy constitutes your consent, such as when you accept an agreement that incorporates this Policy or use our website or mobile applications. Consistent with legal requirements, we may from time to time separately ask for your express consent to handle your Personal Information for particular or new purposes.

You may always choose not to supply RPMS with your Personal Information or request to withdraw consent to the ongoing collection, use or disclosure of your Personal Information. This may impact RPMS’s ability to provide you with services. We will explain to you any consequences of a request to refuse or withdraw your consent, as well as any situations where we cannot fulfil your request.

Collection, Use and Disclosure of Personal Information Without Consent

There are certain circumstances where RPMS may, or may be required to, collect, use or disclose your Personal Information without your knowledge or consent. Those circumstances include (but are not limited to):

(a) if the collection, use or disclosure without your knowledge or consent is required or permitted by law;

(b) the Personal Information is provided to RPMS’s lawyers;

(d) for the purpose of resolving or defending a complaint, dispute, claim or investigation;

(e) to comply with a subpoena, warrant or order made by a court, person or body with jurisdiction to compel the production of information;

(f) to comply with rules of court relating to the production of records;

(g) to comply with a request for information from a government institution or investigative body that has identified its lawful authority to obtain the information;

(h) to comply with a request from a government agency (e.g., Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, etc.) that has authority to review RPMS’s files and interview RPMS’s employees as a part of their mandates;

(i) for the purpose of acting in respect of an emergency that threatens the life, health, or security of an individual; or

(j) the Personal Information has been collected when consent is not required.

Retention of your Personal Information

RPMS maintains policies and practices governing the retention and destruction of Personal Information in its possession or custody. RPMS retains your Personal Information for as long as it is necessary to fulfill the purposes for which it was collected or used and to comply with applicable laws.

Protection of your Personal Information

RPMS will protect your Personal Information in a manner that is consistent with and appropriate to the sensitivity of that Personal Information. For example, RPMS employs physical, technical and organizational measures to ensure your Personal Information receives an adequate level of protection while it is under RPMS’s care, including when your Personal Information is transferred to one of RPMS’s service providers located outside the jurisdiction where you reside. RPMS’s handling of your Personal Information will respect its confidential nature at all times from the time of its collection until its ultimate disposal or destruction.

RPMS maintains policies and practices which ensure the protection of your Personal Information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, RPMS implements a combination of measures to protect your Personal Information, including:

Internal practices that limit employee access to Personal Information;
If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures;
A designated Privacy Officer to monitor RPMS’s compliance with applicable data protection laws;
Employee privacy and data security training;
Procedures for receiving, investigating and responding to complaints or inquiries regarding RPMS’s information handling practices, including any security incidents involving Personal Information; and
Framework governing the retention and destruction of Personal Information, as more fully described above in the “Retention of Your Personal Information” section of this Policy.

While RPMS takes all reasonable measures to safeguard your personal information, please note that no method of electronic transmission of personal information can be guaranteed to be completely secure.

Transfers of Personal Information to Other Jurisdictions

RPMS may store your Personal Information within or outside of Canada. Some of RPMS’s service providers may also access, process or store your Personal Information outside the province where you reside. In that case, RPMS uses reasonable safeguards to ensure that RPMS’s service providers protect your Personal Information wherever it is used or stored. When your Personal Information is used or stored in a jurisdiction other than where you reside, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

Canada’s Anti-Spam Legislation (CASL)

A list of persons or business entities to whom your Personal Information may be provided after signing a lease, and who may, in turn, send Commercial Electronic Messages (CEMs) to you is attached as a schedule to this Policy under the heading: “Third Party Disclosure”. At this time, RPMS has taken steps to generally prohibit third parties from using your Personal Information for the purpose of sending you CEMs unless same are exempt from restrictions of, or are otherwise sent in full compliance with, CASL.

Use of Video Surveillance, Recordings and Photographs

Surveillance of RPMS properties

Video equipment may be installed and operating in common areas of RPMS’s rental buildings and offices. The video equipment may have capabilities such as zoom, or night-vision features. The video equipment may be operating at all times. Surveillance of the video recordings or the taking of photographs may occur at any time to: (a) ensure the safety, security and reasonable enjoyment of RPMS’s residents, occupants, employees, service providers and other visitors to RPMS’s rental properties and offices; (b) ensure you have access to the premises, equipment and services that RPMS has agreed to provide; (c) to preserve RPMS’s property and to deter crime; (d) to document and investigate incidents; (e) to investigate, resolve or defend any complaint, dispute, claim or investigation; and (f) to assist in administration of business operations.

Unit inspections

RPMS staff members and our third-party partners (such as contractors, service providers, or business partners) may need to enter your unit in order to conduct mandatory inspections, such as safety, maintenance, and move-out inspections. During any of these inspections, we may take limited photographs and/or video recordings of your unit.

The purpose of these photos and videos is to document and assess any issues discovered during the inspection(s). The photo and videos will only be used to remedy such issues. For example, if a photograph or recording is taken of a unit fixture in need of repairs, it will only be used to assist in evaluating and completing the necessary maintenance work.

If an inspection requires entry into your unit, you will be provided with a separate notice before your unit is accessed, at which time you may contact your rental office if you have questions or concerns about unit photographs or video recordings.

RPMS events

Photographs and/or audio/video recordings may be taken at RPMS events, which may be used in RPMS publications, including reports and online content published by RPMS on RPMS’s website(s) or official social media accounts. If you have concerns about your image or voice being used in this manner, please contact our Privacy Officer using the contact information listed below.

By attending RPMS events, you hereby transfer, assign and otherwise convey to RPMS any and all right, title and interest globally in and to any and all such photos, videos and recordings taken at RPMS events (the “Materials”), including all copyrights and other intellectual property rights in the Materials arising in any jurisdiction throughout the universe in perpetuity, including all registration, renewal, and reversion rights, and the right to use to enforce such intellectual property rights against infringers. RPMS shall be the exclusive owner of all intellectual property rights, including copyrights, to the Materials. You irrevocably waive any rights that you have may have in the Materials which cannot be assigned, including moral rights in the Materials.

Without limiting the previous paragraph, you grant RPMS the right to use, exploit, retain, disclose, exhibit, display, transmit, broadcast, reproduce, publish, and permit others to use the Materials without payment or other benefit to you. You agree that RPMS has the right to (i) combine the Materials with any other materials; (ii) create derivative works of the Materials; (iii) alter, edit, rearrange, or otherwise revise or modify the Materials; and (iv) license, distribute, assign or transfer any right, title or interest, or intellectual property rights in the Materials, in RPMS’s sole discretion. You release RPMS from all liability with respect to the foregoing.

Where required by law, signs will be posted informing you that video equipment is operating and recording Personal Information about you. You can contact RPMS’s Privacy Officer if you have questions regarding the video recordings.

Use of Audio Equipment and Recordings

When you contact RPMS’s customer service helpline, RPMS may make audio recordings of its employees, service providers, residents or other individuals. There are several purposes for making the recordings, which include: situations where there are work-related performance issues in respect of RPMS’s role as employer, to ensure the safety of the workplace, for quality control, for training, and to prevent harassment.

Audio recordings may be made during meetings, interviews, or telephone calls between RPMS and its employees, service providers, residents and other individuals. Calls made to RPMS may also be recorded for training and quality control purposes.

Information recorded by the audio equipment may capture communications of any of the following persons: the employer, employee, residents, contractors, and the general public.

Exercising your Right to Access or Rectify your Personal Information and Other Privacy Rights

Access to your Personal Information held by RPMS may be requested by contacting the Privacy Officer in writing. Upon such written request, you shall, to the extent possible and/or where permitted under applicable law, be informed of the existence, use and disclosure of your Personal Information and be given access to and ensure the accuracy of that Personal Information.

You also have the right to request the rectification of your Personal Information if it is inaccurate, incomplete or no longer up to date. Depending on where you reside, you may also be entitled to request the rectification or deletions of your Personal Information if our collection, disclosure or retention of such information is not authorized by law.

Any questions with regard to requesting access to, or rectification of, Personal Information or your other privacy rights may be addressed to the Privacy Officer.

RPMS undertakes to use reasonable efforts to maintain the accuracy, completeness and currency of your Personal Information that is held by RPMS as is necessary to fulfill the purpose for which it was collected and is to be used. RPMS may, from time to time, ask you to confirm the accuracy of your Personal Information for such purpose.

Cookies and Similar Technologies

When you visit the RPMS website(s), RPMS may collect and use your internet protocol address to help diagnose problems with RPMS’s server and to administer the website, to understand how users interact with the RPMS website, and to gather broad demographic information. RPMS may also collect web page choices, information about your browser, device, platform, and operating system and versions, and time you spend on the site, to help RPMS improve your experience. Although the RPMS website(s) may collect high-level information about your location (for example, the longitude and latitude associated with your municipality), they do not collect precise geolocation without your consent.

RPMS uses “cookies”, a technology that installs a small amount of information on a website user’s computer, to permit RPMS’s website(s) to recognize future visits using that computer and to avoid having to register your contact information at each visit. Cookies enhance the convenience and use of RPMS website(s). For example, the information provided through cookies is used to recognize you as a previous user of RPMS’s website(s), to track your activity on RPMS’s website(s) and obtain general information about other websites you have visited, to respond to your needs, and to otherwise facilitate your experience on RPMS’s website(s). You may choose to decline cookies if your browser permits, but doing so may affect your use of RPMS’s website(s) and your ability to access certain features of RPMS’s website(s) or engage in transactions through our website(s).

RPMS also uses web cookies and pixel tags to track user behaviour on RPMS’s website(s) and to compile reports regarding user demographics, and website tracking patterns. Within RPMS’s applications, RPMS may also use analytic tools and automated tracking technology or methods. RPMS uses these tools to analyze and enhance the user experience. Please visit RPMS’s cookie policy for more information.

RPMS may use third-party advertising networks to display advertising on RPMS’s website(s) or other websites. These advertising networks use cookies or similar technologies to track your navigation habits on our websites and third-party websites in order to serve you advertising that is customized to your inferred interests and preferences. For example, a cookie may be placed on your computer when you visit a RPMS website, which is recognized and used by third-party advertising networks to serve you with a RPMS ad when you visit other websites within their advertising network. As described above, you may be able to set your browser to decline cookies. Where required by law, RPMS will ask for your consent before enabling such technologies. If you decline cookies you may still receive online advertising; however, it may be less personalized. Some advertising networks participate in industry programs that include web pages to visit to opt-out. For example: http://youradchoices.ca/choices.

Third Party Websites

RPMS may provide links to other websites that are not operated or controlled by RPMS. These websites are not governed by this Policy. You should review the privacy policy associated with any linked website prior to visiting the site or providing any information.

Additional Rights for European Economic Area (EEA)/ Swiss Residents

If you are from the EEA or Switzerland, you may have the right to exercise additional rights available to you, including:

Right to erasure: In certain circumstances, you may have a broader right to erasure of Personal Information that RPMS holds about you. Please note that RPMS may need to retain certain information for record-keeping purposes, to complete transactions, or to comply with RPMS’s legal obligations
Right to object to processing: You may have the right to request that RPMS stop processing your Personal Information
Right to restrict processing: You may have the right to request that RPMS restricts processing of your Personal Information in certain circumstances (for example, where you believe that the Personal Information RPMS holds about you is inaccurate or unlawfully held)
Right to data portability: You may have the right to be provided with your Personal Information in a structured, machine readable and commonly used format and to request that RPMS transfer the Personal Information to another data controller without hindrance

To exercise such rights, please contact RPMS as set forth at the end of this Policy.

You also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

Children’s Personal Information

RPMS’s website(s) are for those who are over the age of majority. RPMS does not knowingly solicit or collect any Personal Information from children under the age of majority through RPMS’s website. If you are under the age of majority, please do not submit any Personal Information through the website. If RPMS is notified or discovers that a child under the age of majority has submitted Personal Information to us, RPMS will take reasonable steps to delete the information.

Changes to RPMS’s Privacy Policy

RPMS reserves the right to change this Policy from time to time. If RPMS makes a significant change, RPMS will provide a more prominent notice when required by applicable laws. RPMS recommends that you periodically review this Policy, which is available on RPMS’s website www.rpmsi.ca, so that you are aware of any changes. Your continued use of RPMS’s services or website following the posting of any changes to this Policy or after having been informed of such changes shall constitute your acceptance of these changes. The “Effective Date” at the top of this Policy indicates when it was last updated.

Responsibility for Compliance with our Privacy Policy

Our Privacy Officer is responsible for overseeing RPMS’s compliance with this Policy and may be contacted at the following address:

Privacy Officer, Elise Lenser
Canadian Apartment Properties Real Estate Investment Trust
11 Church Street Suite 401
Toronto, ON M5E 1W1
privacy@rpmsi.net

Questions or concerns about our privacy practices

Please address any questions or concerns about our compliance with this Policy or our privacy practices generally to the Privacy Officer by email at privacy@rpmsi.net or at the address indicated above.

Schedule “A”: Third Party Disclosure List

Below is a list of Third Parties that the Landlord may provide Personal Information to and who may send you CEMs.

Bell Canada

1050 côte du Beaver Hall, Montréal, Québec H2Z 1S4 www.bell.ca

Rogers Communications Partnership

855 York Mills Road, Toronto, Ontario M3B 1Z1 www.rogers.com