Urban Avas Corp. Privacy Policy

1. Our Commitment

Urban Avas Corp. (“Urban Avas,” “we,” “us,” or “our”) is committed to protecting the privacy of our tenants, prospective tenants, website visitors, and business contacts. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with us, including when you visit urbanavas.com, submit a rental inquiry, apply for tenancy, become a resident, or otherwise communicate with us.

This Policy is based on the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Personal Information Protection Act (Alberta) (“PIPA”). We approach personal information with one operating principle: when in doubt, we choose the option that protects you.

2. Privacy Officer

Urban Avas has designated a Privacy Officer who is accountable for our compliance with this Policy and applicable privacy legislation.

• Privacy Officer: Gursharan Pabla
• Email: privacy@urbanavas.com
• Phone: 403-808-2932
• Address: 2535 3 Ave SE, Unit 400, Calgary, Alberta

You may contact the Privacy Officer with any questions, concerns, requests, or complaints related to your personal information.

3. What This Policy Covers

This Policy applies to all personal information we collect through:

• Our website at urbanavas.com (the “Site”)
• Inquiry, contact, and application forms (whether submitted on our Site, by email, by phone, or in person)
• Lease agreements and tenancy management
• Third-party listing platforms where we advertise (such as Rentals.ca, Rent.ca, RentFaster, Kijiji)
• Marketing and communications channels (email, SMS, social media)
• Any other interaction with Urban Avas

This Policy does not apply to websites or services operated by third parties, even when accessed via links from our Site. Those third parties have their own privacy practices.

4. Definitions

The following terms are used throughout this Policy:

“Personal Information” means any information about an identifiable individual, whether recorded or not. Examples include name, address, email, phone number, date of birth, government-issued ID, financial information, employment information, and online identifiers such as IP addresses.

“Sensitive Personal Information” means a subset of Personal Information that carries a heightened expectation of privacy due to its nature, including financial information, credit history, banking details, government-issued identification, employment income, and information about minors. Sensitive Personal Information requires express consent and heightened safeguards.

“Consent” means a voluntary agreement to the collection, use, or disclosure of Personal Information. Consent may be express (given explicitly, in writing or orally) or implied (reasonably inferred from your actions). For Sensitive Personal Information, only express consent is sufficient.

“Disclosure” means making Personal Information available to a party outside Urban Avas, including service providers and authorities.

“Service Provider” means a third-party organization engaged by Urban Avas to perform services on our behalf (for example, our CRM, hosting, analytics, or credit-check providers). Service providers are contractually required to handle Personal Information only for the purposes we specify.

“Tenant” means any individual who has entered into a lease agreement with Urban Avas, whether currently or formerly.

“Prospective Tenant” means any individual who has inquired about a rental, submitted a rental application, or expressed interest in becoming a Tenant.

“Site” means our website at urbanavas.com and any subdomains we operate.

“PIPEDA” means the Personal Information Protection and Electronic Documents Act (Canada).

“PIPA” means the Personal Information Protection Act (Alberta).

5. Personal Information We Collect

“Personal Information” means any information about an identifiable individual. We may collect the following categories of personal information:

• Contact Information: First and last name, mailing and residential address, email address, telephone numbers, emergency contact details.
• Identity Verification Information: Government-issued ID, driver's licence, date of birth, photographs.
• Demographic and Eligibility Information: Household composition, age, employment information (including employer, occupation, and salary or income), references, prior rental history.
• Financial Information: Banking details, credit history, credit score, payment information.
• Tenancy Information: Lease details, payment history, maintenance requests, communications with our staff, parking and storage assignments.
• Website Activity: IP address, browser type, device information, pages viewed, time spent on Site, referring URL, and similar technical data collected automatically by cookies and analytics tools.
• Marketing Preferences: Email and SMS subscription preferences, communication history.
• Audio and Video Recordings: From time to time, telephone calls and meetings may be recorded for quality assurance, training, and conflict resolution. Common areas of certain properties may use video surveillance for safety and security. Where required by law, signage will inform you.

Sensitive Personal Information

Some of the information we collect, particularly financial information, credit history, employment income, and government-issued identification, is considered Sensitive Personal Information. For Sensitive Personal Information, we rely on express (not implied) consent. We collect this category only when necessary to process a rental application, verify eligibility, or comply with legal obligations. We apply heightened safeguards to its storage, access, and disposal.

6. Why We Collect Personal Information

We collect, use, and disclose your personal information for the following purposes:

• To respond to inquiries and provide information about available rentals
• To process rental applications, including identity verification, credit checks, and reference checks
• To establish tenancy eligibility and prepare lease agreements
• To manage and administer tenancies, including rent collection, maintenance, and resident communications
• To facilitate tenant-benefit programs (such as gym, transportation, or partner-merchant offers)
• To send marketing and promotional communications you've consented to receive, including information about new properties, lease specials, and resident events
• To improve our Site, services, and marketing
• To comply with applicable laws, regulations, court orders, and lawful requests from authorities
• To protect our legal rights, property, and the safety of our staff, tenants, and the public
• To pursue collection of unpaid amounts or enforce lease obligations

If we want to use your personal information for a new purpose not described above, we will obtain your consent before doing so unless the law permits otherwise.

7. How We Collect Personal Information

We collect personal information directly from you when you:

• Submit an inquiry form on our Site (including via our lead-capture provider, WidgetBE)
• Email, call, text, or meet with our staff
• Submit a rental application or sign a lease
• Communicate with us during your tenancy

We also collect personal information from third parties, including:

• Third-party listing platforms (Rentals.ca, RentFaster, Kijiji, and others) where you submit inquiries
• Credit reporting agencies and background-check providers
• Previous landlords and employers (with your consent)
• Government agencies and public records (where lawful)
• Social media platforms (when you interact with our profiles)

We also collect website activity passively through cookies and similar technologies. See Section 11.

8. Consent

By providing personal information to us, or by authorizing a third party to do so on your behalf (for example, a guarantor or emergency contact), you consent to the collection, use, and disclosure of that information in accordance with this Policy.

You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice. Withdrawing consent may limit our ability to provide services to you (for example, we cannot complete a rental application without your consent to a credit check). To withdraw consent, contact our Privacy Officer.

For Sensitive Personal Information, we require express consent before collection.

9. Who We Share Personal Information With

We do not sell your personal information. We disclose personal information only in the following circumstances:

• Service providers: Companies we engage to provide services on our behalf, including our customer relationship management platform (Follow Up Boss), website hosting (Cloudflare), analytics providers (Google Analytics), lead-capture providers (WidgetBE), credit-check providers, background-check providers, payment processors, and email/SMS communication providers. These providers are contractually required to handle your information only for the purposes we specify and to safeguard it appropriately.
• Utility and building service providers: Where necessary to set up services (such as utilities, internet, security, or parking) for your tenancy.
• Legal and regulatory: Where required by law, court order, regulatory body, or law-enforcement request; or where necessary to protect our legal rights, property, or the safety of others.
• Business transactions: In the event of a sale, merger, financing, or restructuring of Urban Avas, your information may be transferred as part of the transaction. We will require any successor to honour the commitments in this Policy.
• With your consent: In any other circumstance where you have authorized disclosure.

Cross-border Storage

Some of our service providers store and process personal information outside of Canada (including in the United States and the European Union). When personal information leaves Canada, it may be subject to the laws of the foreign jurisdiction, including lawful access by foreign authorities. We require our service providers to apply protections comparable to those required by Canadian law.

10. Retention and Disposal

We retain personal information only as long as necessary to fulfil the purposes for which it was collected or to meet legal, regulatory, accounting, or audit requirements. For example:

• Inquiry and lead records: retained for up to 24 months from last contact
• Rental application records (declined): retained for up to 12 months from decision
• Tenant records (active and former): retained for the duration of tenancy plus 7 years for tax and legal purposes
• Website analytics data: retained according to our analytics providers' standard retention windows

When personal information is no longer needed, we securely destroy, erase, or anonymize it.

11. Cookies, Analytics, and Tracking Technologies

Our Site uses cookies and similar technologies to operate the Site, understand how visitors use it, and improve performance. The categories we use are:

• Necessary cookies. Required for the Site to function (e.g., remembering form state). Cannot be disabled.
• Analytics cookies. Help us understand visitor behaviour in aggregate. We use Google Analytics 4 (GA4) and SearchAtlas Dynamic Optimization for this purpose. These tools may collect your IP address, browser and device information, pages visited, and referring URLs. Data is used primarily in aggregate form.
• Lead-capture cookies. When you submit a form on our Site, our lead-capture provider (WidgetBE, which integrates with our CRM Follow Up Boss) may place a cookie on your device, retained for up to 10 years, to associate your submission with future visits. This cookie helps us respond accurately to your inquiry. By submitting a form, you consent to this collection.

You can control cookies through your browser settings. Disabling certain cookies may affect Site functionality.

You can opt out of Google Analytics tracking by installing Google's browser opt-out add-on, available at tools.google.com/dlpage/gaoptout.

12. Commercial Electronic Messages (Email and SMS)

If you've consented to receive marketing emails or SMS messages from us, you may receive communications about:

• New rental availabilities and upcoming properties
• Lease specials and promotions
• Resident events and tenant-benefit program offers
• Service updates relevant to your tenancy

You may unsubscribe from marketing emails at any time using the unsubscribe link in any email, or by replying STOP to any marketing SMS message. Transactional messages (such as appointment confirmations or tenancy-related notices) are not included in the unsubscribe.

Standard message and data rates may apply to SMS, depending on your mobile carrier.

13. Safeguards

We protect personal information using physical, organizational, and technological safeguards appropriate to its sensitivity. These include:

• Restricted physical access to offices and document storage
• Role-based access controls within our digital systems
• Encryption of data in transit (HTTPS) and at rest where appropriate
• Multi-factor authentication on sensitive systems
• Regular review and update of security practices
• Staff training on privacy obligations

No method of electronic storage or transmission is 100% secure. While we use commercially reasonable practices to protect your information, we cannot guarantee absolute security.

14. Your Rights

You have the following rights regarding your personal information:

• Access: You may request a copy of the personal information we hold about you, the purposes for which it was collected, and the third parties with whom it has been shared.
• Correction: You may request correction of inaccurate or incomplete information.
• Deletion: You may request deletion of your personal information, subject to legal or contractual restrictions (for example, we may be required to retain tenancy records for tax purposes).
• Withdrawal of consent: You may withdraw consent to our collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions.

To exercise these rights, contact our Privacy Officer. We will respond within 30 days, or notify you if additional time is required. We may need to verify your identity before processing a request.

In limited circumstances, we may be unable to fulfil your request. For example, where doing so would reveal another person's personal information or where retention is required by law. We will explain the reason in writing.

15. Complaints

If you believe Urban Avas has not complied with this Policy or applicable privacy law, please contact our Privacy Officer first. We take all complaints seriously and will investigate promptly.

If your concern remains unresolved, you may contact:

16. Links to Other Websites

Our Site may include links to third-party websites, including social media platforms, partner businesses, and listing platforms. Those sites have their own privacy practices, which differ from ours. We are not responsible for the content or practices of third-party sites. We encourage you to review their privacy policies before providing any personal information.

17. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will update the “Last updated” date at the top of this Policy. Material changes will be communicated through our Site or by direct notice.

Your continued use of our Site or services after a change takes effect constitutes acceptance of the updated Policy.

18. Contact Us

For any questions, requests, or complaints related to this Policy or your personal information: