Privacy Policy

Last Updated: April 7, 2025

British Pacific Properties Limited and our subsidiaries (“we”, “us”, “our”) respects and upholds individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services. This privacy policy (the “Policy”) explains our practices for processing your personal information. It does not apply to our employees’ personal information, business contact information, anonymized information or other information exempted from applicable privacy laws.

This Policy describes how we may collect, use, disclose, transfer, retain, dispose of and otherwise process (collectively, “process”), and how you may correct, update and access, your personal information that you provide or that we collect through our website located at https://britishproperties.com/ (the “BPP Website”) or the website of any of our “Communities” or projects linked through the BPP Website (together with the BPP Website, the “Website”), and the products, services, software and tools we provide through the Website (collectively, the “Services”). This Policy references our general Terms of Use located here, and forms an integral part of them.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using our Website or Services, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to us processing your personal information in Canada in accordance with this Policy and as may be further identified when the personal information is collected. If you do not consent to the processing of your personal information, please do not access or continue to use the Website or any of our Services, or otherwise provide any personal information to us.

KEY ELEMENTS OF THIS PRIVACY POLICY

Follow these links for quick access to the parts of this policy dealing with these issues:

• the personal information that we collect
• the purposes for which we collect, use and disclose information
• how we disclose and share information
• our approach to consent
• how we keep personal information secure
• how we use cookie and other tracking technologies
• how you can access and correct your personal information
• the limits on our collection, use, disclosure and retention of personal information
• our use of aggregated information
• how we may update this policy
• how to make inquiries or complaints regarding our privacy practices

1. Personal Information

In this Policy, “personal information” means any information about an identifiable individual or any information that can be used, either alone or in combination with other information, to identify an individual (for example, an individual’s name, mailing address, telephone number and email address), but excludes any information that is exempted by applicable privacy laws. For example, in Canada, personal information generally does not include any business contact information that is processed solely to communicate with that person about their employment or profession.

The types of information we receive and collect depends on how you use our Website and Services. Our Website has optional features and Services that, if used, require us to collect additional information to provide those features. You will be notified of that collection, as appropriate. If you choose not to provide the information needed to use a feature or Service, you will be unable to use the feature or Service.

Directly Collected Personal Information

When you use our Website or Services, we may collect the following personal information from you:

• Contact information, such as first and last name, email address, mailing address and phone number;
• In the case of applicants to the Design Approval Process, payment information, such as billing address and bank information; and
• Any other information you voluntarily provide through our Website or Services.

Your personal information may be collected when:

• You register for our mailing list on the Website;
• You apply for the Design Approval Process;
• You fill out free-form fields on the Website;
• You connect with us through social media;
• You interact with us through the Website or Services; and
• You communicate with us by phone or email.

We only collect personal information that we need. We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Automatically Collected Personal Information

We and our third-party partners may automatically collect and store information about you and any computer or device that you use to access our Website, as described in more detail in “Tracking Technologies, Advertising, and Analytics” below.

Collection from Third Parties

Except as described below regarding social media sites, we do not knowingly collect your personal information from a third party, unless you consent or we are otherwise exempted, authorized or required by applicable laws to do so. If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy or terms under which that information was collected.

If you post information about us or engage with us on third-party platforms, such as through your social media accounts, we may collect personal information about you from that third-party platform or account (e.g., your social media username and/or handle). These third-party platforms and services control the information that they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

Links to Other Sites

Our Website may contain links to other websites, applications or Internet resources (“Third-Party Services”) which are provided or made available solely for your convenience and information. When you click on one of those links you are contacting those Third-Party Services. We do not endorse and have no responsibility or liability for, nor do we have any control over, those Third-Party Services, their content or their processing of your personal information. We encourage you to read the privacy policies of those Third-Party Services to learn how they process your personal information.

Information about Minors

Our Website and Services are intended solely for users who are not minors (e.g. those who are 19 years of age or older in British Columbia). We do not knowingly collect personal information about any minor, and no minor, nor any parent or guardian as it relates to a minor, should submit that minor’s personal information to us through the Website, the Services or otherwise for any reason and under any circumstances. By using our Website or Services, you are representing that you are at least 19 years old.

If you believe that a minor has provided us with personal information without parental consent, please contact us at the address indicated in Section 11 below and we will work to delete that data from our systems.

2. Purpose for Which Personal Information is Processed

We may process your personal information for the following purposes:

• To verify and authenticate your identity;
• To operate, maintain and provide to you the Services and all features and functionality of the Website (including, where applicable, to complete the Design Approval Process);
• To maintain accurate records;
• To ensure that the Website or Services are optimized for your use and benefit;
• To analyze user experience and improve the Website or Services;
• To profile, tailor communications, and create personalized experiences, in accordance with applicable law;
• To provide you with requested information, process your questions and/or answer your queries;
• To communicate with you to provide you with information about us (including news releases, newsletters, home opportunities, project updates, similar projects notices, and upcoming promotions or events), in accordance with applicable laws;
• To solicit feedback from you about your satisfaction and experience with our Services (including through occasional surveys);
• To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by you through phone, email or the Website;
• To carry out our obligations arising from any contracts or transactions entered into between you and us (including through the Design Approval Process);
• To comply with internal policies and procedures and other legal, accounting or security requirements;
• To protect us, yourself and others from fraud and error, and to safeguard our business interests;
• To collect debts owed to us;
• To manage or transfer our assets or liabilities (for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services); and
• To share your personal information with our employees, contractors, consultants, professional advisors, and other third party service providers for any of the the purposes set out above.

We will not process your personal information for other purposes without your consent, except where authorized or required by law.

3. Disclosure or Transfer of Your Personal Information

We will not share your personal information with any third party, except as indicated in this Policy or as authorized or required by law.

We may disclose or transfer your personal information for the Purposes as described in this Policy in the following ways:

• To our employees, contractors and agents on an as-needed basis;
• To our affiliates and business partners;
• To our service providers such as website hosting providers, advertising agencies, payment processors, or customer service agencies.);
• To law enforcement, government or regulatory bodies, or other lawful authorities, as strictly required by law; and
• To third parties, in accordance with applicable law, in connection with a corporate reorganization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or securities, provided that the disclosed information continues to be used solely for the purposes permitted by this Policy by the entity acquiring the information.

If we require a third party to deal with your personal information, we will take reasonable steps to ensure that the third party adheres to privacy procedures and will keep your personal information confidential. We will not provide more information than is necessary to the third party and will ensure that the information is returned or destroyed once the purpose for which it was given is filled.

Our services providers may be located outside of Canada, and you acknowledge that personal information may be processed and stored in foreign jurisdictions, and that the governments, courts or law enforcement or regulatory agencies in those jurisdictions may be able to obtain disclosure of that personal information through the laws of the foreign jurisdiction. In these cases, we will comply with applicable local law requirements relating to the conditions for disclosure or release of personal information.

Important Exceptions

We may disclose your personal information to a third party without your consent if permitted or required by applicable law. We may also disclose your personal information, in accordance with applicable law, in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or business, provided that the disclosed information continues to be used solely for the purposes permitted by this Policy by the entity acquiring the information.

4. Legal Basis for Processing Your Personal Information

We collect, use, disclose and otherwise process your personal information in accordance with this Policy and applicable privacy laws. Where required by applicable laws, we will obtain your consent to engage in certain processing activities.

We will process your personal information only with your knowledge and consent, except where exempted, authorized or required by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested. Your consent may be express, with clear options to say “yes” or “no” (such as by being asked to check a box to indicate your consent), or implied (such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request). Your consent can also be provided by your authorized representative. When we process your personal information for a new purpose, we will document that new purpose and ask for your consent again.

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal, contractual or other restrictions and reasonable notice, by opting out of the use of your personal information by contacting our Privacy Officer (see Section 11 below). However, if you withdraw or change your consent, we may not be able to provide you with the Services.

Aside from consent, we may also process your personal information under other legal bases, as permitted or required by applicable laws.

5. Security of Personal Information

The security of your personal information is important to us. We protect the personal information in our custody or under our control using reasonable physical, technological and organizational safeguards designed to prevent unauthorized access, collection, use, disclosure, copying, modification, destruction or similar risks.

We will take reasonable measures, through contractual or other reasonable means, to ensure that our service providers implement a comparable level of protection.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure. As such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over the Internet.

6. Tracking Technologies, Advertising, and Analytics

Tracking Technologies

We may, to the extent permitted by applicable law and, where required, with your consent, use various methods and technologies to automatically store and collect information about you and any computer or device you use to access our Website, read our emails, use our Services or otherwise engage with us (“Tracking Technologies”). We may also allow our third-party partners to provide analytics services and serve advertisements on our behalf across the web and through our Services, and these entities may use Tracking Technologies to do so.

Where required by applicable law, we will request and obtain your consent before using these Tracking Technologies. Where and to the extent permitted by applicable law, by accessing or using our Services, you consent to the use of these Tracking Technologies as described in this Policy. Please do not use our Services if you do not consent to or are not comfortable with the ways in which we and any third parties described below use cookies and related technologies.

Tracking Technologies may set, change, alter or modify settings or configurations on your computer or device that you use to access our Services.

Tracking Technologies may include:

Cookies. When you visit or use the Website, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer or device that allows us to uniquely identify your browser, computer or device. See below for a description of the different types of cookies we may use. Cookies allow us to collect standard Internet log information about how and when you access and use our Website, including your IP address, unique device identifiers, device logs, location data, weblogs, time zone, date, your language preferences, browser settings and browsers used, browsing history and web addresses visited, links clicked, interaction events, scroll-to-page interactions, scroll position, other communication data, searches conducted and pages visited. We use cookies for a number of purposes, including to: ensure the Website is optimized for your use and for future communications between you and us; track your preferences you specify while using the Website; assist us to maintain and manage your status as logged in or logged out while you are using the Website; estimate and report our total audience size and traffic; and conduct research to improve our content, products and services. We may also use cookies and other technologies in online advertising campaigns to track responses to our ads.

Log Files. We may record log file information each time you access the Website. This information may include information such as: your IP address; browser type; unique device identifiers; information about your computer or device; number of click; how you interact with links, features or functionality on the Website; Flash version (if installed), whether Java is enabled; and other such information.

Usage Data. We may also collect information about the way you use our Website and/or Services. For example, the site from which you came and the site to which you are going when you leave our Website, the pages you visit, the links you click on, how frequently you access our Website, whether you open emails or click the links contained in emails, whether you access our Website from multiple devices, last login time, and other actions you take on our Website. We may collect analytics data, or use third-party analytics tools, to help us measure traffic, usage and marketing trends and behaviour for the Website.

There may be other Tracking Technologies now and later devised and used by us in connection with the Services.

Cookies

We may use cookies for the following purposes:

Strictly Necessary Cookies: These cookies and similar technologies are necessary for our Services to function and cannot be switched off in our systems. They are usually only set in response to actions that you make that amount to a request for services, such as setting your privacy preferences, logging in to an account, or filling in forms. Without these cookies, we cannot respond to your requests or provide you with the services you request or access on our Services. You can set your browser to block or alert you about these technologies, but some parts of the Services will not then work properly or be available to you. If you do not consent to our uses of such cookies, please do not use our Services.

Functional Cookies: Functional cookies enable us to provide enhanced functionality and personalization. For example, we use these cookies to remember settings you’ve applied, such as language, to provide and show embedded videos and content, and to make available certain other features on our websites. Some of these cookies are managed for us by third parties, including by third-party providers whose services we have added to our Services. If you do not allow these cookies, then certain features on our websites may not be available or function properly.

Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around our sites. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance, which may affect our ability to make recommendations to you and may slow website performance.

Targeting Cookies: These cookies may be set through our site by third parties, including our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on our website and on other sites, and to measure and improve our advertising and marketing. If you do not allow these cookies, you will still see ads and targeted content, but they may be less relevant to you.

We use these cookies, to operate, understand and improve our Services and for the following purposes:

• To authenticate you and secure our Services: We use first party cookies to monitor login, session and status data. This allows us to know, for example, whether you are logged in.
• To remember your settings and preferences: We use cookies to recognise your browser and remember your preferences. For example, we use cookies to remember your language preferences.
• To carry out analytics and research: We use cookies to understand your use of our Services and how we can improve our offerings. For example, we use cookies to track whether you open emails we send you.
• To assist with advertising and marketing efforts: We use cookies to personalise your use of our Services, including to serve you personalised advertising that may better suit your needs.
• To detect fraud, trust and safety, and investigations: We use cookies to keep our Services safe, including to detect and prevent fraud and conduct investigations.

We may use these types of cookies:

First-Party Cookies: These are cookies that we place on your computer or device directly.

Third-Party Cookies: These are cookies that are placed on your computer or device by other parties. Third-party cookies enable third-party features or functionality within the site, such as site analytics, advertising and social media features. The parties that set these third party cookies can recognise your computer or device both when it visits the site in question and also when it visits certain other sites and/or apps. We do not control how these third parties use your information, which is subject to their own privacy policies.

Session Cookies: Session cookies are placed on your computer or device during a browser session or mobile application session (the time between when an internet browser or application is opened and closed). Session cookies expire and are normally deleted at the end of a session.

Persistent Cookies: Persistent cookies are placed on your computer or device during a browser or application session but remain on your computer or device after the session ends.

Third-party Advertising and Analytics

A number of third-party advertising and analytics cookies are set on our Services, some of which depend on how you use our Services. Our advertising partners may use pixels or similar technology to measure the success of the sponsored posts or other advertising products they use. A “pixel” (also sometimes called web beacon, or clear GIF) is a tiny piece of code, invisible to the user, placed on a webpage or in an email and used in combination with a cookie, to link a given activity or impression back to the user; the advertiser includes it in its content so it can measure whether our users interact with that content (for example, by clicking to view an offer).

Third-Party Advertising: More information about how third-party cookies are used for targeted advertising, and how to opt out of certain third-party advertising-related cookies, is available here: Digital Advertising Alliance of Canada’s Opt-Out Tool

Third-Party Analytics: We may use third-party analytics tools, including Google Analytics (see below), to collect, monitor and analyze information to improve functionality and user-friendliness, and to better tailor our Services to visitors’ needs. We may share information from these sources with third parties, each of which have their own privacy policy addressing how they use the information and any choices you have about their collection and use of information. We recommend that you review these policies.

Google Analytics: Google Analytics is a web analytics service provided by Google, Inc. (“Google”). Google uses cookies to help us analyze how users use our Services. For more information about Google Analytics cookies, please see Google’s help pages and privacy policy. Google has developed the Google Analytics opt-out browser add-on; if you want to opt out of Google Analytics, you can download and install the add-on for your web browser here. The information generated by the cookie about your use of one of our Services (including your IP address) will be transmitted to and stored by Google on servers in the United States. On behalf of our Services, Google will use this information for the purpose of evaluating your use of the Services, compiling reports on your activity for us and third parties who help operate and provide services related to our Services. You may refuse the use of these cookies by selecting the appropriate settings on your browser as discussed in this Policy. However, if you do this, you may not be able to use the full functionality of the Services.

Social Media Links

Some of the content on our Services may include applications made available by third parties, which could include social media buttons or links that allow you to share content or links to our Website through those third-party platforms. These third-party platforms themselves may facilitate the collection of information by those third parties, through your interaction with the platforms and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these platforms or the collection and use practices of the relevant third parties. Please visit the relevant third-party platforms to understand their privacy practices and options they may make available to you into their collection of your personal information.

Social Media Retargeting

If we advertise to you on social media and other platforms we may share your email address (usually in an encrypted or ‘hashed’ form) with third-party ad partners or social media platforms and other services, such as Facebook and Google (“Social Platforms”), so that the third party providers can try to “match” your information with the information of their registered users of their Social Platforms. We do this by providing a list of hashed email addresses to Social Platforms or incorporating a pixel from Social Platforms into our own Services, and the Social Platforms matching common factors between our information and their information collected through cookies or pixels or similar technologies. For instance, we may incorporate the Facebook pixel on our Services and may share your email address with Facebook as part of our use of Facebook Custom Audiences. Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g., on your Facebook newsfeed). This is known as “custom audience” advertising, because we “customise” the audience that we want to reach on the relevant service.

If we advertise to other people who share similar interests and characteristics to you, we may also provide your personal information to Social Platforms. If you use those Social Platforms, we may ask the Social Platforms to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other users. This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” you.

These activities are also subject to the privacy choices and preferences you have made on the applicable third-party services and Social Platforms.

The applicable Social Platform act as our service provider and in other contexts may also be independently using, on their own behalf, the personal information that is collected via your use of our social media pages. Please see the applicable Social Platform’s privacy policy for details of how it uses your personal information and how to exercise your rights with respect to your information.

Managing Preferences

When you visit our website, you can change your cookie preferences by clicking on the “Customize Settings” button on the cookie banner to bring you to our Privacy Preference Centre.

In addition to the options given to you in our Privacy Preference Centre, you may refuse or restrict the use of cookies by selecting the appropriate settings in your browser. However, limiting or refusing cookies may affect your ability to use some of our Services. Our website responds to global privacy control—or “GPC”—signals, which means that if we detect that your browser is communicating a GPC signal, we will, subject to applicable law, process that as a request to opt that particular browser and device out of sales and sharing on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to enable GPC or set your cookie preferences for each browser and device you use to access our website. More information about GPC is available at https://globalprivacycontrol.org.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. Some advertising networks offer you a way to opt-out of targeted advertising.

In addition to the options given to you in our Privacy Preference Center, your mobile device may include a feature that allows you to opt-out of some types of targeted advertising, such as the “limit ad tracking” option in your iOS or Android device’s privacy settings. Visit the Network Advertising Initiative’s mobile choices page at https://www.networkadvertising.org/mobile-choice/ for more information. The Digital Advertising Alliance of Canada also provides a mobile app that lets you opt-out of interest based advertising from participating advertisers found at: https://youradchoices.ca/en/tool-faqs.

7. Privacy Rights and Choices

Accessing Your Personal Information

You have a right to access your personal information that we hold.

Upon your written request, we will provide you with your personal information in our possession or under our control. We will also provide you with information about the ways in which that information is being used and a description of the individuals or organization to whom that information has been disclosed. We may charge you a reasonable fee for doing so.

We may need to request specific information from you to help us confirm you identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who does not have a right to receive it.

In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege). We may also be prevented by law from providing access to certain personal information. If we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps that are available to you.

Correcting Your Personal Information

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

If a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information in our possession or under our control with a note that the correction was requested but not made or otherwise complete such additional actions as required by applicable law.

8. Limits on our Collection and Retention of Your Personal Information

We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.

Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.

We will delete, destroy, erase, aggregate or make anonymous documents or other records containing personal information as soon as it is reasonably to assume that the original purpose is no longer being served by retention of the information and retention is no longer required for a legal or business purpose.

We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.

9. Aggregate Data and Non-identifiable Data

We may use and disclose aggregate, anonymous and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (e.g. data that is no longer reasonably linked or linkable to an identified or identifiable individual, household, or personal or household device) we will maintain and use the information in de-identified form and not attempt to re-identify the information, except in order to determine whether our de-identification processes are reasonable and adequate pursuant to applicable privacy laws.

10. Updates or Changes to this Policy

This Policy was last updated as of the “Last updated” date set out at the beginning of this Policy.
We may update this Policy time to time to ensure ongoing compliance with applicable laws and for any other purpose that we deem reasonably necessary. We therefore encourage you to periodically review this Policy to ensure you are aware of any changes.

If we make any material changes we will either (a) notify you by email (sent to the email address listed in our records), or (b) provide a notice on the Website before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected after the date that this Policy is posted or on the date as specified in the notification. Your continued use of the Website or Services following the effective date of any changes to this Policy signifies your acceptance of such changes.

11. Contact Information for Privacy Officer

If you have any questions or concerns regarding our compliance with this Policy and our processing of your personal information, you may contact our Privacy Officer at privacy@britishproperties.com

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws. Our Privacy Officer will provide you with the contact information to do so if requested.