LARCO INVESTMENTS LTD. PRIVACY POLICY AND PRIVACY CODE

INTRODUCTION

The contents of this document apply to the business operations of the parent company, Larco Investments Ltd., and the businesses that it operates under various trade names such as Maple Leaf Property Management, Maple Leaf Self Storage or Park Royal Shopping Centre. Legally Larco Investments Ltd., (“LARCO” or “the Company”), is comprised of a number of subsidiaries being principally, among others, Larco Hospitality Inc., Maple Leaf Self Storage Inc., Park Royal Shopping Centre Holdings Ltd., and Maple Leaf Self Storage Holdings Ltd. Larco is a fully integrated real estate company carrying on business in the retail, hospitality, industrial and residential market place.

LARCO is committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. As required by the British Columbia Personal Information Protection Act, LARCO has instituted its own Privacy Policy and Privacy Code to reflect the new standards concerning personal information and to address increasing customer and employee concerns about the protection of personal information.

The LARCO PRIVACY POLICY AND PRIVACY CODE (the “LARCO Privacy Policy”) is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by LARCO to its customers and employees. The objective of the LARCO Privacy Policy is to ensure responsible and transparent practices in the management of personal information, in accordance with legislative requirements of the areas in which the Company carries on business activities.

LARCO commits to review its Privacy Policy at least once every five years to ensure it is relevant and remains current with changing technologies and laws and the evolving needs of the Company, its customers and employees.

SUMMARY OF PRINCIPLES

Principle 1 – Accountability

Principle 2 – Identifying Purposes for Collection of Personal Information

LARCO shall identify the purposes for which personal information is collected at or before the time the information is collected.

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

The prior knowledge and consent of a customer or employee are required for the collection, use, or disclosure of personal information, except as permitted or required by law.

Principle 4 – Limiting Collection of Personal Information

LARCO shall limit the collection of personal information to that which is reasonably necessary for the purposes identified by the Company. LARCO shall collect personal information by fair and lawful means.

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

LARCO shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law. LARCO shall retain personal information only as long as is necessary for the fulfillment of the purposes for which it was collected.

Principle 6 – Accuracy

The personal information LARCO maintains shall be as accurate, complete, and current as is necessary for the identified purposes for which it is to be used.

Principle 7 – Security Safeguards

LARCO shall protect personal information by with the use of safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness

LARCO shall make readily available to our customers and employees specific information about its policies and practices relating to its management of their personal information.

Principle 9 – Customer and Employee Access to Personal Information

LARCO shall upon request, provide a customer or employee with access to his/her personal information in the possession of LARCO as well as the use and/or disclosure of that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

In addition, a customer may choose to delete any or all of their personal information in LARCO’s records at any time, subject to the understanding that it may be impossible to completely delete all information without some residual information due to backups and that such deletion may affect the ability to provide some or all services.

Principle 10 – Complaints and Suggestions

A customer or employee shall be able to address any complaint concerning compliance with the above principles to the person accountable for LARCO’s compliance with this Policy.

APPLICATION

The ten principles that form the basis of the LARCO Privacy Policy are interrelated and LARCO shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. The commentary in the LARCO Privacy Policy has been tailored to reflect personal information issues specific to LARCO.

The scope and application of the LARCO Privacy Policy are as follows:

The LARCO Privacy Policy applies to personal information about LARCO’s customers and employees that is collected, used, or disclosed by the Company.
The LARCO Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
The LARCO Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by LARCO:
1. information that is publicly available, such as a customer’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; or
2. the name, title or business address or telephone number of an employee of an organization.
The application of the LARCO Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations, or order of any court, or other lawful authority.

DEFINITIONS

Collection – the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either expressed or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given verbally, electronically or in writing, and does not require any inference on the part of LARCO. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

Customer – an individual who engages, contracts with, uses, or applies to use LARCO’s products or services or otherwise provides personal information to LARCO in the course of the Company’s commercial activities.

Disclosure – making personal information available to a third party.

Employee – an employee of LARCO, and for the purpose of the LARCO Privacy Policy only, includes independent and other contractors performing services within LARCO.

LARCO – Larco Investments Ltd., and its affiliates and subsidiaries in which LARCO exercises control.

Personal information – information about an identifiable individual but not aggregated information that cannot be associated with a specific individual.

For a Customer, such information includes contact information that is not otherwise publicly available, credit information, billing records, records (including any correspondence, or any other documentary materials), accounts, intentions, any recorded complaints and information about personal characteristics or preferences.

For an Employee, such information includes information found in personal employment files, application forms, performance appraisals, reference checks, work product or work performance information, and medical and benefits information.

Third party – an individual other than the customer, or the customer’s agent, or an organization separate from LARCO.

Use – the treatment, handling, and management of personal information by and within LARCO.

PRINCIPLE 1 – ACCOUNTABILITY

LARCO is responsible for personal information under its control. LARCO’s Vice President, Finance & Administration, is accountable for the Company’s compliance with the LARCO Privacy Policy and is LARCO’s Privacy Officer. The Privacy Officer can be reached at 300 – 100 Park Royal, W. Vancouver, BC V7T 1A2, tel: (604) 925-2700.

1.1

Other individuals within LARCO may be delegated to act on behalf of LARCO’s Vice President, Finance & Administration, or to take responsibility for the day-to-day collection and processing of personal information.

1.2

LARCO is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing or other purposes related to LARCO’s business and operations. LARCO shall use contractual or other means to provide a comparable level of protection while the information is in the possession of the third party. (See principle 7)

1.3

LARCO shall implement policies and procedures to give effect to the LARCO Privacy Policy, including:

implementing procedures to protect personal information and to oversee the Company’s compliance with the LARCO Privacy Policy;
establishing procedures to receive and respond to inquiries or complaints;
training and communicating to employees about the Company’s policies and practices; and
developing public information to explain the Company’s policies and practices.

Principle 2 – Identifying Purposes for Collection of Personal Information

LARCO shall identify the purposes for which personal information is collected at or before the time the information is collected.

2.1

LARCO collects personal information only for the following purposes:

to establish and maintain responsible commercial relations with customers and to provide ongoing service;
to understand customer needs and preferences;
to develop, enhance, market or provide products and services;
to manage and develop LARCO’s business and operations, including personnel and employment matters; and
to meet legal and regulatory requirements.

Further references to “identified purposes” in this Privacy Policy mean the purposes identified in this Principle 2.

2.2

LARCO shall specify verbally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within LARCO who shall explain the purposes.

2.3

Unless required by law, LARCO shall not use or disclose for any new purpose personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.

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

The prior knowledge and consent of a customer or employee are required for the collection, use, or disclosure of personal information, except as required or permitted by law.

3.1	In certain circumstances, personal information can or must be collected, used or disclosed without the knowledge and consent of the individual. In such cases, LARCO will provide notice of the collection, use or disclosure of the information as soon as and to the extent that it is possible to do so without undermining the purposes of the collection, use or disclosure.
3.2	In obtaining consent, LARCO shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information is being or will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.
3.3	Generally, LARCO shall seek consent to use and disclose personal information at the same time it collects the information. However, LARCO may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.
3.4	LARCO will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.
3.5	In determining the appropriate form of consent, LARCO shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.
3.6	In general, the use of LARCO’s products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for LARCO to collect, use and disclose personal information for all identified purposes and the reasonableness of the use of the information for those purposes.
3.7	A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, and with the understanding that such withdrawal of consent may impact the ability of LARCO to continue to provide services to the customer. Customers may contact LARCO for more information regarding the implications of withdrawing consent.

Principle 4 – Limiting Collection of Personal Information

4.1	LARCO collects personal information primarily from its customers or employees.
4.2	LARCO may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.

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

5.1	In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)
5.2	In addition, LARCO may disclose a customer’s personal information to: a company involved in supplying the customer with services and products in the normal course of the customer’s business; another person for the development, enhancement, marketing or provision of any of LARCO’s products or services; credit grantors, reporting and collection agencies; a person who, in the reasonable judgment of the Company, is seeking the information as an agent of the customer; and a third party or parties, where the customer consents to such disclosure or disclosure is required by law.
5.3	LARCO may use and disclose personal information about its employees: for normal personnel and benefits administration, including regulation of the workplace and the conduct of employees; in the context of providing references regarding current or former employees in response to requests from prospective employers and/or where consent to provide a reference has been given by the employee; or where disclosure is required or otherwise permitted by law.
5.4	Only those LARCO employees who require access for business reasons are granted access to personal information about customers and other employees.
5.5	LARCO shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, LARCO shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.
5.6	LARCO shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction, which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 – Accuracy

The personal information LARCO maintains shall be as accurate, complete, and current as is necessary for the identified purposes for which it is to be used.

6.1	Personal information used by LARCO shall be sufficiently accurate, complete, and current to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.
6.2	LARCO shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 – Security Safeguards

LARCO shall protect personal information with the use of safeguards appropriate to the sensitivity of the information.

7.1	LARCO shall use appropriate security measures to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction regardless of the format in which it is held. LARCO shall use care in disposing of or destroying personal information, to prevent unauthorized parties from gaining access to the information.
7.2	LARCO shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3	All of LARCO’s employees with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.

Principle 8 – Openness

LARCO shall make readily available to our customers and employees specific information about its policies and practices relating to its management of their personal information.

8.1

LARCO shall make information about its policies and practices easy to understand, including:

the title and address of the person or persons accountable for the Company’s compliance with the LARCO Privacy Policy and to whom inquiries or complaints can be forwarded;
the means of gaining access to personal information held by the Company; and
a description of the type of personal information held by the Company, including a general account of its use.

8.2

LARCO shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy-enhancing services available from the Company.

Principle 9 – Customer and Employee Access to Personal Information

LARCO shall, upon request, provide a customer or employee with access to his/her personal information in the possession of LARCO as well as the use and/or disclosure of that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

9.1	Upon request, LARCO shall afford customers and employees a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in an understandable form within a reasonable time and at a minimal or no cost to the individual.
9.2	In certain situations, LARCO may not be able to provide access to all of the personal information it holds about a customer or employee, if such information is required or permitted by law to be withheld. If this occurs, LARCO shall provide the reasons for denying access. Reasons for denying access may include but are not limited to: if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual; if disclosure would reveal confidential commercial information; if the information is protected by solicitor-client privilege; if the information was generated in the course of a formal dispute resolution process; if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law; or if the information is prohibitively costly to provide.
9.3	Upon request, LARCO shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information.
9.4	In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit LARCO to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
9.5	LARCO shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, LARCO shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences. In addition, a customer may choose to delete any or all of their personal information in LARCO’s records at any time subject to the understanding that it may be impossible to completely delete all information without some residual information due to backups and that such deletion may affect the ability to provide some or all services.
9.6	A customer can obtain information or seek access to his or her individual files by contacting a designated representative at LARCO’s Corporate Office.
9.7	An employee can obtain information or seek access to his or her individual files by contacting his or her immediate supervisor within LARCO.

Principle 10 – Complaints and Suggestions

A customer or employee shall be able to address any complaint concerning compliance with the above principles to LARCO’s Privacy Officer or his/her designate.

10.1	LARCO shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees about the Company’s handling of personal information.
10.2	LARCO shall inform its customers and employees about the existence of these procedures as well as the availability of complaint procedures.
10.3	The person or persons accountable for compliance of the LARCO Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.
10.4	LARCO shall investigate all complaints concerning compliance with the LARCO Privacy Policy. If a complaint is found to be justified, the Company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.

For inquiries, complaints, more information or additional copies of the LARCO Privacy Policy and Privacy Code contact:

Larco Privacy Officer

Larco Investments Ltd.
Suite 300
100 Park Royal
West Vancouver, BC V7T 1A2

Tel: 604-925-2700

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