Privacy Policy

1. Our Commitment to Privacy

Creiland Capital, Creiland Consultants Realty Inc., Brokerage, and CBM Corporation respect your privacy and are committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you:

  • Visit our websites;

  • Create an account or use one of our online platforms;

  • Apply as an investor, sponsor, borrower or client;

  • Review or participate in an investment opportunity;

  • Submit a property, project or financing opportunity;

  • Use our brokerage, investment, financing or advisory services;

  • Attend an event or webinar;

  • Subscribe to our communications; or

  • Otherwise communicate or do business with us.

In this Privacy Policy, “Creiland,” “we,” “us” and “our” refer collectively to:

  • Creiland Capital;

  • Creiland Consultants Realty Inc., Brokerage; and

  • CBM Corporation.

These businesses are affiliated and may share certain personnel, administrative systems, technology and service providers. The entity responsible for your personal information will depend on the service you request, the agreement you enter into and the nature of your relationship with us.

2. What Is Personal Information?

Personal information means information about an identifiable individual. It may include your name, contact information, identification documents, financial information, investment information, transaction history and other information that can reasonably be connected to you. Personal information generally does not include business contact information used solely to communicate with an individual in their professional or business capacity, where excluded by applicable law.

3. Information We Collect

The information we collect depends on how you interact with us and which services you use.

Contact and Account Information

  • Full legal name;

  • Email address and telephone number;

  • Residential or business address;

  • Province, territory, state and country of residence;

  • Company name and job title;

  • Username and account information;

  • Communication preferences; and

  • Records of your communications with us.

Identity and Compliance Information

  • Citizenship, residency and tax residency information;

  • Tax identification information;

  • Government issued identification;

  • Proof of address;

  • Occupation and employment information;

  • Corporate and organizational records;

  • Information about directors, officers and authorized representatives;

  • Beneficial ownership and control information;

  • Politically exposed person information;

  • Sanctions and compliance-screening results;

  • Source of funds information; and

  • Source of wealth information.

Sponsor and Project Information

If you apply as a real estate sponsor, developer, property owner, fund manager or project operator, we may collect:

  • Corporate and ownership records;

  • Information about principals and management;

  • Business history and track record;

  • Financial statements and financial models;

  • Credit and background information;

  • Litigation, insolvency and regulatory information;

  • Professional, lender and investor references;

  • Details about the proposed property, fund or project;

  • Purchase, ownership and financing documents;

  • Appraisals and valuation information;

  • Environmental, engineering, construction and planning reports;

  • Project budgets and schedules; and

  • Other legal, financial or property-level due-diligence materials.

When you provide personal information about another individual, you confirm that you are authorized to provide that information to us.

Commercial Real Estate Brokerage Information

When dealing with Creiland Consultants Realty Inc., Brokerage, we may collect information relating to:

  • Property ownership;

  • Acquisition, disposition and leasing requirements;

  • Financial capacity and transaction requirements;

  • Property searches and preferences;

  • Offers, agreements and transaction documents;

  • Client identification and beneficial ownership;

  • Financing arrangements; and

  • Other information required to provide commercial real estate brokerage or advisory services.

CBM Corporation Information

When dealing with CBM Corporation, we may collect information relating to:

  • Financing or borrowing requirements;

  • Loan applications;

  • Income, assets and liabilities;

  • Credit and financial information;

  • Proposed collateral and ownership of collateral;

  • Banking and payment information;

  • Digital wallet or custody information, where applicable;

  • Source of funds;

  • Guarantor information; and

  • Supporting financial, legal and identification documents.

Website and Technical Information

  • Internet Protocol address;

  • Browser and device type;

  • Operating system;

  • Login and account activity;

  • Pages visited and features used;

  • Date and time of access;

  • Referring website;

  • General geographic location;

  • Cookie and analytics information;

  • Error and performance information; and

  • Security and fraud-prevention information.

3. Information We Collect

We may collect personal information:

  • Directly from you;

  • Through our websites, portals and digital platforms;

  • Through applications, forms, questionnaires and agreements;

  • During telephone calls, meetings and email communications;

  • From another Creiland affiliated entity, where permitted;

  • From an issuer, sponsor, borrower, referral partner or professional adviser;

  • From a registered exempt market dealer;

  • From identity verification, compliance or background screening providers;

  • From financial institutions, custodians and payment providers;

  • From public, regulatory, credit and professional sources; and

  • Through cookies and similar technologies.

5. How We Use Personal Information

We may use personal information to:

  • Respond to inquiries;

  • Create, administer and secure accounts;

  • Provide commercial real estate brokerage and advisory services;

  • Review investment, property, project and financing opportunities;

  • Complete investor, sponsor, borrower and client onboarding;

  • Verify identity and beneficial ownership;

  • Conduct KYC, AML, sanctions and fraud screening;

  • Confirm investor eligibility;

  • Assess sponsor experience and project readiness;

  • Conduct legal, financial and property level due diligence;

  • Process investment subscriptions, loans, payments, distributions and repayments;

  • Maintain investor, client, transaction and ownership records;

  • Administer tokenized limited partnership units or other digital securities;

  • Deliver offering documents, agreements and electronic notices;

  • Provide project updates, financial reports and tax documents;

  • Communicate material changes;

  • Operate, maintain and improve our websites and platforms;

  • Detect unauthorized access, fraud and security threats;

  • Meet legal, regulatory, tax, accounting and reporting obligations;

  • Establish, exercise or defend legal rights;

  • Conduct internal business analysis; and

  • Send permitted marketing communications.

We will not use personal information for a materially different purpose without obtaining additional consent, unless the use is otherwise permitted or required by law.

6. Exempt Market Dealer, KYC and AML Verification

Investment opportunities offered through the Creiland Capital platform may require identity verification, know your client procedures, anti-money-laundering screening, sanctions checks, beneficial-ownership verification, investor eligibility confirmation and suitability or appropriateness assessments.

For each applicable offering, a registered exempt market dealer will act as the dealer and KYC/AML provider. The EMD may be responsible for:

  • Investor onboarding;

  • Identity verification;

  • KYC and AML screening;

  • Beneficial-ownership verification;

  • Investor eligibility review;

  • Suitability or appropriateness assessments;

  • Subscription processing;

  • Regulatory recordkeeping; and

  • Other dealer-related compliance obligations.

The EMD may collect personal information directly from investors. Information submitted directly to the EMD may be governed by the EMD’s own privacy policy and legal obligations. Creiland Capital may disclose relevant information to the EMD where necessary to support investor onboarding, subscription processing and regulatory compliance. Completing onboarding, KYC or AML verification does not guarantee acceptance into an offering.

7. Issuers and Official Ownership Records

The legal issuer of each investment will be identified in the applicable offering documents. Depending on the offering, the issuer may be a corporation, limited partnership, trust, fund or other legal entity. The issuer or its appointed transfer agent or registrar will be responsible for maintaining the official securities and ownership records.

The exempt market dealer acts as the registered dealer and KYC/AML provider. It does not act as the legal issuer or official securities registrar unless it is separately and expressly appointed to perform an additional role.

An investor’s legal rights are determined by the applicable offering documents, subscription agreement, limited partnership agreement, shareholder agreement and official securities register.

8. When We Share Personal Information

We may share personal information among Creiland Capital, Creiland Consultants Realty Inc., Brokerage, and CBM Corporation where reasonably necessary to:

  • Respond to inquiries;

  • Direct you to the appropriate service;

  • Administer an account or transaction;

  • Review a property, investment or financing opportunity;

  • Verify information already provided;

  • Prevent fraud;

  • Meet legal or regulatory requirements; or

  • Provide a service you requested.

We may also disclose information to authorized third parties, including:

  • Exempt market dealers and other registered securities firms;

  • Issuers, funds, limited partnerships and general partners;

  • Investment managers and real estate sponsors;

  • Transfer agents and securities registrars;

  • KYC, AML, identity verification and sanctions screening providers;

  • Banks, custodians and payment processors;

  • Tokenization and digital platform providers;

  • Website hosting and cloud storage providers;

  • Customer relationship management and communications providers;

  • Lawyers, accountants, auditors and tax advisers;

  • Appraisers, engineers, environmental consultants and other real estate professionals;

  • Insurance providers;

  • Regulators, government agencies, courts and law enforcement authorities;

  • Parties involved in a proposed financing, sale, merger or restructuring of our business; and

  • Other parties authorized or directed by you.

Service providers are expected to use personal information only for the services they provide and to maintain safeguards appropriate to the sensitivity of the information. We do not sell or rent personal information to third parties for their independent marketing purposes.

9. Service Providers and Processing Locations

We use third-party service providers to support our websites, platforms and business operations. These services may include hosting, cloud storage, customer relationship management, identity verification, KYC and AML administration, payment processing, communications, tokenization technology and professional services. Our service providers may store or process personal information in Canada or in other jurisdictions where they or their approved subcontractors operate. When information is processed outside Canada, it may be subject to the laws of the jurisdiction in which it is stored or processed and may be accessible to courts, law-enforcement agencies or government authorities in accordance with applicable law. We take reasonable steps, including contractual, administrative and technical measures, to require service providers to protect personal information and use it only for authorized purposes. Our providers and their processing locations may change as our business and technology requirements evolve.

10. Tokenized Investments and Digital Records

Where applicable, an investment may be represented by tokenized limited partnership units or another form of digital security. Certain wallet addresses, transaction identifiers or ownership related records may be maintained through a permissioned ledger, blockchain or other tokenization system.

We generally seek to avoid recording government identification, banking information or other unnecessary personal information directly on a blockchain or distributed ledger. Identity, compliance and subscription records will generally be maintained separately by the applicable issuer, EMD, transfer agent, registrar, KYC provider or platform service provider.

Information recorded on a blockchain or distributed ledger may be difficult or impossible to alter or delete. The legal rights associated with an investment are determined by the applicable offering documents and official ownership records, not solely by possession of a token.

11. Cookies and Analytics

Our websites may use cookies, pixels and similar technologies to:

  • Operate website features;

  • Maintain secure login sessions;

  • Remember preferences;

  • Understand how visitors use the website;

  • Monitor website performance;

  • Detect suspicious activity; and

  • Measure communications or marketing performance.

Some cookies are necessary for the website to function. Other cookies may be optional. You may be able to manage cookies through your browser settings or a cookie-preference tool where one is available. Disabling certain cookies may affect website functionality. Third party analytics or communication providers may collect technical information in accordance with their own privacy policies.

12. Marketing Communications

We may send information about our services, investment opportunities, projects, events, webinars or platform updates where you have provided consent or where the communication is otherwise permitted by law.

You may unsubscribe from marketing communications at any time by using the unsubscribe link in the message or contacting us at [email protected].

Unsubscribing from marketing messages will not prevent us from sending necessary account, transaction, investment, compliance or security communications.

13. Consent and Withdrawal of Consent

By providing personal information to us, you consent to its collection, use and disclosure for the purposes described when the information is collected and in this Privacy Policy. You may withdraw consent for certain uses by contacting us. Withdrawal of consent will not affect information already collected, used or disclosed with valid consent. In some cases, withdrawing consent may prevent us from providing an account, processing a transaction or continuing a requested service. We may continue to retain, use or disclose information where required or permitted by law, regulation, contract or professional obligation.

14. Retention of Information

We retain personal information only for as long as reasonably necessary to:

  • Provide the requested services;

  • Administer an account, investment, loan or real estate transaction;

  • Maintain investor, client and ownership records;

  • Meet securities, brokerage, KYC, AML, tax and regulatory obligations;

  • Prevent fraud and maintain platform security;

  • Resolve disputes; and

  • Establish, exercise or defend legal and contractual rights.

Retention periods may differ depending on the information, relationship, transaction and applicable legal requirements. When information is no longer required, we will take reasonable steps to securely destroy, delete or anonymize it, subject to legal, regulatory and technical limitations.

15. How We Protect Personal Information

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information.

These safeguards may include:

  • Access controls and role-based permissions;

  • Password and authentication requirements;

  • Encryption where appropriate;

  • Secure document-storage systems;

  • Network and platform monitoring;

  • Confidentiality requirements;

  • Service-provider agreements;

  • Employee and contractor training;

  • Data-backup procedures; and

  • Security and incident-response processes.

No electronic transmission or storage system can be guaranteed to be completely secure.

16. Privacy and Security Incidents

If we become aware of a privacy or security incident, we will investigate and take reasonable steps to contain the incident, reduce potential harm and prevent a recurrence. Where required by applicable law, we will notify affected individuals and report the incident to the appropriate privacy regulator.

17. Accessing and Correcting Your Information

You may request:

  • Access to personal information we hold about you;

  • Correction of inaccurate or incomplete information;

  • An update to your account details;

  • Withdrawal of certain consent;

  • A change to your communication preferences; or

  • Deletion of information, subject to legal and regulatory retention requirements.

We may need to verify your identity before responding to a request. Access may be restricted where permitted or required by law, including where disclosure would reveal another individual’s personal information, confidential commercial information or information protected by legal privilege.

18. Children and Minors

Our investment, financing and commercial real estate platforms are intended for individuals who have reached the age of majority in their jurisdiction. We do not knowingly accept investments from minors or intentionally collect personal information from individuals who are not legally able to enter into the applicable agreements.

19. Third-Party Websites

Our websites and platforms may contain links to third party websites or services. We do not control and are not responsible for the privacy, security or content practices of third parties. You should review the privacy policy of a third party service before providing personal information to it.

20. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our services, business operations, technology, service providers or legal obligations. The updated version will be posted on our website with a revised “Last Updated” date. Where a change is material, we may provide additional notice through our website, platform or email.

21. Contact Our Privacy Officer

Questions, requests or concerns regarding this Privacy Policy or our handling of personal information may be directed to:

Privacy Officer

Creiland Capital

Creiland Consultants Realty Inc., Brokerage

CBM Corporation

250 Consumers Road, Suite 1007

Toronto, Ontario M2J 4V6

Canada

Email: [email protected]

Telephone: 1-800-980-6668

Please include “Privacy Request” in the subject line and provide enough information for us to understand and respond to your request.

We will review privacy concerns and make reasonable efforts to resolve them. Individuals may also contact the Office of the Privacy Commissioner of Canada or another applicable privacy regulator regarding concerns about the handling of their personal information.

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