Brookfield Real Estate Services Manager Limited (the "Company"), respects the privacy and security of our Internet users and are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following Privacy Policy to ensure that the Company continues to meet its commitment to your privacy.

"Personal Information" means information about an identifiable individual. This may include without limitation, the individual's name, address, age, gender, income, employment status, credit history, debts and liabilities, income, personal preferences and other information about his or her family. Personal information does not include the name, title or business address or telephone number of an employee of an organization.

The Company’s Privacy Policy is based on, and complies with, Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at

This privacy policy describes the ten principles that the Company follows to ensure that we protect your personal information when we collect, use or disclose it in the course of carrying on commercial activities. All of our employees who have access to personal information must adhere to this Privacy Policy and related procedures. To this end, the Company has appointed a Privacy Officer who has the ultimate responsibility for ensuring compliance within the Company and by all of the Fund’s employees.

This introduction and the following sections, read as a whole, comprise the Company’s Privacy Policy:

  1. The Ten Principles of Privacy
  2. Application of the Ten Privacy Principles
  3. Questions, Concerns and Complaints

The following ten principles govern our actions as they relate to the use of the personal information we collect:

  • Principle 1 – Accountability
  • Principle 2 – Identifying Purposes
  • Principle 3 – Consent
  • Principle 4 – Limiting Collection
  • Principle 5 – Limiting Use, Disclosure and Retention
  • Principle 6 – Accuracy
  • Principle 7 – Safeguarding Personal Information
  • Principle 8 – Openness
  • Principle 9 – Individual Access
  • Principle 10 – Questions and Concerns
Principle 1 – Accountability

The company is accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by you.

Principle 2 – Identifying Purposes

The Company will inform you of the purposes for which it is collecting any personal information, unless otherwise apparent, before or at the time the information is collected.

Principle 3 – Consent

The Company will seek to obtain consent from you before or when we collect, use or disclose your personal information. The Company will strive to ensure that individuals understand how their personal information will be used or disclosed.

An individual's consent can be express, implied, or given through an authorized representative. An individual can withdraw consent at any time, with certain exceptions. Individuals may contact the Company’s Privacy Officer respecting the withdrawal of any previously given consent or any change in the purposes for which information held by the Company may be used, disclosed or retained. Additionally, information may be retained by the Company for audit or archival purposes notwithstanding any withdrawal of consent otherwise applicable but the fact that consent has been withdrawn will be noted so as to prevent an unauthorized use.

The Company, however, may collect, use or disclose personal information without an individual's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

Principle 4 – Limiting Collection

The Company will only collect information that is reasonably necessary for the purposes identified. Information will be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Personal information will only be used or disclosed for the purpose for which it was collected unless the individual has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected.

In certain exceptional circumstances, the Company may have a legal duty or right to disclose personal information without an individual’s knowledge or consent with respect to matters that concern the Company's or the public's interest.

Principle 6 – Accuracy

The Company will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. The Company will update and correct any personal information held by it if the individual concerned provides the Company, with particulars, satisfactory to it, of any required updating or correction.

Principle 7 – Safeguarding Personal Information

Personal information is safeguarded to protect against loss, theft or unauthorized access, disclosure, use or modification of information using measures appropriate to the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical organizational and electronic security measures.

Principle 8 – Openness

The Company will make information available about the policies and procedures the Company uses to manage personal information. Individuals have access to this information through our web sites, or through written correspondence with the Company’s Privacy Officer.

Principle 9 – Access

If you would like to view the personal information held in your file, please make a written request to the Company’s Privacy Officer. The Company will respond to your request as efficiently as possible and will advise of the individual cost, if any, prior to the retrieval of such records. If the Company is prohibited from providing such access, the Company’s Privacy Officer will explain the reasons, except where prohibited by law.

Principle 10 – Questions or Concerns

The Company has policies and procedures to receive, investigate and respond to individuals' complaints and questions. Individuals may contact the Company’s Privacy Officer to express any concerns or to request access to their personal information. The contact information for this individual is provided below.

2.1 The Kind Of Information We Collect

Through its website, The Company gathers and uses personal information in order to provide you with the services you have requested or to offer additional services in which you may be interested. Providing us with your personal information is your choice, however, we may not be able to provide you with certain services if you do not provide us with certain information.

The nature of our relationship with you will determine the kind of personal information we might ask for.

Information that is typically required to provide you with our services may include:

  • Name,
  • Residential and e-mail address, and
  • Phone number(s)

The Company may keep a file with your contact history to be used for inquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you.

If you visit the Company’s web site, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.

2.2 How We Use Your Information

Generally speaking, The Company uses personal information to communicate with you in order to provide you with our services or information, and we will only use personal information for the purpose that we have disclosed to you.

If we want to use your information for a different purpose, we will notify you and ask for your consent first.

2.3 When We May Disclose Your Personal Information

The Company is obliged to keep your personal information confidential except under the following circumstances:

  • When Authorized by You,
  • When Required by Law, and
  • When Permitted by Law.
i. When Authorized by You

The Company needs to obtain personal information about you in order to perform the services we have been engaged to provide. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you about.

ii. When Required by Law

The type of information we are legally required to disclose usually relates to government tax reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.

iii. When Permitted by Law

The legislation has provided certain situations where the Company is legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, or suspicion of illegal activities.

2.4 Who We May Share Your Information With
i. The Company Employees

In the course of daily operations, access to sensitive personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, the Company’s employees are required to follow all applicable laws and regulations, including this privacy policy.

Unauthorized use or disclosure of confidential information by a Company employee is prohibited and may result in disciplinary measures.

ii. The Company Affiliates.

In order to meet your needs we may share your personal information with our Affiliates and suppliers. We will only do this with your consent and you may withdraw this consent at any time. Such suppliers are only given the information that is needed to provide the specific service for which they are necessary to provide the service. We insist that our suppliers are contractually bound to protect the confidentiality of your personal information and that they are prohibited from doing anything with this information that we have not authorize them to do. They are required to treat your personal information in a manner consistent with the Company’s Privacy Policy.

The Company Affiliates are companies that: i) are owned 50% or more by Brookfield Asset Management, Inc. (“BAM”); or ii) those companies that BAM owns less than 50% and that BAM maintains significant influence over the management and operation of the company.

2.5 How We Safeguard Your Information

The Company has extensive controls in place to maintain the security of our information and information systems. Files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

When you telephone a Company employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

2.6 Web Site Security

In order to serve you better, the Company offers individuals access to certain information through our web sites. For instance, provides general information about the Company and the services we offer.

If you visit the Company’s web site, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.

2.7 Accessing and Amending Your Personal Information

You have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request to the Privacy Officer at the address listed below, under "3. Questions, Concerns and Complaints". We will respond to your request as efficiently as possible.

To make a change, please make a similar request in writing to the Privacy Officer.

2.8 Opting Out

In order to provide you with our services, the Company will, with your consent, share your personal information with other Brookfield affiliates. Should you not want to receive promotional materials from or have your personal information shared with these companies please contact the Company’s Privacy Officer at the address, phone number or email address provided in Section 3 below.

2.9 Anonymous information and "cookies"

The Company may collect anonymous information about you. This means that the information collected cannot be traced back to a specific person. For example, our Web servers may record certain information automatically when you visit the Company’s website. This information is collected using "cookies" and might include the pages you visited, your IP (Internet protocol) address and other site usage statistics. This anonymous information is used for research and analytical purposes only (like evaluating how many visitors our web site receives or which pages they visit most often). It does not reveal any Personal Information about you, the user. This aggregate data may be disclosed to third parties, but never with personally identifying information.

"Cookies" are small text files that contain a unique identification number that allows our computers to identify your Web browser (but not you) each time you visit our Web site that uses cookies. The information helps the Company improve the functionality of the site and enhance the navigation and security of your session. Most major Web sites use this technology and most browsers are set up to accept them.

You may configure your browser to notify you when you receive a cookie, and you may refuse to accept them entirely. However, if you refuse to accept cookies, you may limit the functionality that we can provide to you when you visit our site.


If you have any questions, concerns or complaints about your personal information, or about the Company’s Privacy Policy, please contact our Privacy Officer using the following contact information:

The Company’s Privacy Officer: Mr. Thomas A. Hogan

Brookfield Residential Property Services
General Counsel
465 South Street, Suite 202
Morristown, NJ 07960
Tel: (973) 889-6150
Bizcom: No. 1-888-228-0715

© 2018 Brookfield Real Estate Services Manager Limited