Privacy
Policy

01About this policy

429 Walmer is a purpose-built rental residence under development at 429 Walmer Road, Toronto, by Stafford Homes Ltd. (“Stafford”) and DBS Developments (“DBS”). In this policy, “429 Walmer”, “we”, “us” and “our” mean Stafford and DBS acting jointly in connection with the project.

The project is being carried on through a partnership that is in the course of being formed. When that entity is registered, this policy will be updated to name it, and it will assume the responsibilities set out here in place of, or together with, Stafford and DBS. Until that time, Stafford and DBS are jointly accountable for the personal information described below.

This policy applies to 429walmer.ca (the “Site”) and to personal information we collect in connection with the 429 Walmer project by any means, online or offline. That includes information collected by email, by telephone, at a leasing or presentation office, and by leasing agents, brokers or property managers acting on our behalf.

This policy does not apply to other Stafford or DBS projects, which are governed by their own policies:

• Stafford — https://stafford.ca/privacy-policy/
• DBS Developments — https://dbsdevelopments.ca/privacy-policy/

“Personal information” means information about an identifiable individual, as that term is defined under the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws. “Including” and its derivatives mean “including without limitation”.

02What the Site collects right now

The Site is currently a single informational page. It does not host registration forms, enquiry forms, leasing applications or advertising, and we are not building a mailing list from it.

We do collect limited technical information automatically whenever a page is loaded. Section 4 describes what that is.

03Information you give us

If you contact us, or if the Site later offers a registration, enquiry or leasing form, we collect the information you choose to provide. Depending on what you are asking for, this may include:

• Contact information — name, email address, telephone number, mailing address
• Housing preferences — suite type and size, desired move-in date, budget range, parking, storage, pet and accessibility requirements
• How you heard about us, and whether you are working with a real estate agent or brokerage
• Anything else you choose to include in a message, enquiry or comment to us

We ask for the minimum we need to respond to you. You are never obliged to give us personal information. If you choose not to, we may be unable to answer your enquiry, add you to a leasing interest list, or process a future application.

Leasing applications

We are not accepting leasing applications at this time.

When leasing opens, applicants will be asked for further information, which may include employment and income information, rental history, credit references and credit checks, and guarantor details. That collection will be described in the application form itself, will require your express consent, and will be handled in accordance with the Ontario Human Rights Code and Ontario Regulation 290/98, which limit how such information may be requested and used in selecting tenants.

04Information collected automatically

Server logs. Our web host records standard technical data each time the Site is visited: IP address, browser type and version, operating system, the page that referred you, the pages requested, and the date and time of the request. This happens on every website and we cannot switch it off. We use it to keep the Site available and secure, to diagnose faults, and to understand overall traffic volumes. We do not attempt to identify individual visitors from it.

Cookies and similar technologies. A cookie is a small text file placed on your device by a website. Web beacons and tracking tags perform a similar function.

The Site uses Google Analytics to understand how visitors use it, including which pages are viewed, how long visits last, and roughly where visitors come from. Google Analytics sets cookies and receives your IP address. Google's practices are described at https://policies.google.com/privacy. You can prevent Google Analytics from collecting your activity by installing Google's opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

Most browsers let you refuse or delete cookies. If you do, parts of the Site may not work as intended.

Browser privacy signals. The Site does not currently respond to “Do Not Track” or Global Privacy Control signals.

05How we use personal information

We use personal information to:

• respond to your enquiries and requests
• keep you informed about 429 Walmer, including leasing timing, availability, pricing and events, where you have consented to receive those communications
• understand what prospective residents are looking for, so we can plan and improve the building, its suites and its services
• administer leasing enquiries and, in future, leasing applications and tenancies
• operate, secure and improve the Site
• meet our legal, regulatory, insurance and accounting obligations

We use personal information only for the purposes described here, for purposes you later consent to, or as permitted or required by law.

06Consent

We collect, use and disclose personal information with your consent, unless the law permits or requires otherwise.

Your consent may be express, for example by ticking a consent box on a form, or implied by your conduct, such as sending us an enquiry so that we can reply to it. Where the information is sensitive, we seek express consent.

Commercial electronic messages. We send marketing emails and text messages only where you have given express consent under Canada's Anti-Spam Legislation (CASL). Every such message identifies us and includes a working unsubscribe link. You may withdraw consent at any time using that link or by writing to the address in section 15. We will act on a withdrawal within 10 business days. Withdrawing marketing consent does not stop us from replying to an enquiry you have made, or from sending you messages required in connection with an existing tenancy.

Withdrawing consent generally. You may withdraw consent to our use of your personal information at any time, subject to legal and contractual restrictions and reasonable notice. If you do, we may no longer be able to provide you with information about the project or process an application.

07Who we share personal information with

We share personal information only as described below.

Between Stafford and DBS. Personal information collected in connection with 429 Walmer is shared between Stafford and DBS, and with the project entity once formed, for the purposes set out in section 5. Neither company uses information collected for 429 Walmer to market its own unrelated projects unless you have separately consented to that.

Service providers. We use third parties to operate the Site and the project. They receive only the information they need to perform their function, are contractually required to protect it, and are not permitted to use it for their own purposes. Categories include:

• website hosting and maintenance
• email delivery and marketing platforms
• customer relationship management and leasing systems
• analytics and advertising platforms
• printing, mail and courier services
• property management, leasing agents and brokerages
• credit reporting agencies and tenant screening providers, at the application stage only

Professional advisers. Lawyers, accountants, insurers and consultants, where necessary.

Legal and safety. Where permitted or required by law, including in response to a search warrant, subpoena, court order or other lawful demand; to investigate a suspected breach of an agreement or of the law; to detect, prevent or suppress fraud; or to establish, exercise or defend legal claims.

Business transactions. In connection with a proposed or completed sale, financing, merger, reorganisation or transfer of all or part of the project or of either company, personal information may be disclosed to or transferred with the business, subject to appropriate confidentiality protections.

08Where personal information is stored

Personal information may be stored and processed in Canada and in the United States, and by service providers located in other jurisdictions. Our website hosting is provided by a service provider whose servers are located in the United States.

Where personal information is held outside Canada, it is subject to the laws of that jurisdiction and may be accessible to that jurisdiction's courts, law enforcement and government authorities under those laws. We require our service providers to protect personal information to a standard comparable to our own.

09How long we keep it

We keep personal information only as long as we need it for the purposes described in this policy, or as long as the law requires us to keep it. How long that is depends on what the information is and why we hold it.

• Enquiries and registrations that do not lead to a tenancy are kept while the project is being marketed and leased, and for a reasonable period afterwards, and are then deleted or made anonymous.
• Leasing applications that are not accepted are kept long enough for you to ask us about the decision and for us to respond to any question or claim about how your application was handled, and are then deleted.
• Tenancy records are kept for the term of the tenancy and afterwards for the periods required by the Residential Tenancies Act, tax law and our insurers.
• Website server logs are kept for a short period for security and troubleshooting, and are then overwritten or deleted.

You may ask us to delete personal information we hold about you at any time, and we will do so unless we are required to keep it. Section 11 explains how.

10How we protect it

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, including restricting access to staff and service providers who need it to do their jobs, and requiring them to keep it confidential.

No security measure is absolute. The internet is not a secure means of communication, and we cannot guarantee the security of information you send us over it. Please do not send sensitive information, such as identification documents or financial details, by ordinary email.

If a breach of our safeguards creates a real risk of significant harm to you, we will notify you and the appropriate regulator as required by law.

11Your rights

You may:

• Access the personal information we hold about you
• Correct it if it is inaccurate or incomplete
• Withdraw consent, subject to section 6
• Ask us to delete it, where we are not required to keep it

Write to the contact in section 15. We will respond within 30 days. We may need to verify your identity first. In limited cases we may be unable to provide access, for example where doing so would reveal another person's personal information, or where the information is subject to legal privilege. If we refuse, we will tell you why.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca or 1-800-282-1376.

12Links to other websites

The Site may link to websites we do not operate, including social media platforms and, in future, leasing and availability tools. Those sites have their own privacy policies and we are not responsible for their practices. A link is not an endorsement. Please read their policies before providing personal information to them.

13Children

The Site is intended for adults. We do not knowingly collect personal information from anyone under 18. If you believe we have, contact us and we will delete it.

14Changes to this policy

We may update this policy from time to time. The current version is always posted here with its effective date. Your personal information is handled according to the policy in effect when it was collected, unless you consent otherwise. Material changes will be brought to your attention before they take effect.

15Contact us

Questions, access requests, corrections, complaints and opt-out requests should go to:

Email: info@429walmer.ca

16Conflict with a lease or agreement

If you enter into a lease or other agreement with us, and that agreement deals with personal information differently from this policy, the agreement governs for the matters it covers.

17Governing law

This policy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable in Ontario.

Last Updated: September 2026