Effective Date: February 12, 2026

Last Updated: February 12, 2026

275 Carling Ave. LP, operating as The Clemow, a subsidiary of KTS Properties Ontario (Business Identification Number: 1000812723) (“we,” “us,” “our,” or “The Clemow”), is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at theclemow.com, interact with our services, or communicate with us.

This Privacy Policy is drafted in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and Ontario’s applicable privacy legislation. By accessing our website or providing your personal information to us, you consent to the practices described in this Privacy Policy.

1. Information We Collect

We may collect and process the following categories of personal information:

a) Information You Provide Directly

• Contact Information: Name, email address, phone number, and mailing address when you submit an inquiry, book a visit, or complete a contact form.
• Rental Application Information: Date of birth, employment information, income verification, credit history, references, and identification documents submitted in connection with a rental application.
• Communications: Records of correspondence when you contact us via email, phone, or through the website.

b) Information Collected Automatically

• Device and Usage Data: IP address, browser type and version, operating system, referring URL, pages visited, time and date of visits, and time spent on pages.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to enhance your browsing experience. For more details, see Section 6 (Cookies) below.

c) Information from Third Parties

• Credit Reporting Agencies: Credit reports and credit scores obtained with your consent in connection with a rental application.
• References: Information provided by personal or professional references you have authorized us to contact.
• Analytics Providers: Aggregated and anonymized data from analytics services such as Google Analytics.

2. How We Use Your Information

We use your personal information for the following purposes:

• Processing Rental Applications: To evaluate your eligibility, conduct credit checks, verify references, and process your application for tenancy at The Clemow.
• Managing Tenancies: To administer and manage existing residential tenancy agreements, including rent collection, maintenance requests, and communications related to your tenancy.
• Responding to Inquiries: To respond to your questions, requests, and communications submitted through our website or other channels.
• Scheduling Visits: To facilitate and confirm on-site or virtual visits to The Clemow.
• Website Improvement: To analyze website usage, improve the functionality and content of our website, and enhance user experience.
• Marketing Communications: To send you promotional materials, newsletters, or updates about The Clemow, where you have provided your consent. You may opt out at any time.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes, and to establish, exercise, or defend legal claims.

3. Legal Basis for Processing

Under PIPEDA, we process your personal information on the following legal bases:

• Consent: Where you have given us express or implied consent to collect and use your personal information for a specific purpose.
• Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party, such as a Residential Tenancy Agreement.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided such interests are not overridden by your rights and freedoms.
• Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject.

4. Disclosure of Your Information

We may share your personal information with the following categories of recipients:

• KTS Properties Ontario: As our parent company, for administrative and operational purposes.
• Service Providers: Third-party service providers who perform services on our behalf, including property management systems, payment processors, credit reporting agencies, IT support providers, and marketing platforms. These providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• Legal and Regulatory Authorities: Where required by law, regulation, legal process, or enforceable governmental request, including the Landlord and Tenant Board of Ontario.
• Professional Advisors: Lawyers, accountants, auditors, and insurers, where necessary in the course of the professional services they render to us.
• Business Transfers: In connection with any merger, acquisition, financing, sale of assets, or transition of service to another provider, your personal information may be transferred as part of such transaction, subject to standard confidentiality requirements.

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

5. Data Retention

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. Rental application records are retained for a period of two (2) years following the date of the application decision. Tenancy records are retained for a period of six (6) years following the termination of the tenancy, in accordance with applicable limitation periods. Website usage data collected through cookies is retained in accordance with our cookie settings as described in Section 6 below.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to collect and store certain information about your browsing activity. Cookies are small text files placed on your device by your web browser. We use the following types of cookies:

• Essential Cookies: Necessary for the website to function properly. These cookies cannot be disabled.
• Analytics Cookies: Used to collect information about how visitors use our website, including pages visited and traffic sources. We use Google Analytics for this purpose. Google Analytics data is processed in accordance with Google’s Privacy Policy.
• Functional Cookies: Used to remember your preferences and provide enhanced functionality.
• Marketing Cookies: Used to deliver relevant advertisements and track ad campaign performance.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

7. Your Rights

Under PIPEDA and applicable Ontario privacy legislation, you have the following rights with respect to your personal information:

• Right of Access: You may request access to the personal information we hold about you.
• Right of Correction: You may request that we correct any inaccurate or incomplete personal information.
• Right to Withdraw Consent: You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions. Withdrawal of consent may affect our ability to provide certain services to you.
• Right to Complain: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

To exercise any of these rights, please contact us using the contact information provided in Section 11 below. We will respond to your request within thirty (30) days, as required by PIPEDA.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit, secure server infrastructure, access controls, and regular security assessments. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

9. International Data Transfers

Your personal information may be stored and processed in Canada and, in some cases, may be transferred to and processed in other jurisdictions where our service providers operate. Where personal information is transferred outside of Canada, we ensure that appropriate safeguards are in place to protect your information in accordance with PIPEDA and applicable laws.

10. Children’s Privacy

Our website and services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information promptly.

11. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

275 Carling Ave. LP (operating as The Clemow)
101 – 265 Carling Ave
Ottawa, ON K1S 2E1
Canada

Email: info@ktsproperties.ca
Phone: +1 (613) 704-6991
Website: ktsproperties.ca

12. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with an updated “Last Updated” date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information. Your continued use of the website following the posting of changes constitutes your acceptance of such changes.

13. Office of the Privacy Commissioner of Canada

If you are not satisfied with our response to your privacy concern, you may contact the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca