Privacy Policy

This Privacy Policy governs the collection, use, disclosure, and retention of personal information by Cohen Group Marketing ("we," "us," or "our") in connection with our real estate projects, events, websites, and related services. This Policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5) and, where applicable, provincial privacy legislation including Quebec's Act respecting the protection of personal information in the private sector (Law 25), Alberta's Personal Information Protection Act (PIPA), and British Columbia's Personal Information Protection Act (PIPA B.C.).

1. Accountability

We are responsible for the personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Policy and applicable privacy laws.

2. Information We Collect

We collect personal information that is necessary, relevant, and proportionate to the identified purposes. This may include:

2.1 Information You Provide Directly:

• Full name
• Email address
• Phone number (mobile and/or home)
• Mailing or home address
• Real estate preferences (property type, budget range, timeline)
• Responses to event registration questions
• Any other information you choose to include in a form or correspondence

2.2 Information Collected Automatically:

• IP address and device type
• Browser type and version
• Pages visited and time spent on our website
• Referring URL
• Cookie and tracking data (see Section 9)

2.3 Information From Third Parties:

• Referral information from licensed real estate agents or partner organizations
• Publicly available information related to real estate transactions

3. Purposes for Collection, Use, and Disclosure

We collect and use personal information only for the following identified purposes:

• To respond to your inquiries, register you for events, and provide you with information about our real estate projects and services.
• To send you commercial electronic messages, including project updates, pricing, promotional materials, market reports, newsletters, and event information, where you have provided express consent under CASL.
• To assess your interest and preferences in order to provide you with relevant information about properties or projects that may suit your needs.
• To comply with legal obligations, including real estate regulations, anti-money laundering requirements under FINTRAC (Proceeds of Crime (Money Laundering) and Terrorist Financing Act), and applicable provincial legislation.
• To manage our business operations, improve our services, and conduct market research and analysis.
• To prevent fraud and protect the security of our systems and customers.

We will not use or disclose personal information for purposes other than those identified above without your prior consent, except as required or permitted by law.

4. Consent

We obtain consent for the collection, use, and disclosure of personal information. The form of consent may vary depending on the sensitivity of the information and the circumstances. Express consent is required for:

• Sending commercial electronic messages under CASL
• Sharing personal information with third parties outside of service provider relationships
• Using sensitive personal information

Implied consent may be relied upon in limited circumstances, such as where you have an existing business relationship with us or have made your contact information publicly available in connection with your business role. Implied consent under CASL expires after two (2) years from the most recent transaction.

You may withdraw your consent at any time, subject to legal and contractual restrictions. Withdrawal of consent will not affect the lawfulness of any processing that occurred prior to withdrawal. To withdraw consent, contact our Privacy Officer at info@homes-il.com or click the unsubscribe link in any electronic message.

5. Limiting Collection

We limit the collection of personal information to that which is necessary for the identified purposes. We do not collect information indiscriminately. We collect information by fair and lawful means.

6. Limiting Use, Disclosure, and Retention

We do not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required by law. We may disclose your personal information to:

• Licensed real estate agents and brokers engaged by or affiliated with Cohen Group Marketing in connection with projects you have expressed interest in
• Service providers and contractors engaged to perform services on our behalf (e.g., email marketing platforms, CRM providers, event management platforms), bound by confidentiality and data processing agreements
• Legal, regulatory, or government authorities as required by applicable law
• Successors or assigns of Cohen Group Marketing in connection with a merger, acquisition, or sale of assets, provided that the successor continues to be bound by this Privacy Policy

We retain personal information only as long as necessary to fulfill the identified purposes or as required by law. Consent records are retained for a minimum of three (3) years after the last commercial electronic message. Other personal information is retained in accordance with our internal Records Retention Schedule, available on request.

7. Accuracy

We make reasonable efforts to ensure that personal information is accurate, complete, and up to date for the purposes for which it is to be used. You are responsible for notifying us of any changes to your personal information. You may request correction of your information at any time by contacting our Privacy Officer.

8. Safeguards

We protect personal information using security measures appropriate to the sensitivity of the information. These measures include:

• Physical measures: secured offices, restricted physical access to records
• Technical measures: encryption in transit (TLS/SSL), access controls, password protection, and secure servers
• Organizational measures: staff privacy training, confidentiality agreements, and data handling policies

We cannot guarantee the security of information transmitted over the internet. Any transmission is at your own risk. We will notify affected individuals and the Office of the Privacy Commissioner of Canada of any privacy breach that poses a real risk of significant harm, as required under PIPEDA's Breach of Security Safeguards Regulations (SOR/2018-64).

9. Cookies and Tracking Technologies

Our website and event registration pages may use cookies, web beacons, and similar technologies to collect information about your browsing activity. These technologies help us:

• Maintain session state and remember your preferences
• Measure website traffic and performance
• Deliver relevant content and advertisements

You may disable cookies through your browser settings. Please note that disabling certain cookies may affect website functionality. We do not respond to browser "Do Not Track" signals at this time, though we are monitoring regulatory developments in this area.

Our website may use third-party analytics services (e.g., Google Analytics). These services are governed by their own privacy policies. Cohen Group Marketing enters into data processing agreements with all third-party service providers who access personal information.

10. Openness

We make our Privacy Policy and practices available upon request and on our website. This Policy is updated as necessary to reflect changes in our practices or applicable law. The date of the most recent revision is indicated at the top of this document.

11. Your Rights - Access and Correction

Under PIPEDA and applicable provincial privacy laws, you have the right to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete personal information
• Withdraw consent for the use of your personal information (subject to legal limitations)
• Request deletion of your personal information (to the extent permitted by applicable law)
• Be informed of the existence, use, and disclosure of your personal information

To exercise any of these rights, please submit a written request to our Privacy Officer. We will respond within 30 days of receiving a complete request. In some circumstances, we may require additional information to verify your identity before processing a request.

Note for Quebec Residents: Individuals whose personal information is subject to Quebec's Law 25 (Act to modernize legislative provisions as regards the protection of personal information, S.Q. 2021, c. 25) have additional rights, including the right to data portability and the right to be informed of automated decision-making. Please contact our Privacy Officer for further information.

12. Cross-Border Data Transfers

Some of our service providers may store or process personal information outside Canada, including in the United States. When personal information is transferred outside Canada, it may be subject to the laws of the receiving jurisdiction. We take contractual measures to ensure that your personal information receives a comparable level of protection as it would in Canada.

13. Challenging Compliance

You have the right to challenge our compliance with this Privacy Policy and applicable privacy laws. If you believe we have not complied with your privacy rights, please contact our Privacy Officer first so that we may investigate and respond. If you are not satisfied with our response, you may contact:

• Office of the Privacy Commissioner of Canada: www.priv.gc.ca | 1-800-282-1376
• Commission d'accès à l'information du Québec (Quebec residents): www.cai.gouv.qc.ca
• Office of the Information and Privacy Commissioner of Alberta: www.oipc.ab.ca
• Office of the Information and Privacy Commissioner for British Columbia: www.oipc.bc.ca

14. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this Policy and, where required by law, notify affected individuals. Your continued use of our services after any changes constitutes your acceptance of the revised Policy.

15. Contact Us

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

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This Privacy Policy was last updated on March 16, 2026. By continuing to use our services after this date, you acknowledge that you have read and understood this Policy.

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