1. Introduction

Three Sisters Mountain Village (“TSMV,” “we,” “our,” or “us”) is committed to protecting your privacy and ensuring transparency regarding the personal information we collect, use, and share. This Privacy Policy outlines how we handle your personal information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and Alberta’s Personal Information Protection Act (PIPA). Where these statutes overlap or conflict, we apply the standard most protective of your privacy.

This policy applies to personal information collected through our website and through all other TSMV channels including sales/leasing registrations, event attendance, purchaser files, leasing files, and other relationships.

TSMV has designated a Privacy Officer who is accountable for our compliance with this policy and applicable privacy legislation. Contact information for the Privacy Officer is set out in Section 9.

2. Information We Collect

We may collect the following types of personal information:

• Contact Information: Name, email address, phone number, and postal code (zip code if applicable).
• Demographic Information: Age, interests, or location preferences related to inquiries.
• Technical Information: IP address, browser type, device type, operating system, website interactions through cookies, and analytics data.
• Transaction Information: Information related to property inquiries, registrations for events, newsletters, and customer service interactions.
• Financial Information: Income range, pre-qualification status, or mortgage details provided voluntarily in connection with a property purchase inquiry or priority registration.
• Identity Verification: Government-issued identification provided in connection with a purchase transaction or event registration.
• Communication Records: Emails, correspondence, or call notes generated through interactions with our sales and marketing team, agents or consultants, or customer service.
• Broker-Submitted Information: Personal information provided to us by real estate brokers or agents acting on your behalf.

3. How We Use Your Information

Your personal information is collected to:

• Respond to inquiries about real estate (or related) opportunities.
• Provide updates and newsletters.
• Improve user experience on our website.
• Conduct marketing and advertising activities relevant to TSMV, including targeted digital advertising and retargeting on third-party platforms. Where your information is shared with advertising platforms for this purpose, those platforms are identified in Section 5.
• Maintain and analyze website performance and security.
• Fulfill obligations under applicable regulations and, where applicable, federal anti-money laundering and financial reporting requirements.
• Comply with applicable legal obligations.

4. Consent

By providing personal information through our website or through any other TSMV channel, you consent to our collection, use, and disclosure of your information in accordance with this policy.

For marketing communications, we rely on your express consent, which you may provide at the point of registration or inquiry. For other purposes described in Section 3, we may rely on implied consent where the purpose is obvious, and the information is not sensitive.

You can withdraw your consent at any time by contacting our Privacy Officer (see Section 9). We will act on your withdrawal request within 10 business days. Withdrawal of consent for marketing communications will not affect our ability to contact you regarding an active transaction or legal obligation.

5. Disclosure and Sharing of Information

We do not sell your personal information. We may share your information:

• With trusted third-party service providers assisting in website hosting, analytics, marketing, or customer service, including CRM platform providers, email marketing services, and digital advertising platforms. Where information is shared with digital advertising platforms, it is used solely for the purpose of delivering relevant TSMV communications and is not used by those platforms for their own purposes beyond what you have separately agreed to with them.
• With real estate brokers or agents who have submitted a registration on your behalf, for the purpose of facilitating your inquiry.
• With legal counsel, financial institutions, or other professionals engaged in connection with a property transaction.
• When required by law or to comply with legal processes, including requests from regulatory authorities such as the Real Estate Council of Alberta.
• To protect and defend our rights and property or to ensure personal safety.

We require all third parties receiving personal information to maintain appropriate safeguards consistent with this policy and applicable law. We do not authorize third parties to use your personal information for their own marketing purposes.

6. Security of Your Information

We implement reasonable physical, technical, and administrative safeguards to protect your personal information against unauthorized access, use, disclosure, and alteration. However, no internet transmission is entirely secure, and we cannot guarantee absolute security.

In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm, we will notify you and report to the applicable privacy regulator as required under PIPEDA and Alberta PIPA. Notification will be provided as promptly as possible and will include a description of the breach, the information involved, and the steps we have taken or propose to take to address it.

7. Access and Correction

You have the right to access and request correction or updating of your personal information in our custody by contacting our Privacy Officer directly (see Section 9). We will respond to access requests within 30 days. In circumstances where additional time is required, we will notify you of the extension and the reason for it.

There is no fee for an access request unless the volume or complexity of the request reasonably warrants one, in which case we will advise you of the anticipated cost before proceeding.

8. Cookies and Analytics

Our website uses cookies and similar technologies to enhance your browsing experience and collect data on website usage. We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the website to function. These cannot be disabled.
• Performance and Analytics Cookies: Used to understand how visitors interact with our website, including through third-party analytics platforms. The data collected is aggregated and used to improve website performance.
• Marketing and Targeting Cookies: Used to deliver relevant advertising and to track the effectiveness of our marketing campaigns. These cookies may be set by third-party advertising platforms.

You may manage your cookie preferences through our cookie preference tool on this website or disable cookies through your browser settings. Disabling certain cookies may impact your experience on our website.

9. Privacy Officer and Contact Information

TSMV has designated a Privacy Officer who is responsible for the organization’s compliance with this policy and applicable privacy legislation, consistent with the accountability requirements of PIPEDA and Alberta PIPA.

If you have questions, concerns, or wish to exercise your privacy rights, including making an access or correction request, withdrawing consent, or reporting a privacy concern, please contact our Privacy Officer:

Privacy Officer

Three Sisters Mountain Village Properties Ltd.

1444 Hastings Crescent SE

Calgary, AB, T2G 4C8

brian.talbot@tsmv.ca

403-815-8505

If you are not satisfied with our response to a privacy concern, you may file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or with the Office of the Information and Privacy Commissioner of Alberta at www.oipc.ab.ca.

10. Changes to This Policy

We reserve the right to update this Privacy Policy periodically. For material changes to how we collect, use, or share your personal information, we will provide direct notice to individuals whose information is affected, where we have their contact information, and we will seek renewed consent where required by applicable law.

All changes will be posted on our website with an updated “Last Updated” date. We encourage you to review this policy regularly.

Continued use of our website following notice of a non-material change constitutes acceptance of that change. For material changes, we will seek your express consent where required.