Privacy Policy

Effective Date: September 2, 2025

Michael Hale (“we,” “our,” or “us”) is committed to protecting the privacy and personal information of individuals who visit or interact with our website, crownsurpluslofts.ca, and who engage with the Crown Surplus Lofts investment opportunity. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information in compliance with Canadian privacy laws.

1. What Personal Information We Collect

We may collect personal information directly or indirectly, including but not limited to:

Full name

Email address

Phone number

Mailing or business address

Investment-related financial information (via secure third-party service providers)

IP address, device type, and location data

Information voluntarily submitted (e.g., forms, inquiries, emails)

2. Why We Collect Your Information

We collect and use personal information for the following purposes:

To respond to inquiries and investor interest

To assess investor eligibility and suitability (e.g. Accredited Investor status)

To manage our communications and business relationship with you

To send investor updates, offering materials, and project announcements

To schedule virtual or in-person meetings

To ensure legal and regulatory compliance (e.g. under NI 45-106)

To improve our website and investor experience

To detect fraud, abuse, or technical issues

To fulfill contractual obligations

3. How and When We Collect Information

We collect personal information when you:

Fill out an investor inquiry or registration form

Email or call us directly

Subscribe to communications or marketing updates

Engage with the website or digital advertisements

Provide information through our third-party legal or financial partners

4. Limiting Collection

We only collect personal information necessary to support the services we offer and meet regulatory obligations. Any data collected is handled with care and used solely for the intended purposes outlined here.

5. Use, Disclosure & Retention

We may share or disclose your personal information only when necessary:

With legal counsel or securities professionals assisting with the offering

With third-party service providers (e.g., CRM platforms, cloud storage, secure payment processors)

In connection with a business transfer, merger, or acquisition

To comply with legal or regulatory obligations

When explicitly authorized by you

We retain personal information for as long as necessary to meet the objectives above and to comply with applicable laws, including investor recordkeeping requirements.

6. International Data Processing

Some third-party providers may store or process personal data outside of Canada. In these cases, appropriate contractual or legal safeguards are in place to ensure your information is protected.

7. Comments and User-Submitted Content

If commenting is enabled on the site, we may collect:

The data submitted in the comment form

Your IP address and browser user agent string for spam detection

(If applicable) an anonymized hash linked to your email for profile photo display via Gravatar

8. Media Uploads

If uploading media (e.g., images) via our website becomes available, avoid including embedded location data (EXIF GPS), as it may be accessible by other users.

9. Cookies & Tracking

Our site may use cookies to enhance functionality and remember user preferences (e.g., saving form inputs). Cookies may also be used for analytics and targeted marketing.

10. Embedded Content

Content on this site may include embedded features (e.g., YouTube videos, Google Maps) that behave as if you visited the source site. These third-party sources may collect data about your interaction.

11. Data Sharing

If you request a password reset (if/when applicable), your IP address may be included in the reset communication.

12. Data Rentention

We retain:

Comments and metadata indefinitely

Registered user profile information (if applicable)
Users may access, update, or delete their data upon request, except where retention is legally required.

13. Your Rights

You have the right to:

Request access to your personal data

Request corrections or deletions (where permitted)

Withdraw consent for specific uses

Request a copy of your data in a portable format

To exercise these rights, contact us using the details below.

14. Data Protection & Spam Detection

Visitor submissions may be processed through automated spam or fraud detection systems.

15. Consent

By using our website, submitting your information, or engaging with Crown Surplus Lofts, you consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy.

16. Contact Us

For any questions or concerns regarding this Privacy Policy or your data, contact:

Michael Hale
Email: [email protected]
Phone: 780-690-7281

Last Updated September 2, 2025