Privacy Policy

EMPIRE HOMES PRIVACY STATEMENT

Effective Date: November 14, 2025

The following Privacy Statement pertains to privacy matters related to Empire Homes’ development, construction and for-sale business (performed as Empire Homes) and to our rental business (performed as Empire Rental Living).

This Privacy Statement applies to Willowdale Asset Management Inc., and any subsidiary, affiliate, or other related company, including Empire Homes (referred to collectively as “Empire,” “we,” “our,” or “us”). We may provide you with additional privacy policies or procedures that address particular circumstances in which your Personal Information is handled for certain Empire businesses or offerings.

As part of our ongoing effort to keep you informed about our privacy practices, we have prepared this policy to inform you about our collection, use, and disclosure of information, including via this website and any website or mobile application that links to this policy (collectively, the “Site”).

It should be noted that certain services can only be offered if a person provides Personal Information to Empire. Consequently, if an individual chooses not to provide us with any required Personal Information, we may not be able to offer the services requested.

1. WHAT IS PERSONAL INFORMATION?

“Personal Information” means information about an identifiable individual and may include any information that is linked or reasonably linkable to an individual acting in their personal capacity.

2. TYPES OF PERSONAL INFORMATION WE COLLECT

The Personal Information we collect, use and disclose will depend upon the nature of our relationship and business with you. This information may include:

    • Your name and other contact and background information, such as your email, phone number, age, and gender;
    • Your log-in information;
    • Financial information, such as your income, employment, credit information, banking information, and net worth;
    • For job applicants, your employment history, education, work eligibility, resume information, information from background checks, references, recommendation letters, and other information obtained during the recruitment process;
    • Your payment information and other information we need to meet real estate transaction requirements;
    • Records of products or services purchased, obtained, or considered;
    • Video or audio recordings of you (see sections 5. Use of video surveillance and recordings, and 6. Use of audio surveillance and recordings, for more information);
    • Information about your real estate agent or other legal agent(s);
    • For tenants and tenant applicants, tenancy information, including information about occupants, information from background and credit checks, guarantors, emergency contacts, proof of insurance, and vehicles, as well as any other information provided in a tenant application;
    • Information about your requests, interests, or needs that you provide to us; and
    • Any other information you choose to provide. 


In most cases, the type of Personal Information we collect depends upon whether you are a purchaser, a tenant, or a job applicant. For customers, it also depends upon the products or services you are interested in, and the amount of information we need to communicate with you, assess eligibility, meet our obligations and run our businesses. Knowing you better helps us understand your needs and ultimately to provide the right products and services for you.

In Canada, if a credit check is required in connection with a purchase, we may request that you provide us with your Social Insurance Number (SIN), which we use to ensure we obtain the correct credit report about you. However, providing your SIN is entirely optional.

We (and other entities) automatically collect information relating to your interactions with us and our Site, including browser type, IP address, pages visited and other activities on the Site, device type, and time and date of visit, and other information we collect through the use of cookies and similar technology.  See the “Digital Advertising & Analytics” section of this privacy policy to learn more about the use of this information and the choices available to you.

3. HOW WE COLLECT PERSONAL INFORMATION

Personal Information is collected from you directly online, over the telephone, in written form or in face-to-face meetings and visits. Empire collects Personal Information using various documents including registration forms, applications, questionnaires and surveys, purchase and lease agreements and other related documents.

We may also collect information from other individuals about you—for example, information from your real estate agent or family member.

If you give us Personal Information about another person, we assume that you have the right to give us their Personal Information, and that you have their consent for us to collect, use, and share their Personal Information as described in this Privacy Statement.

In certain cases, information collected using video or audio recording equipment can constitute Personal Information as well.

As noted, we automatically collect some information about you online via cookies and similar technologies.

Empire may also collect Personal Information from third parties and combine it with information we collect ourselves, such as when we contact references for employment or tenant applications or perform credit, government registry, social media and similar background checks on such applicants. In some cases, the third party may require you to provide separate consent to those checks. For tenants, we may collect Personal Information about you from other third parties including service providers, co-residents, occupants, guarantors, and third-party payors of rent.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

4. WHY EMPIRE COLLECTS AND USES PERSONAL INFORMATION

Empire collects and uses Personal Information of customers, tenants, job applicants, website visitors, consultants, strategic partners, agents, distributors, suppliers, contractors and other entities (including their employees) in the ordinary course of its businesses. This information allows Empire to:

  • Market and sell Empire homes and services to customers and to otherwise fulfill orders;
  • Rent homes, condominiums and other Empire properties to tenants;
  • Engage in various kinds of real estate transactions;
  • Respond to your inquiries, including questions about transactions;
  • Communicate with applicants regarding job applications;
  • Operate and improve our products and services;
  • Operate, personalize, and improve the Site, including for analytics purposes;
  • Provide you with homeowner updates, including on the status of your new home construction;
  • Communicate with, and provide information, updates, promotions, advertisements and marketing materials to, customers, tenants, and others about products, services and offers that may be of interest to them, including in some cases products and services of third parties;
  • Develop and maintain relationships with, among others, Empire customers, consultants, strategic partners, agents, distributors, suppliers, contractors and other entities;
  • Determine customer/tenant eligibility and suitability for financing or renting homes and accessing other services, including conducting initial and periodic credit checks;
  • Administer and manage lease agreements and tenancies, including to process rent payments, manage utility payments and accounts, assess and arrange for maintenance or repairs, and to enforce the terms of lease agreements;
  • Collect amounts outstanding from customers and tenants and those providing guarantees or other forms of security for them;
  • Protect the rights, interests and property of Empire, our personnel, our customers, our tenants, and others;
  • Adhere to applicable legal and regulatory requirements and maintain the security of our Site;
  • Document and investigate incidents and complaints;
  • Inspect, repair, and maintain the safety and good condition of rental properties and units (including by taking photographs and video recordings);
  • Various other purposes necessary to operate or carry out our business that are generally consistent with these purposes; and
  • Fulfill purposes with your consent or as otherwise disclosed at the time information is collected.


Empire may also de-identify or aggregate personal information for any of the purposes above.

5. USE OF VIDEO SURVEILLANCE AND RECORDINGS

Video equipment may be installed and operating in our for-sale communities during the marketing period or in common areas of our rental properties. The video equipment may have capabilities such as zoom, audio recording or night-vision features. The video equipment may be operating at all times. Surveillance of the video recordings may occur at any time.

The purpose of this equipment is to ensure your safety, security and reasonable enjoyment (as well as that of other persons who are our customers/tenants), to ensure you have access to the premises, equipment and services that Empire provides, to preserve our property and to deter crime.

Where required by law, signs will be posted informing you that video equipment is operating and recording your Personal Information.

Please note that in our rental properties, photographs and video recordings of units may be taken as part of inspection, maintenance, and repairs procedures, for the purposes of documenting the state of the unit. Such photographs and video recordings are not intended to capture Personal Information.

6. USE OF AUDIO EQUIPMENT AND RECORDINGS

There are circumstances under which Empire may make audio recordings of communications with contractors, customers, tenants or others. There are several purposes for making the recordings including situations where there are performance issues in respect of Empire’s role as contractor, landlord or product or service provider, to ensure the safety of our properties and employees, to monitor customer service and to prevent harassment.

Audio recordings may be made during meetings, interviews or telephone calls involving Empire and other parties. Audio equipment may be operating at other times.

7. WHEN EMPIRE MAY SHARE YOUR PERSONAL INFORMATION

We may share the information we collect with other parties, including the following:

  • With third parties that assist with eligibility decisions—for example, sharing information with credit agencies to evaluate your creditworthiness as a prospective customer or tenant, or disclosing information to check references provided by job applicants;
  • With third parties and business partners to help us and them provide you with advertising and other personalized services;
  • With third parties who perform services for us or on our behalf, such as payment processors, property managers, contractors that service our rental properties, service providers that assist us in the recruitment process (including background check providers), and our legal or business advisors;
  • With any of our affiliates or related companies, or any joint venture partners that we may have in the future;
  • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
  • If the disclosure is required by law (including compliance with subpoenas, court orders and rules) or lawfully requested by a government agency;
  • To protect our rights or the rights of third parties, including for the purposes of debt collection or investigating breach of contract, or to protect the safety or security of any person or entity and where necessary in an emergency situation; and
  • With your consent or as otherwise disclosed at the time of data collection or sharing.


We may share information that has been de-identified or aggregated for the purposes described above.

Where Empire discloses Personal Information to service providers, we will require them to use such information solely for the purposes of providing services to the person concerned or Empire and to have appropriate safeguards for the protection of that Personal Information.

8. DIGITAL ADVERTISING & ANALYTICS

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

You may visit the Digital Advertising Alliance (DAA)’s WebChoices tool at www.aboutads.info/choices (US) or www.youradchoices.ca/ (Canada) to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA’s AppChoices tool at https://youradchoices.com/appchoices (US) or https://youradchoices.ca/en/appchoices (Canada).

If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA tools.  Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. 

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes. Empire uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

9. THIRD-PARTY LINKS AND TOOLS

The Site may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this privacy policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Site also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share Personal Information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. 

Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

10. U.S. STATE PRIVACY RIGHTS

Some U.S. states—California, Colorado, Tennessee, and Texas (collectively, “Certain States”)—grant individuals certain rights under state privacy laws with respect to Personal Information we collect. If you are subject to the privacy laws of these states, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you.

Personal Information We Collect and Disclose. In the preceding 12 months, Empire collected and disclosed the following categories of Personal Information:

  • Personal and online identifiers (such as first and last name, email address, government identification documentation, device information, or unique online identifiers);
  • Recordkeeping information (such as physical characteristics or description; bank account number, credit card number, debit card number, or any other financial information);
  • Characteristics of legally protected classifications (such as race/ethnicity or gender);
  • Commercial or transactions information (such as records of products or services purchased, obtained, or considered);
  • Internet or other electronic network activity information (such as browsing history, search history, or interactions with a website, email, application, or advertisement);
  • Sensory information (such as call recordings or other audio, electronic, visual, thermal, olfactory, or other similar technology);
  • Inferences drawn from the above information about your predicted characteristics and preferences; and
  • Other information about you that is linked to the Personal Information above.


We share personal information for targeted advertising purposes but do not otherwise engage in “sales” of personal information as defined by state laws.

Additionally, we do not knowingly sell or share Personal Information of individuals under 16.

Specifically, in the past 12 months, we have disclosed the following categories of Personal Information to third-party business partners—such as advertising networks—for advertising and marketing purposes, including targeted advertising:

  • Identifiers;
  • Internet or other similar network activity; and
  • Inferences drawn from other Personal Information (excluding any information that may be considered sensitive under applicable state laws).


Categories of Sources. We collect Personal Information from the following categories of sources:

  • You;
  • Our affiliates and joint venture partners;
  • Our business partners;
  • Our service providers; and
  • Advertising companies and networks.


Our Purposes for Processing Personal Information. We use and disclose the Personal Information we collect for our commercial and business purposes, as further described above in the “Why Empire Collects and Uses Personal Information” section of this Privacy Policy.

We may use and share de-identified information to the extent permitted by applicable law. When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our deidentification processes satisfy the requirements of applicable law.

Recipients of Personal Information.  We disclose the categories of Personal Information designated above to the categories of third parties listed above in the “When Empire May Share Your Personal Information” section of this Privacy Policy for commercial and business purposes.

11. EXERCISING PRIVACY RIGHTS

Residents of various jurisdictions, including Canada and Certain States, have rights with respect to the Personal Information collected by Empire. Depending on your jurisdiction, you may be able exercise the following rights regarding Personal Information, subject to certain exceptions and limitations:

  • The right to confirm whether we are processing Personal Information about you;
  • The right to know the categories and specific pieces of Personal Information we collect, use, disclose, and sell about you; the categories of sources from which we collected Personal Information about you; our purposes for collecting or selling Personal Information about you; the categories of Personal Information about you that we have sold or disclosed for a business purpose; and the categories of third parties with which we have shared Personal Information;
  • The right to receive a portable and readily usable copy of the Personal Information we have collected about you, to the extent feasible;
  • The right to correct inaccuracies in the Personal Information we have collected about you;
  • The right to request that we delete the Personal Information we have collected about you;
  • The right to opt out of (i) the sharing or processing of Personal Information for targeted advertising, (ii) the sale of Personal Information, and (iii) the processing of Personal Information for profiling with legal or similarly significant effects. Please note that if you opt out of certain practices, we may be unable to provide you with some services; and
  • The right not to receive discriminatory treatment for the exercise of the above privacy rights.


To exercise any of the above rights, please contact us by emailing us at privacy@willowdaleasset.com. You can submit any of the above requests by contacting us as described in “Comments and Questions”.

Additionally, for individuals subject to state laws in Colorado, Tennessee, and Texas, if you have submitted a request that we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to privacy@empirehomes.com.

Verification Process and Required Information:  Note that we may need to request additional information from you to verify your identity or understand the scope of your request (other than certain opt-out requests).  You will not be required to create an account with us to submit a request or have it fulfilled.  We will require you to provide, at a minimum, basic contact information like your name and phone number.

Authorized Agent:  Depending on your state or province, you may also designate an authorized agent to make requests on your behalf by designating such an agent in writing or through a power of attorney. For requests other than certain opt-outs, we will require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

12. RETENTION AND INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

Your Personal Information is retained in identifiable form only as long as we need it to effectively provide products and services to you, fulfill the purposes for which the Personal Information was provided to us, or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or to satisfy any similar essential purposes. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. After the retention period expires and if not otherwise required to retain information by law, Personal Information will be destroyed, deleted or de-identified.

Your Personal Information may be retained or transferred outside your current jurisdiction to another jurisdiction in which we, or a party to whom we provide the Personal Information, operates. When your Personal Information is in another jurisdiction, it may be subject to the laws of that jurisdiction. This includes legal requirements to disclose Personal Information in response to legal demands or requests from governments, regulators, courts, and law enforcement.

13. YOUR EMAIL MARKETING CHOICES

To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as important updates and notifications related to your services.

For choices with respect to third-party interest-based advertising activities, please see the “Digital Advertising & Analytics” section above.

14. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

When you have an account with us, you may review, change, or update your contact information by logging into your account.  If you do not have an account with us, see “11. Exercising Privacy Rights” above for information on how you may be able to access or update your information.

15. CHANGES TO OUR PRIVACY POLICY

Empire reserves the right to change this Privacy Statement from time to time and in our sole discretion. If we change our information practices, this Privacy Statement will be updated accordingly. We recommend that you periodically review this Privacy Statement, which is available on our website (www.empirehomes.com/privacy-policy/) so that you are aware of the changes.

16. COMMENTS AND QUESTIONS

If you have a question, issue or complaint related to this Privacy Statement or any of our procedures, please contact our Privacy Officer at the email address or mailing address listed below:

Empire Privacy Officer
125 Villarboit Crescent
Vaughan, Ontario L4K 4K2
privacy@willowdaleasset.com

PHOTO GALLERY

1233 upper mar drive

$ 300,000

Phase 3 - Lot #40

Mls
w4630073

Beds

4

Baths

2.5

Garages

2

sq.ft

1,936

Phases

PHOTO GALLERY

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