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Privacy Policy

Last Updated: April 16, 2024

Skyline Private Investment Capital Inc. and Skyline Enterprises Management Inc. (o/a Skyline Group of Companies), and all of their respective subsidiaries (“we”, “us”, “Shared Services”) are committed to safeguarding the Personal Information you entrust to us. This privacy policy will inform you about the Personal Information we process and how we process it.

We process your Personal Information in accordance with applicable privacy legislation, which includes the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and provincial legislation deemed substantially similar to PIPEDA (privacy legislation applicable to the private sector in British Columbia, Alberta, and Quebec).

1. Scope

Skyline’s Shared Services include corporate finance, legal, human resources, operations, information technology, corporate marketing, sustainability, and our executive team. This privacy policy applies to Personal Information processed by our Shared Services including Personal Information obtained directly and Personal Information shared by other Skyline Entities as needed to provide them with the services they require. This privacy policy does not apply to entities within the Skyline Group of Companies whose specific privacy policies are available through their own websites (each a “Skyline Entity” and collectively “Skyline Entities”).

“Processing” Personal Information means collecting, using, and/or disclosing it. Personal Information encompasses information about identifiable individuals. Beyond standard elements considered Personal Information (like your name, email, address, phone number, etc.), what makes you identifiable is sharing different pieces of data that, alone or in conjunction with other data, allow us to unequivocally identify you. By way of illustration, your name without further data elements like an address or postal code is unlikely to be categorized as Personal Information because other people may have the same name, as such we may not be able to identify you with certainty.

2. Processing of Personal Information

2.1 Legal Bases

We process your Personal Information based on:

  • Your provision of consent to a Skyline Entity or to us (where applicable),
  • exceptions to the consent requirement as outlined in the law;
  • your contract with another Skyline Entity or with us;
  • your business relationship with another Skyline Entity or with us; and
  • in line with legal or regulatory requirements or guidance.

2.2. Collection of Personal Information

We collect Personal Information necessary to operate our business and to provide the information and services of your choice. With limited exceptions, we collect your Personal Information directly from you through different forms and contracts. When operating as Shared Services, we generally receive your information from other Skyline Entities, which allows us to provide them with the services they need to deliver the services you requested.

Collection of Personal Information is conducted via email, websites, phone, fax, in person, or through marketing campaigns. From time to time, we utilize publicly accessible information where necessary to verify information provided by you. Additionally, our marketing team obtains leads from providers who have collected your consent to receive information from companies providing the types of products and services we offer.

When you disclose to us the Personal Information of another person for use in connection with our services, such as personal or professional references, you must be authorized to entrust that Personal Information to us.

2.3. Processing Purposes

We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:

  • Legal Operations
    • Managing legal components of transactions processed by Skyline Entities, such as financing, acquisitions, leasing and dispositions.
    • Conducting due diligence processes related to transactions; for instance, searches under the Ontario Personal Property Security Act (PPSA), the federal Bankruptcy and Insolvency Act, and the various provincial land registration systems may produce results including Personal Information. Similarly, other corporate searches may, from time to time, output Personal Information about officers and directors of entities with whom Skyline Entities or we do business.
    • Drafting contracts (only if Personal Information is shared).
    • Conducting investigations and initiating and defending claims.
    • Processing access requests and disclosing information, including Personal Information, where required by law or regulation or as otherwise needed for business purposes, provided that an applicable legal basis for processing Personal Information is in place.
  • Financial Operations
    • Processing transaction funding, investor distribution payments, redemption payments, and investment acceptance and deposits.
    • Producing and submitting financial and regulatory reports (i.e., Trade reporting to the Ontario Securities Commission).
  • Human Resources Operations
    • Managing recruitment processes.
    • Reviewing third party’s employee information when required to assess or close a transaction (i.e., an acquisition).
  • Marketing Operations
    • Managing commercial electronic messages.
    • Obtaining and administering marketing leads to promote our business.
    • Managing media and communications, including marketing campaigns.
    • Managing consent.
  • General Operations
    • Handling general business operations, including business continuity processes which may include, among others, handling situations that are life-threatening and require processing of Personal Information.
  • Sustainability Operations
    • Minimizing excess energy consumption and waste in Skyline properties.
  • Information Technology and Security Operations
    • Incidentally, we will process your Personal Information in connection with internal operations such as information security, authentication and verification processes, server and email administration, and management of internal requests.

Additionally, we process your Personal Information for business purposes like record-keeping, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.

2.4. Processing Activities, Profiling and Tracking

In line with our Processing of Personal Information for the purposes listed above, we conduct tasks (“Processing Activities”) that are required to provide you information and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose. The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.

Note that Processing Activities and Personal Information collected, used, and disclosed may change from time to time.


Personal Information processed by the legal department includes, among others:

  • Government issued identification documents, such as driver’s license and SIN, and financial information as required to complete transactions.
  • Personal Information included in rent-rolls: Unit number, unit type, tenant code, tenant name, rent, lease expiration, move-in date, move-out date, lease status, parking fee, storage fee, key deposit.
  • Lease information such as tenant name, last name, occupant names, address, postal code, rental unit, parking spaces and type of space, term of tenancy, type of rent payment (monthly/weekly), total rent payment, payment method, administration charge, services and utilities, rent discount, rent deposit, key deposit, smoking information, tenant signature.
  • Personal Information captured in public registries, such as property owned, and monies owed.
  • Information about claims such as Landlord and Tenant requests to vacate a unit or terminate a lease. Personal Information processed depends on the specific procedure as well as the applicable tribunal or court forms, and the evidence required.
  • Personal Information processed to respond to an access request depends on the nature of the information to be disclosed. Similarly, Personal Information processed because of an investigation or claim is dependent on the specific issue; and Personal Information disclosed on the basis of mandatory disclosure depends on the form provided by the government board or institution.
  • In relation to contract drafting, information processed is generally not Personal Information (i.e., contact information including title, work email, and work phone number); however, on an exceptional basis, Personal Information may be provided.


Personal Information processed to conduct financial operations includes investor name, address, phone number, Skyline account number; financial account name, financial holding name (REIT where units are held), holding security ID, account type (TFSA, regular, non-registered, RRSP), financial institution affiliation (Olympia, Questrade); financial institution account number, account status, date closed, transaction type (i.e., new purchase, distribution), number of shares, purchase price, book value, market value, effective date of trade, deposit slips.


  • For employment candidates: Cover letter, resume, name, phone number, email, work experience (job title, company name, start year, description of duties, current job), education (school, degree, degree status, degree year, description), referrer, highest level of education, age (range), start date, references, language skills, desired salary, opinions about Skyline values, country, postal code, ability to work remotely.
  • In the context of acquisitions, we process staffing contracts which include employer name, commencement date, duties, salaries and benefits, and signatures, as well as employment history.


Personal Information processed by marketing pertains to accounts, leads, and financial accounts. Among other items processed to track the lifecycle of leads and our relationship with you, Personal Information elements processed by marketing include name, email, phone number, CASL consent status, country, address, postal code, investment product, marketing preferences, annual revenue, company, referral, spouse name, total household income, opportunity information.


Personal information processed by the Sustainability team includes tenant name, address, unit number, and electricity consumption.

Other Information of Relevance

  • PROFILING: Profiling means the collection and use of Personal Information to assess specific characteristics of an individual, in particular to analyze that person’s work performance, economic situation, health, personal preferences, interests, or behavior. In Processing sensitive Personal Information, we abide by our non-discrimination policy. We do not have fully automated processes.

    Regarding marketing, we document your preferences, such as information, products, or services you may be interested in. You can always opt-out from our marketing communications by using the link available in emails you receive from us or by contacting us at

  • TRACKING: We track the lifecycle of our relationship with you in our database. We also track your user activity to enable our systems to recognize your browser or device and to provide, market, and improve our offerings. To this end, we and our service providers use cookies and similar technologies (pixels and beacons). To learn about cookies, visit

2.5. Sharing Personal Information

  1. Service Providers: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information.
    Some of the categories of service providers and third parties with whom we share your Personal Information include transaction partners, external law firms, government and regulatory agencies, real estate brokers, financial and other lending institutions or entities, marketing and advertising service providers, analytics providers, consultants, auditors, technology vendors, mail services, record-keeping providers, among others.
  2. Other Companies within the Group: If we determine that Processing of Personal Information by another Skyline Entity would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with another Skyline Entity, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
  3. Government Bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations.
  4. Access Requests by Third Parties: In some cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law.

3. Storage of Data, International Transfers and Transfers Outside of Quebec

Your Personal Information may be processed outside of Canada. If you are a Quebec resident, please be advised that your Personal Information is processed outside of Quebec.

Personal Information may be accessed, transferred, or transit through other countries due to the nature of the Internet and based on the hosting location of some of our service providers. Access from other countries may also be required for maintenance, security, or support management.

4. Retention of Personal Information

We will keep your Personal Information for the legally required data retention period, modified by internal requirements, where applicable, or for the period required to provide the services the Skyline Entity with whom you have a relationship, to provide you with products or services, or to manage our relationship with you.

5. Security

We understand that the security of your Personal Information is essential; because of that, we employ a range of prevention and detection tools and methods to safeguard against the loss, unauthorized access, and unauthorized disclosure of the Personal Information we hold. Additionally, we implement administrative measures, such as contractual provisions, to ensure that the parties we share your Personal Information with are subject to legal and technical requirements to protect it.

6. Your Rights

You are entitled to access and rectification of the Personal Information we hold about you. If you are a Quebec resident, you may be entitled to additional rights. To exercise your rights, please use one of the following mechanisms:

Phone: 519-826-0439
Mail: Please direct your communication to

Martin Castellan
Co-founder, Chief Administrative Officer & Privacy Officer

Attention: Legal – Privacy & Data Security
301 – 5 Douglas Street,
Guelph, ON
N1H 2S8

In connection to the exercise of your rights, we reserve the right to communicate with you to verify your identity and relationship with us, respond to questions you may have during the process, follow up with you and clarify the boundaries of the request where necessary, and to let you know about the progress of your request.

7. Changes to this Privacy Policy

This Privacy Policy is subject to changes as deemed necessary by the Skyline Group of Companies.

Report a Privacy Incident

Use this form exclusively to report incidents related to

personal information

Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual. Information about a business is NOT personal information.

. Other requests submitted via this form may not be processed.

All fields are required unless indicated.

Your province of residence is necessary to understand the legislation applicable to your report.

Please provide detailed information about the incident you are reporting.

Privacy Right Request

Use this form exclusively to request access to or correction of

personal information

Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual. Information about a business is NOT personal information.

. Other requests submitted via this form may not be processed.

All fields are required unless indicated.

Your province of residence is necessary to understand the legislation applicable to your report.

Submit a Privacy Complaint

Use this form exclusively to submit complaints or comments about

personal information

Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual. Information about a business is NOT personal information.

. Other complaints submitted via this form may not be processed.

All fields are required unless indicated.

Your province of residence is necessary to understand the legislation applicable to your report.