Privacy

PRIVACY POLICY

Introduction

First Capital Realty Inc. (“FCR”) develops, owns and operates urban retail properties.

This Privacy Policy (the “Policy”) sets out the manner in which FCR and its affiliates collect, use, disclose and retain your personal information.

When you submit personal information to FCR or its affiliates or authorize us to obtain personal information from other sources, you are agreeing to be bound by this Policy, including consenting to the collection, use, disclosure and management of your personal information in accordance with this Policy.

What is Personal Information?

Personal information is any information about an identifiable person.

This Policy is not intended to cover information other than personal information, such as business or anonymous information.

Consent

FCR will obtain your consent (through this Policy or other means) to collect, use or disclose personal information except where we are authorized or required by law to do so without consent.

How Does FCR Collect Your Personal Information?

We collect personal information about you from your interactions with us and from certain third parties and other sources.

We obtain personal information from you through your interactions with us (including via email, telephone, and the internet) to provide you with information about our services (such as using the FCR website inquiry form), when you apply for services from us (such as on a lease application), and in the course of FCR providing you with service.

We may also collect personal information about you from third parties, including from financial institutions, credit reporting agencies, and references you have provided. If FCR collects any personal information from a third-party enterprise, it will record the source of such personal information.

We may also obtain general information related to your use of our website, https://www.fcr.ca (“Website”), through cookies and similar technologies. We do not collect personal information that can identify you when browsing our Website. However, certain non-identifying information such as an IP address, device identifier, internet tags and navigational data may be collected in order to understand how, when, and for how long a user visits our Website.

Information gathered from the Website via cookies is used to provide you with a customized online experience and to improve our services, communications and marketing.

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Website. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. For more information on blocking cookies or targeted advertising, visit the Digital Advertising Alliance of Canada page at http://youradchoices.ca/choices/.

FCR also uses Google Analytics, a web analytics tool from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses information obtained by the cookies to evaluate your use of the Website for us, to create reports on Website activities and to provide further services related to the Website and the internet usage for us. This information may be transmitted to a server in the USA and stored there. Please note that Google Analytics information may be disclosed to

marketing agency partners that use the data to optimize marketing campaigns. Google will not

associate your IP address with any other data held by Google. For more information on Google’s

privacy policy in general and Google Analytics, please visit their website at

<www.google.ca/policies/privacy/> and <www.google.com/analytics>. You can deactivate the Google

Analytics function with a browser add-on, which you can download at

<https://tools.google.com/dlpage/gaoptout>. To do this you must install that browser add-on. This will

prevent the analysis information from being sent to Google.

FCR will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the purposes it was collected or as authorized by law.

Use and Disclosure of Personal Information

Personal information collected by FCR will only be used or disclosed for purposes described in this Policy, for other purposes disclosed to you at the time of collecting such personal information, for example, as described on a lease or PAD agreement, or for purposes to which you have otherwise given your consent. Notwithstanding the preceding, FCR may use or disclose personal information without your consent where it is permitted or required by law. Refusing to provide or withdrawing your consent in respect of FCR’s collecting or use of certain personal information may result in FCR being unable to conduct business with you.

FCR may disclose your personal information to its affiliates, service providers, advisors, agents or representatives, as required, to initiate business with you, administer services to you, carry out FCR’s and its affiliates’ business operations (including organizational restructuring, financing, marketing or other transactions), communicate with you, and as required for FCR and its affiliates to meet regulatory or legal obligations. FCR may disclose personal information to third parties in connection with the potential sale or sale of all or part of its business, and as part of completing such a transaction.

If FCR discloses personal information to third parties engaged to perform services for us, FCR prohibits the third party from using personal information for any purpose other than the specific purpose for which FCR supplies it.

In the event FCR’s affiliates or service providers are located in a foreign jurisdiction, they are subject to the laws of the jurisdiction in which they are located including laws regulating disclosure of personal information to government authorities. FCR will not however, transfer information outside of Canada without first taking reasonable steps to ensure that the personal information will receive adequate protection and that it will not be used or disclosed for unauthorized purposes.

We may also de-identify, aggregate or anonymize information about you to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. Such information may also be shared with third parties for other analytical purposes, but will not personally identify any individual and therefore is not subject to our privacy policy.

Retention of Your Personal Information

FCR will retain personal information for as long as needed to satisfy the purposes for which it was collected or as otherwise permitted or required by law.

Safeguarding Your Personal Information

Personal information under FCR’s control is protected by physical, organizational and technological

safeguards appropriate to the sensitivity of the information

FCR will take all reasonable steps to ensure that your personal information is protected from misuse,

interference, loss, unauthorized access, modification or disclosure. Where your personal information is disclosed to third parties, such as service providers, FCR requires third parties who receive personal information to use safeguards equivalent to those in place at FCR to protect that information.

Access to personal information will be limited to persons who need such personal information in order to allow FCR to provide you with its services.

However, there is always a risk to sending personal information to any third party, and you should exercise caution before sending sensitive personal information to FCR or using less secure communication methods.

Our Website may contain links to other websites. When you click on a link to another site, you leave the

FCR site and this Policy will not apply to the handling of personal information on the other site. FCR

is not responsible for, and does not endorse, the content, security, operation or reliability of any third

party site linked on the Website. If you access such websites, either directly or via the Website, you

should review the privacy policy of each site.

Accuracy and Accessing Your Personal Information

In order to ensure that the information relied on by FCR is accurate, you can ask to review your personal information by writing to FCR’s privacy officer, using any of the contact methods outlined below. FCR will give access to personal information in alternative form to an individual with a sensory disability as required by law.

You can request that corrections be made where you can show that the personal information about you is incorrect or incomplete. Please note that under certain circumstances, you may not be permitted to view your records, such as where the disclosure of your records would cause security, legal or confidentiality concerns, could harm a third party, or is prohibited by law.

Contacting FCR

If you have any questions or concerns about this Policy or about FCR’s handling of your personal information, please contact FCR’s privacy officer in writing at:

Address: Privacy Officer

First Capital Realty Inc.

85 Hanna Avenue, Suite 400

Toronto, Ontario M6K 3S3

Email: PrivacyOfficer@fcr.ca

Please note that we may need to confirm your identity or request additional details in order to process your request.

Updates to this Policy

FCR may update this Policy from time to time, at its sole discretion, and will post the current version on our Website at www.firstcapitalrealty.ca. Whenever you need to refer to this Policy you should refer to FCR’s website to ensure you have the most up to date version.

This Policy was last amended in December 2018.