Effective Date: September 2025

Please read the following policy carefully before using this website.

Lightwell Homes Ltd., and its parents, subsidiaries, related companies, and affiliates (collectively, “Lightwell,” “we,” “our,” or “us”) have published this privacy notice (this “Notice”) to explain how we collect, use, disclose, and store personal information when you access our services, including our websites, sales centres, online portals, registration forms, project marketing and realtor services (collectively, our “Services”).

We value transparency. To help you scan quickly, we begin with Summary Highlights, followed by the full details.

Summary Highlights of this Notice

Realtors / Brokerages:
Most information we collect about you is business information (e.g., name, brokerage, license number, work email/phone). We use it to support and better understand our realtor community, coordinate previews and launches, and provide and improve our Services.

Clients / Purchasers / Prospects (incl. clients of realtors):
We may receive your personal information directly from you or from your realtor/brokerage, project marketing firm, or via our registration forms and sales centre interactions. We use it for the purposes provided—including contacting you about properties, floor plans, pricing, promotions, events, and purchase processes. For information shared with us by your realtor, please contact your realtor first with any questions or requests.

Website / Portal Users:
We collect information you provide (e.g., email, preferences) and information collected automatically (cookies, pixels, analytics, IP address, device/browser). We use this to operate, secure, and improve our Services and deliver more relevant content and advertising.

Employees / Contractors / Job Applicants:
If you apply to work with us, we collect and use your personal information to assess your application. If hired, a separate employee privacy notice may apply.

Application of This Notice

What Does this Notice Cover?

This Notice applies to all personal information that we collect, use, disclose, and store when you access our Services, including interactions related to project registrations, sales releases, open houses, previews, website use, online portals, and communications with Lightwell and its marketing or realtor partners.

What Does this Notice Not Cover?

• Realtors: Information we receive from third parties, including realtors, brokerages, or project marketing firms, will generally be used for the purposes for which it was provided (e.g., following up about properties of interest). Questions about how your realtor collected or shared your information should be directed to your realtor.
• Non-Personal Information: Business contact information and anonymized/aggregated data are not considered personal information under many privacy laws. We may anonymize personal information; once anonymized, it is no longer personal information.
• Jurisdiction-Specific Practices: We operate in multiple jurisdictions. We may adopt practices that address specific local requirements or rely on permitted statutory exemptions as applicable.

If you are unsure how this Notice applies to you, Contact Us.

Changes to this Notice

We may update this Notice by posting a revised version on our websites. Our collection, use, disclosure, and retention of your personal information will be governed by the version then in effect. Your continued use of the Services following notice of changes constitutes acceptance.

Collecting Your Personal Information

Information You Provide Directly

We collect personal information when you voluntarily provide it, such as when you:

• Complete website or sales-centre registration forms (e.g., “Register,” “Contact Us,” “Book an Appointment,” “Download Brochure”);
• Request information on developments, pricing, availability, floor plans, incentives, or events;
• Interact with us at open houses, previews, or sales events;
• Communicate with us by email, phone, or in person;
• Create or use accounts on our portals (e.g., purchaser portals, document rooms);
• Submit a job or contractor application.

Personal information may include: name, email, phone, mailing address, preferred contact method, property interests (budget range, bedroom count, timing, neighbourhood), realtor/brokerage details, and any information you choose to provide (e.g., survey responses, accessibility needs for showings).

Information We Receive from Third Parties

We may receive personal information about you from:

• Realtors/brokerages representing you;
• Project marketing firms engaged by Lightwell;
• Platform providers (e.g., sales, contract, payment, and signature platforms);
• Event or registration partners.

They are responsible for obtaining appropriate consent or relying on a lawful basis before sharing your information with us.

Information Collected Automatically

When you access our websites or portals, we automatically collect certain information using common technologies:

• Cookies: Our Services use cookies to operate, remember preferences, enhance user experience, and measure performance. You can disable cookies in your browser; doing so may affect some features. Learn more at allaboutcookies.org.
• IP Address & Device Data: We collect IP address, device and browser type, operating system, timestamps, pages viewed, and files downloaded. We use this to understand website traffic, usage patterns, and improve security and performance.
• Web Analytics & Remarketing: We use analytics and advertising tools (e.g., Google Analytics/Ads, Meta Pixel) to measure engagement and deliver more relevant content/ads. These providers may set their own cookies or similar technologies. See Google’s privacy policy at policies.google.com/privacy and Ads control at policies.google.com/technologies/ads.
• Web Beacons / Pixels: We may use pixels (e.g., Meta/LinkedIn) to understand how users interact with our pages and campaigns.
• “Do Not Track” Signals: Our Services currently do not respond to DNT signals. For information about DNT, see allaboutdnt.com.

Using Your Personal Information

We use personal information to:

• Communicate & Respond: Contact you regarding inquiries, registrations, showings, events, and materials you request (brochures, price sheets, floor plans, feature lists).
• Project Marketing: Send project updates, releases, incentives, promotions, and invitations; coordinate realtor previews and purchaser events.
• Sales Processes: Facilitate pre-sale and sale processes (e.g., contract portals, e-signing, deposits, purchaser due diligence), including sharing information with licensed brokerages, project marketing firms, and MLS participants where relevant.
• Personalization & Improvement: Operate, analyze, and improve our websites, portals, campaigns, and customer experience.
• Compliance: Meet legal, regulatory, and industry obligations, including CASL compliance and, as applicable, FINTRAC obligations for anti-money-laundering and anti-terrorist financing.
• Security & Integrity: Protect our Services, investigate potential violations, and prevent fraud or abuse.
• Recruitment: Consider and manage job or contractor applications.

We may de-identify or aggregate data for analytics and business reporting. De-identified/aggregated data is not personal information and may be used for any lawful purpose.

Sharing and Disclosure of Personal Information

With Our Service Providers (Processors)

We share personal information with service providers who assist us in delivering the Services, including:

• Project marketing & advertising vendors (campaign and audience management, lookalike modelling, email/SMS tools);
• Customer support and CRM providers;
• Hosting, cloud, and security providers;
• Sales and purchase platforms (e.g., purchaser portals, e-signature, payment processing);
• Analytics and measurement partners.

Service providers receive only the information they need and must protect it in accordance with applicable law and contractual obligations, using it solely for the purposes we specify.

With Third-Party Recipients (Controllers)

We may disclose personal information to:

• Licensed real estate brokerages, sales representatives, MLS participants, and project marketing firms engaged by Lightwell, to conduct sales, follow-up, and customer communications;
• Affiliates within the Lightwell group;
• Regulators and law enforcement where required by law, or to protect rights, safety, or property;
• FINTRAC, as applicable, to help detect/prevent money laundering and terrorist financing;
• Business transaction counterparties (and their advisors) in connection with mergers, acquisitions, reorganizations, or asset sales, subject to confidentiality.

Where required by law, we will obtain your consent prior to such disclosures.

Cross-Border Transfers

Service providers and recipients may be located outside your province/country, including in Canada and the United States. Your personal information may be subject to the laws of those jurisdictions and accessible to law enforcement and national security authorities. For questions about cross-border practices, Contact Us.

Marketing Communications & CASL

By registering with Lightwell (online or at a sales centre), providing your contact details to our teams or partners, or otherwise indicating your consent, you agree to receive commercial electronic messages about Lightwell projects (e.g., emails/SMS on releases, events, promotions). You may withdraw consent at any time by using the unsubscribe link in our messages or contacting us directly. Even if you opt out of marketing, we may still send transactional or account communications.

If you are represented by a realtor, you may also receive communications from them, subject to their own privacy practices.

Your Rights

Subject to applicable laws (including British Columbia’s PIPA) and any legal restrictions, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccuracies;
• Withdraw consent to marketing or other processing (where consent is the basis);
• Request deletion/erasure (subject to retention requirements);
• Object to or restrict certain processing.

We may request information to verify your identity before acting on a request. If we cannot comply, we will explain why (subject to legal limits). You may also have the right to complain to your local privacy commissioner.

To exercise rights, see Contact Us.

Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Notice, to maintain appropriate business records, and to comply with legal and regulatory obligations (including warranty and tax records). We may anonymize information instead of destruction where appropriate.

Security

We use reasonable physical, technical, and organizational safeguards designed to protect personal information against loss, theft, and unauthorized access, use, disclosure, or modification—appropriate to the sensitivity of the information. However, no method of transmission or storage is fully secure.

If you maintain an online account, you are responsible for keeping your credentials confidential and notifying us immediately of any suspected unauthorized use.

Children’s Privacy

We do not knowingly collect personal information from children under 13 without verifiable parental/guardian consent. If you believe a child has provided personal information to us without consent, please Contact Us.

Third-Party Services and Links

For convenience, our Services may link to third-party sites or integrate with third-party platforms (e.g., MLS displays, e-signature or payment providers). Those third parties collect and use personal information under their policies. We encourage you to review their privacy notices before use.

Do We Collect Personal Information About Third Parties from You?

If you use referral/invite or “send to a friend” features, you must ensure you have the recipient’s permission before sharing their details with us. We will use such information only to facilitate the requested communication unless otherwise stated.

Contact Us

If you have a question, comment, request to exercise your rights, or a privacy complaint, please contact our Privacy Officer:

Privacy Officer – Lightwell Homes
Address: 1666 W 8th Ave. Vancouver, BC V6J 1V4
Email: info@lightwellhomes.ca

If your question relates to information originally provided by a realtor, please contact the realtor first. If unresolved, you may contact us and we will do our best to assist, though we may not be able to address matters outside our control.

Legal/Jurisdictional Notes (Informative)

• This Notice is intended to comply with applicable Canadian privacy laws, including British Columbia’s PIPA and CASL (for commercial electronic messages).
• For purchasers, Canadian federal FINTRAC obligations may apply in real estate transactions.
• Where local laws grant additional rights or impose additional obligations, Lightwell will comply as required.

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