Effective date: September 9, 2026

This policy applies to Cavly Group’s brochure-style website and direct communications with Cavly Group.

1. Our commitment

Cavly Group Inc. and its affiliated companies (collectively, “Cavly Group”, “we”, “us” or “our”) develops, builds, owns and manages purpose-built rental housing. We respect privacy and handle personal information in accordance with applicable Canadian privacy laws, including PIPEDA, where applicable.

2. Information we collect

The website primarily provides information about Cavly Group, its business and its projects. The website displays contact information so visitors can contact us directly. We may collect:

• contact details and the contents of communications sent to info@cavly.ca or otherwise provided directly to us;

• information provided by individuals who contact us regarding development opportunities, projects, partnerships, employment opportunities or general business inquiries; and

• basic technical and usage information associated with visits to the website, such as IP address, browser, device, referring page and pages viewed.

Do not send sensitive financial, identification, medical or credit information unless we specifically request it through an authorized secure process.

3. How we use information

• respond to communications and provide requested information;

• assess development, project, partnership, employment and general business opportunities;

• operate, secure, maintain and improve the website;

• understand general website usage and performance; and

• comply with legal obligations and protect our rights, property and security.

4. Consent and communications

We collect, use and disclose personal information with meaningful consent, except where otherwise permitted or required by law. Consent may be withdrawn, subject to legal or contractual restrictions and reasonable notice.

5. Website hosting, cookies and analytics

The website is hosted using Squarespace. Squarespace and related service providers may process technical and usage information to host, secure, operate and measure the website. The website may use essential cookies and basic analytics associated with its operation. If Cavly Group later introduces non-essential advertising, remarketing or enhanced analytics technologies, this policy and any required cookie choices will be updated before or when those technologies are used.

6. When we share information

We do not sell personal information. We may share information with affiliated companies and service providers that support our website and operations, including hosting, technology and professional service providers. Information may also be disclosed with consent, in connection with a proposed business transaction, or where permitted or required by law.

7. Processing outside Canada

Cavly Group’s hosting and other service providers may process or store personal information outside Ontario or Canada, including in the United States. Information may therefore be subject to foreign laws and lawful access by courts, law enforcement or regulatory authorities.

8. Retention, security and privacy incidents

We retain personal information only as long as reasonably necessary for the stated purposes and applicable legal or recordkeeping requirements. We use reasonable safeguards, but no internet transmission or storage system is completely secure. Where required by law, we will notify affected individuals and the appropriate regulator of a breach creating a real risk of significant harm and maintain required records.

9. Access, correction, external links and changes

Subject to applicable exceptions, you may request access to or correction of your personal information. We may verify identity before responding. The website may link to third-party services that we do not control. We may update this policy by posting a revised version and will provide additional notice or obtain consent where required.

10. Contact us

Privacy Officer Cavly Group Inc. and its affiliated companies 2787 Brighton Road, Oakville, ON L6H 6J4 info@cavly.ca