How we are complying with Canada's Anti-Spam Legislation

FirstService respects the choices of our contacts to determine whether they would like to receive CEMs from us.

CASL

OVERVIEW

A. Our “No Spam” CASL Promise

Canada’s Anti-Spam Legislation (“CASL“) allows recipients to control the commercial electronic messages (“CEMs“) they receive. FirstService Corporation is an Ontario-based publicly held company in the essential outsourced property services sector (“FirstService“, “we“, “us” or “our“). FirstService respects the choices of our contacts to determine whether they would like to receive CEMs from us. The anti-spam elements of our policy for compliance with CASL include:

subject to exceptions permitted by CASL (such as the exception for certain business-to-business CEMs and the exception for CEMs sent via certain electronic messaging systems)

(a) checking that we have consent before sending CEMs;
(b) setting out our sender identification information on CEMs;
(c) providing an unsubscribe mechanism for those on our CEM distribution lists;
(d) effecting unsubscribe requests promptly and, in any event, no later than ten business days after receipt; and
(e) keeping records of consents and unsubscribes.

If you currently subscribe to any FirstService CEMs, you may unsubscribe at any time by contacting us at privacy@firstservice.com.

B. Our Other CASL Promises

CASL also regulates or prohibits certain other activities in the digital marketplace, and therefore, our compliance with CASL also includes the following:

No Unsolicited Software Installation

not installing, or causing to be installed, software (including upgrades) on another person’s computer or other device without that person’s consent (obtained via appropriate disclosures based on whether or not the software is intrusive all as defined under CASL) and, where we have installed software and in the circumstances required under CASL, to help uninstall such software;

No Spyware

not to collect personal information through illicit access to the computer systems of others through means such as spyware;

No Address Harvesting

not to engage in electronic address harvesting – namely, the use of a computer program to indiscriminately collect electronic addresses, such as email addresses, which commitment includes:

(a) following due diligence to avoid inadvertently harvesting, or using harvested email addresses; and
(b) taking appropriate precautions when:
- (i) working with a third party that has been contacted to do email marketing on our behalf; and
- (ii) buying a list from a vendor to do email marketing in-house;

No Deceptive Electronic Messages

not sending, or causing to be sent, electronic messages that are deceptive, especially in connection with the subject line, locator, or sender information of the electronic message; and

No Alteration of Transmission Data

not altering the transmission data in electronic messages (which results in the messages being delivered to different destinations without express consent).

C. Administrator

If you have questions about our CASL Policy, please contact:

FirstService Corporation
1255 Bay Street
Suite 600
Toronto, Ontario
Canada, M5R 2A9

Attention: Director, Marketing & Communications
Email: privacy@firstservice.com

This policy was last updated and is effective as of February 22, 2021.