This Privacy Policy explains how TM Holdings Management Inc (“we”, “us”, “our”) collects, uses, shares and protects personal information when you visit jefrealty.com (the “Site”), contact us, or send a request through our forms. By using the Site you acknowledge the practices described below.
1. Who we are
TM Holdings Management Inc provides property and real estate management services, including residential and commercial property management, leasing, maintenance coordination, rent collection, financial reporting and portfolio advisory. We are the controller of the personal information collected through the Site.
2. Information we collect
Information you give us
When you fill in our request form, email or call us, we may collect:
- your name, email address and phone number;
- the topic of your inquiry and the content of your message, including details about a property you own or manage;
- your confirmation that you agree to this Privacy Policy, and the date and time of your request.
Please do not include sensitive information (such as financial account numbers, government ID numbers or health data) in the form.
Information collected automatically
When you browse the Site, our servers and, if you allow it, cookies may record:
- technical data such as IP address, browser type, device type, operating system and language;
- usage data such as pages visited, time spent, referring page and approximate location derived from the IP address;
- advertising data, such as whether you arrived through one of our online ads (only with your consent).
3. How we use information
- to answer your request, prepare a management proposal and communicate with you about our services;
- to provide, operate, maintain and secure the Site, including preventing spam and abuse of our forms;
- to understand how visitors use the Site and improve its content (analytics, with consent where required);
- to measure the performance of our advertising campaigns (with consent where required);
- to comply with legal obligations and to establish, exercise or defend legal claims.
We do not sell your personal information and we do not use it for automated decision-making that has legal effects on you.
4. Legal bases
Where laws such as the EU/UK GDPR apply, we rely on the following legal bases:
- Steps before a contract — answering your request and preparing a proposal;
- Consent — analytics and advertising cookies, which you can withdraw at any time;
- Legitimate interests — keeping the Site secure and improving our services;
- Legal obligation — keeping records required by law.
5. Sharing of information
We share personal information only when necessary and only with:
- service providers that help us operate the Site and our business (hosting, email, IT support, analytics), under contracts that require them to protect the data;
- professional partners involved in your request — for example licensed brokers or contractors — only with your knowledge;
- authorities when required by law, court order, or to protect rights, property or safety;
- a successor entity in the event of a merger, acquisition or sale of assets, subject to this Policy.
6. Cookies & similar technologies
Cookies are small text files stored on your device. When you first visit the Site, a banner lets you accept all cookies, reject optional cookies, or choose categories individually. You can change your choice at any time with the link in the footer.
| Category | Purpose | Examples | Default |
|---|---|---|---|
| Strictly necessary | Security, form protection, remembering your cookie choice | PHPSESSID, jfr_consent | Always on |
| Analytics | Anonymous statistics about visits and page usage | Google Analytics (_ga, _ga_*) | Off until you opt in |
| Marketing | Measuring and personalising advertising | Google Ads (_gcl_au, conversion cookies) | Off until you opt in |
You can also block or delete cookies in your browser settings; some parts of the Site may then work less smoothly.
7. Advertising & Google services
We may advertise our services through Google Ads and use Google tools to measure the results. With your consent, Google may set cookies or use similar identifiers to show our ads and record conversions (for example, when a visitor who clicked an ad sends a request). We use Google Consent Mode, so these tags respect the choice you make in our cookie banner.
- Learn how Google uses information: policies.google.com/technologies/partner-sites
- Manage personalised ads: adssettings.google.com
- Opt out of interest-based ads from many companies: optout.aboutads.info
We do not use sensitive categories of information to target advertising.
8. Data retention
We keep inquiry data for as long as needed to handle your request and any resulting business relationship, and generally no longer than 24 months after our last contact unless a longer period is required by law. Analytics data is kept in aggregated or pseudonymous form for up to 14 months. When data is no longer needed, we delete or anonymise it.
9. Security
We use reasonable technical and organisational measures to protect personal information, including encrypted connections (HTTPS), access restrictions and protection of form submissions against automated abuse. No method of transmission or storage is completely secure, but we work to protect your information and will notify you and authorities of a breach where the law requires.
10. Your rights & choices
Depending on where you live, you may have the right to:
- access the personal information we hold about you and receive a copy;
- correct inaccurate information or complete incomplete information;
- request deletion of your information;
- object to or restrict certain processing, and withdraw consent at any time;
- receive your information in a portable format;
- lodge a complaint with your local data protection authority.
To exercise a right, email [email protected]. We will verify your request and respond within the period required by law (usually 30–45 days).
11. Regional privacy rights
Depending on the country, state or province where you live — for example under the EU/UK GDPR, the California Consumer Privacy Act or similar laws — you may have additional rights, such as the right to know what personal information we hold, to correct or delete it, and to opt out of the “sale” or “sharing” of personal information for targeted advertising. We do not sell personal information. You can opt out of advertising cookies at any time through the cookie settings. We will not discriminate against you for exercising your rights, and an authorised agent may submit a request on your behalf with your written permission. We apply the rights that the law of your place of residence grants you.
12. Age restriction
The Site and our services are intended only for persons aged 18 or older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, please contact us and we will delete it.
13. International transfers
We and our service providers may process personal information in countries other than the one where you live, including the country where our office is located (see the contact details below). Where required, we use appropriate safeguards for such transfers, such as standard contractual clauses.
14. Changes to this policy
We may update this Privacy Policy from time to time. The “Last updated” date above shows when it was last revised. Significant changes will be highlighted on the Site.
15. Contact us
Questions about this Policy or your personal information? Contact us: