INTRODUCTION
We value your business and respect your right to privacy and the following discloses the personal information collection, use and disclosure practices of Canderel. This Policy also applies to users of any Canderel websites that link to this Policy (“Websites”) unless such websites have their own data protection policy and privacy notice.
This privacy policy (the “Privacy Policy”) of Canderel, including its affiliates, all management and real estate subsidiaries owned directly or indirectly, as gathered and operating under the Canderel banner together with its managed properties and investments (“Canderel” or ‘’us’’) generally applies to any personal information collected and processed by Canderel from or about guests, prospective purchasers, clients and customers, tenants, service providers or business partners (hereinafter “users”). For the purposes of applicable laws and regulations relating to data protection and privacy, Canderel acts as a controller in respect of your personal information.
Canderel reserves the right to change this Privacy Policy at any time without notifying you of the existence of a new Privacy Policy. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by any means including, but not limited to, posting on our websites and our mobile apps. Your continued use of our services, websites, mobile apps and/or Wi-Fi after such modifications will constitute your acknowledgement of the modified Privacy Policy and your agreement to abide and be bound by the modified Privacy Policy.
1. PERSONAL INFORMATION
Personal information has the meaning given to it or any similar term (e.g., “personal information”, “non-public personal information”, “PII”, “personally referable information”) per applicable laws and regulations relating to data protection and privacy and for the avoidance of doubt, means any information which directly or indirectly identifies or otherwise relates to a living individual and which is in the possession or under the control of Canderel. Such personal information may include, without limitation, the name, age, identification number, email address, home address, telephone number, location data, financial data or online identifier of that individual, information relating to your inquiry with us, any complaints documented in a file or other personal or demographic information. It may also include other types of more technical information such as users’ IP addresses, usernames, browser history (pages accessed, date of access, location when accessed), but only when this information can identify you as an individual.
Personal Information does not include non-identifiable information being information that cannot be associated with or traced back to specific individuals with any certainty. Canderel may collect and use non-identifiable information to assess the effectiveness of web site content and traffic. This allows Canderel to improve the quality of visits to web sites managed by it by streamlining visitors’ ability to navigate these sites and developing featured programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analyses of the collective characteristics and behaviour of individuals and to measure demographics and interests. Aggregate non-identifiable information may be used to describe Canderel services and products to third parties such as prospective business partners, prospective or current tenants or purchasers and financial institutions. In any of these circumstances, only non-identifiable information in an aggregate form and not personal information is disclosed.
2. COLLECTION
We collect information, including without limitation, from visitors to the Website and others (each, referred to as an “Individual” or “you”) when an Individual: (i) uses the Website, (ii) contacts us with comments or questions (iii) signs up to receive from time-to-time email news updates from Canderel or (iv) enters into a business transaction with Canderel
For greater certainty, the information collected by Canderel from your use of the Website or as a result of you contacting us with comments or questions, includes but is not limited to information collected in our server logs (such as browser type, pages visited, referring page, IP address, date and time stamps, other statistics and errors), through cookies (such as saving your login information and storing session information) and about the device you are using to access the Website (such as hardware and operating system details). We may collect personal information from you, without limitation, in the following situations:
We may collect personal data that you provide when you contact Canderel for any reason, such as to express an interest in obtaining additional information about our services, direct questions or concerns about our services to us, the use of a “Contact Us” form or similar features, signing up for our emails or to attend an event or downloading certain content. Such information may include contact information such as name, job title, company name, phone number and email address. Additionally, some technical information relating to how you are using our website is automatically collected when you browse our Websites.
To help us respond to requests for data access and/or deletion requests as permitted by applicable laws, as well as create and maintain a trusted environment, we may collect the name, address, telephone numbers (office, home, cell), email addresses, information from government issued identification, and photograph for access card purposes.
We may collect personal data from you and from third parties in connection with the performance of due diligence on our service providers, employees, prospective purchasers and tenants and business partners. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history and job titles or roles and work experience, education and other pertinent information for the position. We may collect the information which you have included in your resume when you submit a job application or when you apply for a position with Canderel.
If you sign into one of our websites, mobile apps or Wi-Fi using a social media account such as Facebook or Twitter, we may collect information that you have added in your registration profile from those accounts, and which is made available to us by default by Facebook, Twitter or any other social media accounts. We may also collect personal information about you from your use of social media networks you participate in (“Social Media Channels”), although at all times, in compliance with applicable privacy laws. You may also choose to participate in a third party app or feature (such as one of our Facebook or Twitter apps or a similar app or feature on a third party website) through which you allow us to collect (or the third party website to share) information about you, (including personal information) such as details of your friends/connections, “likes”, comments you have shared, groups and location. In addition, we may receive information about you, (including your personal information) if other users of a third-party website give us access to their profiles and you are one of their friends/connections or if information about you is otherwise accessible through your friends’/connections’ web page, profile page or similar page on a Social Media Channel or other third-party website or interactive service. We may supplement the information we collect about you directly with the information we receive from third parties in order to enhance our ability to serve you, to tailor our content to you and to send you details of promotions and/or offers which we believe may be of interest to you, although at all times in compliance with applicable privacy laws.
We retain security guards to monitor and secure certain of our properties. Security guards may, outside of certain time or outside of certain days, collect information on persons and visitors entering our properties, including the person’s name and employer/office you are visiting, the time of entry in the property and the time of departure. Access to some of the properties may be restricted at certain times or on certain days and authorized users may only access tenant spaces by way of passcards or passcodes. Information relating to such authorized users may be collected in order to issue such passcards/codes. Readers for such passcards or passcodes may maintain logs of the dates, times, areas accessed and persons using such passcards/codes which information Canderel may access. Security guards at the properties may also collect information regarding incidents at the property including the identity of any party involved in the incident and/or witnesses to the incident and other information which they may observe or be informed of.
The use of any parking facilities at a Canderel property may entail the collection of information regarding your vehicle, model and year and licence plate of your car. The use of any designated or reserved parking in Canderel properties requires the collection of personal information such as your name, contact information, employer, vehicle model and year and licence plate number. These parking facilities may also have video surveillance cameras and they will collect your image and/or vehicle information when you access these parking facilities.
We collect information such as your name, address, credit/financial and bank information and your contact information if you enter into an offer to purchase or purchase a condominium or other real estate in a Canderel development and we may also collect other information to combat money-laundering or other similar illegal activity.
In some cases, we may collect information automatically which may not necessarily identify you as an individual. This may include information collected via our video surveillance system on our properties, technical information collected when you visit our websites or use our mobile apps, IT systems and/or Wi-Fi, geolocation (if you use our mobile apps, Wi-Fi and/or similar technologies) including anonymized data received from third parties in accordance with applicable laws), traffic information, demographic information (estimated gender, age) and device count information collected via technologies that you may encounter when you visit our properties, metadata (mobile phone number and date/time stamp) when you use our chat services, profile information if you use a social media account when interacting with us and your vehicle information if you park on one of our properties. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. For example, you may opt-out of the use of Google Analytics by visiting the Google Analytics opt-out page or you can opt out by visiting Google’s Ads Preferences Manager.
3. PURPOSE
Canderel uses such personal information to: (i) maintain accurate records; (ii) make the Websites more user-friendly; (iii) provide information to Individuals as requested by them; and (iv) provide its services to tenants and real estate to prospective purchasers and tenants and as is otherwise required or permitted by law. Canderel collects personal information for general business related purposes such as to manage its business, provide or deliver a product or service requested (through the use of our website, mobile apps and/or Wi-Fi) or when necessary for the safety of a service that we provide or deliver (for example, ensure the security of our properties, authenticate the identity of individuals contacting us, monitor use of Wi-Fi to ensure that it is lawful and complies with the Wi-Fi Terms of Use). We may also collect personal information as necessary to ensure the efficiency of the Canderel information systems and networks, protect their reliability and security, as well as prevent or reduce our commercial risk (internal training and quality assurance, prevention of fraud, unauthorized activities, claims and other liabilities).
4. CONSENT
Additionally, in certain exceptional circumstances, your personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
Consent may be withdrawn at any time; however, without such consent, Canderel may in some cases limit the services it can offer you and/or Canderel may be unable to enter into a business relationship, maintain such relationship and/or interact with you, but only to the extent that your personal information is necessary for those purposes. You may also withdraw your consent from the use or sharing of your personal information for marketing purposes or from any collection of information from cookies.
When appropriate, you are given the opportunity to: (i) opt-out of receiving communications from us; (ii) remove your personal information from our records; or (iii) elect to no longer use the Website. If you wish to opt-out of receiving further communications, please contact our Privacy Officer by email or at the address, using the contact information provided below.
You can withdraw your consent for the marketing and commercial electronic communications that Canderel sends to you at any time. To opt-out of marketing and commercial electronic communications, simply click on the link titled “unsubscribe” or “opt-out” which can be found at the bottom of any commercial electronic communication we send to you. Please note that even if you opt-out of marketing and commercial communications, we may still contact you when required by law.
5. USE OF PERSONAL INFORMATION
Personal information about our users will not be sold or otherwise transferred to unaffiliated third parties without your approval. However, Canderel may disclose personal information when authorized by law or share your personal information with its affiliates, subsidiaries and tenants operating from its properties, for purposes related to service providers that are retained to perform work on our behalf, as well as in the context of a business transaction (for example in the context of a merger or sale of any parts of our business). Canderel may share personal information as follows:
Canderel may share personal information with its affiliates, subsidiaries and tenants operating from our properties, for purposes related to marketing the services provided or any real estate offered for sale by Canderel or its business partners or such retailers, at all times in compliance with applicable privacy laws.
We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by Canderel to perform work on its behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required and we ensure that they have entered into contractual arrangements that provide adequate protection of your personal information and which prohibits them from using the information for purposes other than to carry out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others.
From time to time, Canderel may disclose your personal information if such disclosure is necessary for the establishment, exercise or defense of legal claims, or as otherwise permitted by law, for instance if Canderel is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid summons, search warrant, government investigation, other legally valid request or investigation or if reasonably necessary to protect the rights, property and safety of others or ourselves and with the insurers who may be involved in an incident at a property. We may also share information with tenants in our properties about who is using passcards or passcodes to enter their premises or if an incident at a property concerns them. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law.
We may disclose personal information to a third party in connection with a corporate merger, acquisition, consolidation, the sale of a part of our business, a business unit or any property or any interest in such property, or other fundamental corporate change, whatever form it may take. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
If you complete and submit an employment application (including an online application found on our Website), you hereby consent to the disclosure of your completed on-line employment application to Canderel human resources personnel.
Information collected as part of any security programs Canderel maintains for the buildings or parking facilities on its properties may be used for the improved security and protection of the properties, the tenants and other building occupants, to respond to emergencies and in any inquiries relating to incidents that occur at the property and for purposes of improved management of our properties and parking facilities.
6. SECURITY
Canderel has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. Canderel maintains reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. Websites have appropriate security measures in place to protect against the loss, misuse and alteration of personal information under the care and control of Canderel. Any information transmitted via the Internet, however, may be intercepted by third parties. Canderel does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. You acknowledge that: (i) there are Internet security and privacy limitations which are beyond the control of Canderel; (ii) the security, availability, integrity and privacy of any and all information and data exchanged between you and Canderel through our websites and mobile apps or when using our Wi-Fi cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party. Because of this, we cannot ensure or guarantee the security of any such information. In the event there is a security incident concerning any of your personal information collected and retained by Canderel under this Privacy Policy, we may contact you by email, letter, telephone or through other secure form of communication.
7. CHILDREN
The Websites are intended for use by persons over 18 year of age. We do not knowingly solicit or collect personal information on the Websites from children under the age of 18. Our services (including our websites, mobile apps and/or Wi-Fi) are not intended for children under the age of 18. If you are under the age of 18 please do not use our services (including our websites, mobile apps and/or Wi-Fi), and if you are over the age of 18 but under the age of majority in the province in which you reside, you should use our services (including our websites, mobile apps and/or Wi-Fi) only with the involvement and permission of a parent or legal guardian.
8. CONTACT
If you have any questions about this Privacy Policy or the privacy practices of Canderel in respect of how we collect, use and share your personal information or to file a complaint concerning the collection, use and/or disclosure of personal information, please send an email to the Privacy Officer at privacy@canderel.com.
All complaints will be investigated by Canderel’s Privacy Officer as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints clearly and promptly and will be notified of any relevant steps taken or to be taken as a result of a complaint.
Canderel Management (West) Inc.— licensed brokerage Alberta. Canderel Pacific Management Inc. — licensed brokerage British Columbia.
To contact Canderel’s Privacy Officer, please email privacy@canderel.com
900–2000 Peel Street, Montreal, QC H3A 2W5 Canada
