INFORMATION COLLECTED FROM OR ABOUT YOU
In many cases, we collect personal information directly from you when you visit our property, rent space in our property, interact with us (inquiry) or use our services, Website, Platform, Wi-Fi network, register to receive our newsletter, or enter a contest or promotion. We may also collect personal information when you rent space on our property or when you submit a job application. You will therefore know when we collect this information.
In some other cases, we may collect personal information from third parties (for example, from credit score companies or when conducting a background check) but at all times, with your prior consent or as authorized by law.
More specifically, we may collect personal information from you in the following situations:
We may collect your name, contact information, e-mail address, and other similar types of information when you are interacting with us, for instance when you make an inquiry or contact us, when you register to receive our newsletter, when you enter a contest or promotion when you use our Website, Platform, or Wi-Fi network (if you chose to provide your information), or when you download or use the Platform.
We also collect personal information such as your email address and name when you visit a tenant located at our properties. The tenant must provide us with your email address and name so that we can send you a QR code that provides you with access to the elevator banks and their unit during your visit.
When you use our chat services, we will also collect personal information contained in the messaging content.
- TENANTS, AS INDIVIDUALS
We may collect the name, address, telephone numbers (office, home, cell), email addresses, credit reports, information from government-issued identification, banking information, insurance policy number, and other information regarding insurance, and photographs for access card purposes (for occupants only).
- TENANTS, AS BUSINESS ENTITIES
We may collect the name, address, telephone numbers (office, home, cell), email addresses, credit report, government issued identification, banking information, insurance policy number and other information regarding insurance, photograph for access card purposes (for occupants only), as well as details regarding the existence of a dispute between a consumer and a merchant from our tenants.
- SUPPLIERS AND OTHER BUSINESS PARTNERS, AS INDIVIDUALS
We may collect the name, address, telephone numbers (office, cell), email addresses, IT systems activity logs, and in certain circumstances, personal information collected in the context of a background check (such as employment records, credit records, and criminal records).
More specifically, we may collect personal information from guests, tenants, suppliers, other business partners, and applicants for the following purposes:
We collect personal information from tenants to evaluate their creditworthiness, evaluate and process applications for tenancy, prepare leases, and provide tenants with relevant information and services throughout the term of the lease (including specialized services and memberships, such as for parking and fitness facilities). We may also use tenants’ personal information for emergency, security, or incident reporting involving video, swipe card, and other surveillance methods, for insurance, security, and risk management purposes, and generally speaking, to establish, manage or terminate our business relationship;
- SUPPLIERS AND OTHER BUSINESS PARTNERS
We collect personal information from suppliers and other business partners to evaluate and select them, initiate orders, process payments, maintain our business relationships, establish and maintain responsible business relations with clients and partners, to provide ongoing service to protect the security of our IT systems, such as by maintaining activity logs and to manage risk;
- RESEARCH AND DEVELOPMENT
Subject to applicable laws and, when necessary, with your consent, we may collect and use anonymous or de-identified information to understand and assess the interests and changing needs of our guests with a view to improving our products and services and developing new ones, to measure and monitor traffic at, understand how our guests interact with and/or return and/or visit our property, evaluate potential improvements or other modifications to the functionality of our Website, Platform, Wi-Fi network, as well as to improve the experience of our guests.
Learn more about the internal research and development purposes for which we collect and use anonymous and de-identified information.
We may collect anonymous and de-identified information for the following internal research and development purposes:
• If you visit our Website or use our Platform or Wi-Fi network, we will use a browser, device, and technical information collected to measure and monitor traffic and improve the effectiveness of our Website, Platform, or Wi-Fi network or enhance the experience of our guests. For instance, the technologies used in our properties to conduct anonymous video analytics and anonymous traffic analysis allow us to consider certain demographic information about our guests (such as gender and age) and their location within our properties, on an anonymous basis, for the purpose of improving their experience. We may also track devices that have accessed and/or visited our properties or used our services, Website, Platform, or Wi-Fi network, on an anonymous basis, for similar purposes. We may use statistical data about traffic in our properties to help us manage our properties, including choosing the most appropriate tenants, and we may share this statistical information with our business partners, including our tenants.
• We may also use the location information collected automatically from your Wi-Fi-enabled device or similar technologies, including anonymized data received from third parties in accordance with applicable laws, to generate spatial analyses in an aggregated format, which allows us to understand how our guests interact with our properties, and how many guests return and/or visit our other properties. We use this information to manage our properties and support the operational and decision-making process.
SURVEY AND MARKETING PURPOSES
In certain circumstances, your personal information may be collected, used, or disclosed without consent in case of an emergency, when authorized by law (for example, to detect or prevent fraud or illegal activity), or when required to comply with a court order or a similar type of requirement.
Learn more about when we may collect, use or disclose your personal information without consent.
EXCEPTIONS TO CONSENT REQUIREMENT
In certain circumstances, your personal information may be collected, used, or disclosed without consent. These exceptional circumstances may include:
- to perform a contract or agreement that we have entered into with you;
- where it is clearly in your interest and consent cannot be obtained in a timely way, such as in emergencies, where the life, health, or safety of an individual is threatened, or where legal, medical, or security reasons make it impossible or unrealistic to obtain consent;
- when information is being collected, used, or shared for the detection, prevention of, or remediation of, the breach of an agreement, fraud, or other illegal activity, and the collection of consent might defeat the purpose of collecting the information; and
- to comply with a subpoena, warrant, or other court order, requests received from law enforcement authorities, or as may be otherwise required or authorized by law or any competent regulatory authority.
Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, CIBC SQUARE may in some cases limit the services it can offer you, and/or CIBC SQUARE 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 any collection of information from cookies.
- E-MAIL OR TELEPHONE SOLICITATION MARKETING AND QUALITY CONTROL COMMUNICATIONS
You may decide that you prefer CIBC SQUARE not to use your personal information to promote new and/or additional services which may be of interest to you, not share your information with our affiliates, subsidiaries, and tenants from our property and not contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by emailing us at privacy@CIBCSQUARE.com.
- COMMERCIAL ELECTRONIC MESSAGES
You can withdraw your consent for the marketing and commercial electronic communications that CIBC SQUARE sends to you at any time. To opt out of marketing and commercial communications, simply click on the link entitled “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.
- OPTIONS RELATED TO COOKIES
CIBC SQUARE may share personal information as follows:
- AFFILIATES AND BUSINESS PARTNERS
- THIRD-PARTY SERVICE PROVIDERS
We may hire service providers to perform services on our behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required and ensure that they have entered into contractual arrangements that provide adequate protection of your personal information. They are prohibited from using the information for purposes other than carrying out the services they have been engaged to provide. These service providers are not permitted to disclose this information to others.
- AS PERMITTED OR REQUIRED BY LAW
CIBC SQUARE may disclose your personal information if such disclosure is necessary for the establishment, exercise, or defense of legal claims, as part of the administration of our loss prevention program, or as otherwise permitted by law. For instance, we may disclose your 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 and ourselves. 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.
- BUSINESS TRANSACTION
We may disclose personal information to a third party in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business, business unit, or 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.
Only those employees of CIBC SQUARE or trusted third-party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about our users.
CIBC SQUARE recognizes the importance of safeguarding the privacy of children and encourages parents to regularly check and monitor their children’s use of online activities. Our services (including our Websites, Platform, and/or Wi-Fi network) are not intended for children under the age of thirteen (13). IF YOU ARE UNDER THE AGE OF THIRTEEN (13), PLEASE DO NOT USE OUR SERVICES (INCLUDING OUR WEBSITE, PLATFORM AND/OR WI-FI NETWORK), AND IF YOU ARE OVER THE AGE OF THIRTEEN (13) BUT UNDER THE AGE OF MAJORITY IN THE PROVINCE IN WHICH YOU RESIDE, YOU SHOULD USE OUR SERVICES (INCLUDING OUR WEBSITE, PLATFORM AND/OR WI-FI NETWORK) ONLY WITH THE INVOLVEMENT AND PERMISSION OF A PARENT OR LEGAL GUARDIAN. No personal information is deliberately or knowingly collected from children under the age of thirteen (13) by CIBC SQUARE without parental consent. If we are informed that we have collected personal information of a child under the age of thirteen (13) or the applicable legal age in the country of residence of the child, we will delete any personal information related to such child.
Applicable privacy law gives you a number of rights when it comes to the personal information we hold about you. The key rights are set out below. Under certain circumstances, by law, you have the right to:
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you
- Request the rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Withdraw your consent, as described in the Section Right to Withdraw Consent above.
- Lodge a complaint with the Office of the Privacy Commissioner of Canada if you think that we are using your personal information in a way that breaches applicable privacy laws.
We may need to request specific information from you to help us understand the nature of your request, confirm your identity, and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
ADDITIONAL PROVISIONS FOR THIS BUILDING MOBILE APP
- When you download our Mobile App and set up an account, we, through our service provider, will collect certain personal information from you such as, your email address and password, in order to create and administer your account. Additionally, we, and our service provider, will collect personal information you provide as a part of any support requests submitted via the “Help” sections of the Mobile App, including your name, email address, and the content of your request.
- In an ongoing effort to better understand and serve the users of the App Services, CIBC SQUARE may conduct research on customer and user demographics, interests and behavior based on the personal information and other information provided to us on the Mobile App. This research may be compiled and analyzed on an aggregate basis. CIBC SQUARE may share this aggregate data, as well as anonymized and aggregated statistical and usage data, and data related to the functionality of the Mobile App, with its affiliates, agents and service providers, to use and disclose for their own purposes, as permitted by applicable law, This aggregate information does not identify you personally, nor can it reasonably be associated with you.
- Provide you with information, products and services that you request from us;
- Respond to an enquiry or other request you make when you contact us via the Mobile App, including for customer support;
- Identify a user for authentication to the Mobile App;
- Notify you about any changes to App Services;
- Carry out our obligations arising from any contracts;
- Issue a notice or corrective action to you in relation to any of the App Services, if required;
- Help us improve the content, functionality, and security of the Mobile App and App Services, and to better understand how you use the App Services;
- Provide you with information about events, promotions, features, or other services which we believe will be of interest to you similar to those that you have already attended, enquired about, or purchased; and
- Share your personal information with third party providers of amenities offered through the App Services, if you chose to use such amenities, for example fitness classes, in order to fulfill your requests, reservations, and contracts with these third party amenities providers.