Legal
Last Updated:
07.22.2022

ACCEPTANCE OF PRIVACY POLICY

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By using this website, you agree to be bound by this privacy policy.

Privacy Policy

Bay Park Centre Limited Partnership (“CIBC SQUARE”, “us”, or “our”) welcomes you to our property, Website, Platform, and other channels. This privacy policy (the “Privacy Policy”) generally applies to any personal information (as defined below in the section entitled Definition of Personal Information) collected and processed by CIBC SQUARE from or about building occupants, guests, tenants, services providers, or business partners (hereinafter “users”). The objective of the Privacy Policy is to help you understand our practices concerning the collection, use, sharing, protection, and retention of personal information and of the choices you can make in this regard. Our website (https://www.cibcsquare.com/privacy-policy/) and our web and mobile-app-based tenant engagement platform (“Platform”) are also governed by applicable terms of use found on the Website and the Platform, respectively, and the use of Wi-Fi is governed by the Wi-Fi Terms and Conditions Of Use found on our Wi-Fi portal.

By submitting personal information to CIBC SQUARE or its service providers and agents and by accessing our Website, Platform, Wi-Fi network, or properties, or by visiting CIBC SQUARE, you agree that we may collect, use and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

This Privacy Policy does not apply to third-party websites or third-party services which may be accessed by clicking on links appearing on such websites, and CIBC SQUARE is not responsible for such third-party websites or services. If you follow a link to a third-party website, that third party will have its privacy policies which you should review before submitting any personal information.

 A summary of provisions related specifically to the Tenant Engagement Platform can be found at the end of this Privacy Policy.

Definition of Personal Information

PERSONAL INFORMATION

When used in this Privacy Policy, personal information means “any information about an identifiable individual”. This may include contact or demographic information, information relating to your communications with us, or more technical information (such as users’ IP addresses, and usernames) but only when this information can identify you as an individual. CIBC SQUARE may use and share the information which is anonymized and/or aggregated.

NON-IDENTIFIABLE INFORMATION

Personal data that is de-identified and/or aggregated and cannot be associated with an identifiable individual is not considered to be personal information. CIBC SQUARE reserves the right to freely use non-identifiable personal information about you to the extent that such information is not re-identifiable.

What Personal Information Do We Collect?

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:

  • GUESTS

    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).

INFORMATION COLLECTED AUTOMATICALLY

In some cases, we may collect information automatically which may not necessarily identify you as an individual.

For instance, we may collect the following type of information:

  • VIDEO SURVEILLANCE
    We may collect video images of you at various locations at our properties through video surveillance used as a security measure and to ensure the safety of our guests, tenants and retailers, and occupants of our properties. We indicate the possibility of such collection with signage at the entrances of the property.
  • BROWSER, DEVICE AND TECHNICAL INFORMATION 
    When you visit our Website or use our Platform, Wi-Fi network, or IT systems generally, we may use electronic means such as cookies to collect technical information about your browser or device, and about your usage of our Website, Platform, Wi-Fi network, and IT systems. This information may include information about your visit or usage, including the IP address of your device, the browser you used to access our Website, Platform, Wi-Fi network, and IT systems, your operating system, your mobile device’s MAC address, resolution of the screen, language settings in browsers, the site you came from, keywords searched (if arriving from a search engine), the number of pages viewed, as well as information you entered and advertisements you saw. We may also collect your gender, age group, and interests, but such information is always aggregated and is not associated with any identifiable individual. For information on how you can limit the type of information that we collect, use or share about you when you visit and/or use our Website, Platform, Wi-Fi network, and IT systems, please refer to the section of this Privacy Policy entitled Right to Withdraw Consent.

We may also collect and use the following types of marketing and communications personal information:

  • GOOGLE ANALYTICS
    We use Google Analytics which allows us to see information on users’ online activities including, but not limited to, page views, sources, and time spent on our Website and Platform. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to a particular individual. You may opt out of the use of Google Analytics by visiting the Google Analytics opt-out page.
  • GOOGLE ADWORDS
    We use Google AdWords remarketing to advertise CIBC SQUARE across the Internet and to advertise on third-party websites (including Google) to previous visitors to our Website. AdWords remarketing will display ads to you based on what parts of the Website or Platform you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our Website or that we advertise on the Google search results page or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our Website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords remarketing, you can opt-out by visiting Google’s Ads Preferences Manager.
  • GEOLOCATION INFORMATION
    If you chose to use our mobile version of the Platform, some functionality or services (for example the transit screen) may depend on the use of your geolocation information. We will only collect such information if you chose to use such functionality or services. We may send you notifications that you chose to receive, such as reminder alerts, deals, recommendations, weekly digests, and parking prompt notifications. You may manage your notification preferences directly in the mobile app. When you use our Wi-Fi network, we may gather information about your devices, such as an anonymized version of your device’s MAC address and the Relative Signal Strength Indicator (RSSI), to determine your device’s approximate location within our property. This information is used to improve your ability to use our Wi-Fi service and connect to our network, manage our services, including troubleshooting, and generate location analytics in an aggregated format, as further detailed in the section of the Privacy Policy Why Do We Collect Personal Information? Please note that recent devices may automatically generate randomized MAC addresses.
  • TRAFFIC, ANONYMOUS VIDEO ANALYTICS AND DEVICE COUNT
    In some cases, we may use or allow third parties to use, cameras and other technologies to conduct anonymous video analytics (“AVA”) and anonymous traffic analysis (“ATA”). This allows us to estimate the number of individuals in our properties but does not allow us to identify them. We do not take or store any photos or video records of our guests for AVA or ATA. These technologies 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 the experience of our occupants and guests. We may also track devices that have accessed and/or visited our property 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 property to help us manage our property, including choosing the most appropriate tenants, and we may share this statistical information with our business partners, including our tenants.
  • SMS, TENANT ENGAGEMENT PLATFORM, AND SEND-WORD-NOW
    When you use our chat services, including the chat feature within the tenant engagement platform, we may collect metadata, such as your mobile phone number and date time stamps, linked to your interactions. We may also gather certain information automatically from electronic communications with you and store it in log files. This information may include IP addresses as well as browser, internet service provider, referring/exit pages, operating system, date/time stamp and click stream data.
  • SOCIAL MEDIA
    If you sign into our website, mobile app, or Wi-Fi using a social media account such as Facebook or Twitter, we will collect information that you have added to your registration profile from those accounts, and which is made available to CIBC SQUARE by default by Facebook or Twitter. For instance, when you log in to our Wi-Fi network using your social media account, you expressly authorize us to collect (or to receive) information about your profile, such as your name, age, gender, and email address. 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 CIBC SQUARE to collect (or the third party 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 CIBC SQUARE access to their profiles and you are one of their friends or connections or information about you is otherwise accessible through your friends or 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, tailor our content to you, and send you details of promotions or offers that we believe may be of interest to you, although at all times, in compliance with applicable privacy laws.
  • VEHICLE INFORMATION
    If you park at one of our properties, we may collect information about your vehicle for the purposes of managing our parking facilities, providing parking services to you, and enforcing our parking regulations.
Why Do We Collect Personal Information?

CIBC SQUARE collects personal information for general business-related purposes such as to help prevent fraud, unauthorized activities, claims, and other liabilities, manage its business, provide or deliver a product or service requested (through the use of our Website, Platform, or Wi-Fi network) or when necessary for the safety of a product or service that we provide or deliver,  and to ensure the security of our properties, authenticate the identity of individuals contacting us, and monitor the use of our Wi-Fi network 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 CIBC SQUARE 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).

More specifically, we may collect personal information from guests, tenants, suppliers, other business partners, and applicants for the following purposes:

  • GUESTS
    We collect personal information from you as guests to provide you with the information requested or to contact you to answer your questions, requests, or inquiries, to administer the contest or promotion which you have entered, or send you our newsletter if you have registered to receive a newsletter through our Website or our Platform, or if we have your implied consent to send you such communications. If you have accessed, registered, or signed in to our Website, Platform, or Wi-Fi network, we may also collect personal information from you to complete registration, measure and monitor traffic to the Website or Platform, improve the effectiveness of our Website our Platform, or enhance the user experience. We may collect your personal information to process your request, and provide and manage our guest services, including troubleshooting and monitoring, detecting, and responding to any activity that may be unlawful, harm the safety of our services, property, network, employees, or guests, or otherwise breach an applicable agreement, as our Wi-Fi Terms of Use. We may collect your personal information from tenants of our properties to provide you with a QA code that you may use to access our elevator banks during your visit. Moreover, we may collect anonymous information or de-identify personal information collected from our guests to understand and assess their interests and changing needs with a view to improving our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our websites and mobile apps.
  • TENANTS
    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

Subject to you providing consent, we may use your information to contact you regarding future services and/or to conduct surveys on the quality of our amenities, services, or customer service, to improve the on-site experience, or to provide you with offers for additional products and services that we feel may be of interest to you. For instance, if you access our Wi-Fi network using your social media account, we may collect and use information about your account (including your name, age, and email address) to inform you about promotions or offers that may be of interest to you, to tailor advertising content to your interests, and to understand the preferences and interests of our guests in order to customize how we promote our products and services on various channels and platforms, including social media channels. For more details on the type of commercial electronic messages (“CEM”) that you may receive from us, please refer to the section of this Privacy Policy entitled  Electronic Communications and Notifications. To withdraw your consent from such use, see the section of this Privacy Policy entitled Right to Withdraw Consent.

ELECTRONIC COMMUNICATIONS AND NOTIFICATIONS

You may receive the following type of electronic communications and notifications from CIBC SQUARE:

  • ELECTRONIC NOTIFICATIONS
    You may receive electronic notifications for various purposes including facilitating or confirming a transaction such as your subscription to our services, providing you with information about your use of our services or your current subscription or accounts, to inform you of any incident regarding the security of your information or in order to give effect to a legal right or obligation.
  • COMMERCIAL ELECTRONIC MESSAGES
    You may receive CEMs such as marketing and promotional emails from CIBC SQUARE if we have your consent to send you CEMs:
    • EXPRESS CONSENT
      You can verify that you have provided consent to CIBC SQUARE - (or verify the status of your consent) by reviewing your preferences in the Preference Center. To access your profile in the Preference Center, you must click on the link provided in the CIBC SQUARE communications which you receive, or by contacting David Hoffman, General Manager at the contact number or address provided in the Contacting CIBC SQUARE section of this Privacy Policy..
    • IMPLIED CONSENT
      CIBC SQUARE may infer your implied consent if: (i) we have an existing business relationship with you or had a business relationship with you that terminated less than two years ago (for instance, you purchased our services, you have entered into a lease with us, or registered to use our Wi-Fi, etc.); (ii) we have received an inquiry from you within the last 6 months; and/or (iii) you have provided your electronic address to CIBC SQUARE and the CEM sent by CIBC SQUARE complies with the Canadian Anti-Spam Legislation.

For more information on how you may unsubscribe from receiving such commercial electronic messages (CEMs) please refer to the section in this Privacy Policy entitled Right to Withdraw Consent.

Your Consent

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.

For more information on how CIBC SQUARE may share your personal information, please refer to the section Sharing of Personal Information of this Privacy Policy.

Right to Withdraw Consent

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
    When visiting or using our websites and/or mobile apps, you can, at any time, block the use of cookies by activating the settings in your browser. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to not accept cookies, or subsequently block cookies, you may not be able to access all or part of the content of our websites and/or mobile apps. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-ons’ settings or visiting the website of its developer.
Sharing of Personal Information

As well as any sharing listed above, we may also share your information with third parties, service providers, and affiliated companies in our group. These entities are required to respect the security of your personal information and to treat it in accordance with the law and in a manner consistent with this Privacy Policy.

CIBC SQUARE may share personal information as follows:

  • AFFILIATES AND BUSINESS PARTNERS
    Subject to our user's rights under the Right to Withdraw Consent section found in this Privacy Policy, CIBC SQUARE may share personal information with its affiliates, subsidiaries, and occupants (which may include our tenants) operating from our property, for purposes related to marketing the services offered by CIBC SQUARE, its affiliates, subsidiaries, and such occupants, at all times in compliance with applicable privacy laws.
  • 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.

Security

CIBC SQUARE 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. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure. You acknowledge that: (i) there are internet security and privacy limitations that are beyond the control of CIBC SQUARE; (ii) the security, availability, integrity, and privacy of any and all information and data exchanged between you and CIBC SQUARE through our Websites and Platform or when using our Wi-Fi network 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 CIBC SQUARE under this Privacy Policy, we may contact you by e-mail, letter, telephone, or through another secure form of communication.

Retention of Personal Information

We have personal information retention processes and retention schedules designed so that we retain users’ personal information for no longer than reasonably necessary for the purposes stated in this Privacy Policy or to meet our legal obligations.

Location, Storage, and Cross-Border Transfer

Your personal information is stored in secured locations and on servers controlled by CIBC SQUARE or its service providers, located either at our facilities or at the facilities of our service providers. Notwithstanding the foregoing, CIBC SQUARE and its third-party service providers may process or store your personal information outside of Canada, including in the United States. In accordance with the laws of those countries, in certain circumstances, your personal information may be accessed by foreign law enforcement, regulatory bodies, or other authorities.  For more information about our practices and policies regarding the use of foreign service providers, please contact us in the section of this Privacy Policy entitled Contacting CIBC SQUARE.

Children

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.

Your Rights

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:

  • Be informed in a clear, transparent, and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this Privacy Policy. If you require any further information about how we use your personal information, please let us know.
  • 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.

To exercise your rights, please contact the contact number or e-mail address provided in the Contacting CIBC SQUARE section of this Privacy Policy.

Updating and Accessing Your Information

At your request CIBC SQUARE will: (a) provide reasonable access to your information that is in CIBC SQUARE’s records; and (b) use reasonable efforts to allow you to update/correct personal information which you state is incorrect to the extent that the information has been maintained by CIBC SQUARE and if so, that such updating/correction will not CIBC SQUARE’s privacy or security interests, subject to legal or contractual restrictions as well as the understanding that it may be impossible to completely delete your information without some residual information because of backups. You may access your profile in the Preference Center to update your communications preferences by clicking on the link provided in the CIBC SQUARE communications which you receive. For access to your personal information, please contact our privacy officer at the contact number or e-mail address provided in the Contacting CIBC SQUARE section of this Privacy Policy.

Privacy Policy of Third Parties

This Privacy Policy only addresses the use and disclosure of information by CIBC SQUARE. Other websites that may be accessible through our Website or the Platform have their privacy policies and data collection, use, and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties before providing them with information or taking advantage of an offer or promotion.

Contacting CIBC SQUARE

If you have any questions about this Privacy Policy or the privacy practices of CIBC SQUARE in respect of how we collect, use and share your personal information, please direct your inquiry to David Hoffman, General Manager at privacy@CIBSQUARE.com.

Changes to Privacy Policy

CIBC SQUARE reserves the right to change this Privacy Policy at any time by 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 Website or Platform. If the changes are significant, we will provide a more visible notice or obtain consent when required by law. Your continued use of our services, Website, Platform, or Wi-Fi network after such modifications will constitute your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by the modified Privacy Policy. When significant modifications are made to this Privacy Policy, we will attempt to notify you by email. Please check our Website frequently to see any updates or changes to our Privacy Policy.

Last Update: July 27, 2022

Please note that this version does not substantively change the way we treat personal information compared to the previous version of the Privacy Policy.

ADDITIONAL PROVISIONS FOR THIS BUILDING MOBILE APP

For your convenience, we have summarized the personal information that we collect from the Tenant Engagement Platform. Please note that the list below is a subset of the functionality that may be provided to you by the Tenant Engagement Platform, and that the Tenant Engagement Platform may provide additional functionality that is not listed below. To the extent the Tenant Engagement Platform provides any functionality not listed below, including the collection, use, disclosure and processing of your personal information for such purposes, such functionality will be governed by the applicable terms of use (and privacy policy) of the Tenant Engagement Platform.

The personal information which the Tenant Engagement Platform will be collecting and disclosing to us is set out below, and how we may use, disclose or otherwise process such personal information will be as set out in our privacy policy above:

  • 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.
     

We use your personal information as described in this Privacy Policy to provide the App Services, including to:

  • 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.
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