Last Update: February 1, 2018
Personal Information, however, does not include any information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address.
COLLECTION OF PERSONAL INFORMATION
QuadReal collects Personal Information in a variety of ways: directly from you when you provide it, indirectly from your devices and online use, and from other third parties. We describe these ways in more detail below.
From you directly: We may collect Personal Information when you provide your information to us directly, such as when you contact us, enter your Personal Information on our Website or fill out a rental or job application.
- We may collect and use the Personal Information that you provide to us via your resident portal account: for instance, your name, email address, country of residence and/or other registration or application information.
- If you apply to rent one of our suites, you may be asked to provide your address, driver’s license number, year of birth, property ownership status, mortgage/rent payment, balance, social insurance number (optional), employment information/history, reference information, income and banking information.
- Some payment information (for instance, bank account number) so that we can process and reconcile rent transactions.
- Information about your tenancy, such as confirmation of insurance and utilities, service issues in the suite, move dates, parking requirements, permitted guests and visitors, names of persons residing in suite, emergency contact information, vehicle information including license plate numbers, and special needs of owners (for fire evacuation, security and accessibility).
- Name and contact information may be collected if you participate in one of our social media forums or an online chat (where available) with one of our QuadReal representatives so that we can locate our discussion and follow-up with you if necessary.
- We may collect information about you offline, such as when you visit QuadReal offices or properties, attend one of our events, sign up for a contest, place a service request (either online or over the phone), or contact our customer service.
- Images, movements, actions, or other identifiable information about our residents and visitors may be captured by video equipment monitoring the common areas at our properties. The purpose of such monitoring is to enhance security, safety and reasonable use and enjoyment by all lawful users of the property.
From your devices: We collect Personal Information from your devices, including:
- Through our digital services, including our Website, our software applications, social media pages, and in e-mail or text messages and when you log on or use our wi-fi networks.
- Automatically when you use a browser or your device. This information may include your Media Access Control (MAC) address, type of computer or device, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the services (e.g. the RentCafé App) you are using.
- Automatically when you visit our Website, via cookies, web beacons and other digital markers:
- QuadReal or our advertisers or other third parties may send a “cookie” to a person’s computer. A cookie is a small piece of data that is sent to an individual’s Internet browser from a web server and stored on a person’s computer hard drive and that can be re-sent to the serving website on subsequent visits. A cookie, by itself, cannot read other data from the computer’s hard disk or read other cookie files already on the computer.
- Cookies also allow QuadReal, in the case of our third party advertisers, to provide individuals with online advertising and to customize the sort of advertisements advertisers provide. Cookies may also be used in online advertisements to see how individuals interact with QuadReal advertisements. Individuals may be able to choose whether or not to accept cookies by changing the settings of their Internet browser, but some functionality of the website may be impaired or not function as intended.
- Some of QuadReal’s web pages and electronic communications may contain web beacons (sometimes referred to as “pixel tags”). Web beacons collect only limited information, including a cookie number; time and date of a page view; and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These web beacons do not carry any Personal Information and are only used to track usage of the website and activities associated with the website.
- We may assign users a unique internal identifier to help keep track of their future visits. We use this information to gather aggregate demographic information about users, and we use it to personalize the information users see on the website and some of the electronic communications users receive from us (if they have they provided their consent to receive such communications). We keep this information for our internal use, and this information is not shared with others.
From other third parties: We may also collect Personal Information from other sources, such as our affiliated companies (including QuadReal Property Group Limited Partnership), retailers, consumer reporting agencies, government agencies, insurance providers and others. For example:
- We collect credit information from credit reporting agencies if you apply to rent one of our suites or agree to be co-signor or guarantor of an applicant.
- If you are an applicant for employment, we may obtain information about you from government agencies in order to ensure that you have not violated the law;
- We also may receive information about you from other sources, such as public databases, joint marketing partners, third-party repair or service centers, and social media platforms.
USE OF PERSONAL INFORMATION
We do not collect, use, or disclose Personal Information for a new purpose that was not previously identified without, first, explaining the new purpose to you and, second, obtaining consent.
We collect and use Personal Information for many purposes, including to:
- Provide you with QuadReal products and services and related activities, such as administering your suite services, managing move in/out dates and arranging suite viewings;
- Share with our affiliated companies (including QuadReal Property Group Limited Partnership) to manage your tenancy, the building and related business purposes;
- Communicate with you, such as when you call us; make a request or inquiry; enter a contest or sweepstakes; complete a survey; or share a comment or concern. As well, we use this information to respond to and investigate your inquiries, send you newsletters, brochures, alerts or other materials; to request and provide feedback; and to facilitate social sharing and communication;
- Facilitate a payment and provide related customer service;
- Improve our products and services through quality assurance and improvement activities, including to develop and promote new products and services; to improve or modify our existing products and services; and to analyze and improve the safety and security of our products and services.
- Monitor building and suite performance, including delivering any services requested by you; and complying with legal and contractual requirements;
- Perform analytics, such as to understand and improve how people use our Website (e.g. Google analytics), mobile applications, and products and services; generate insights and understand how people interact with us;
- Operate and improve upon our business and lawful business activities; to maintain our programs, accounts, and records; for research; to determine your satisfaction with our products and services; to detect and prevent fraud or misuse of our products and services; and
- Defend or protect ourselves, and our tenants, employees or third parties, from harm or in legal proceedings; protect our rights; protect our security and the security of our tenants, employees, and property; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance; and notify you of safety and security issues.
We limit the collection of Personal Information to that which is necessary for the purposes identified to you, and collect Personal Information through fair and lawful means. For example, we limit the collection of your financial and contact information by only collecting the information deemed necessary to process a transaction and for business purposes.
LIMITED USE AND DISCLOSURE OF PERSONAL INFORMATION
We do not use or disclose your Personal Information for purposes that are not identified at the time of collection, except with your consent or as otherwise required or permitted by law. QuadReal does not sell, rent or share its tenant lists to third parties for marketing purposes.
We may disclose Personal Information to third parties, including the following:
- To credit reporting agencies, government institutions (e.g. departments of motor vehicles or other relevant agencies), and insurance providers in order to process your lease or other tenancy interaction;
- To social media account providers, if you connect your social media account with a QuadReal account; and
- To business partners, such as utility providers not owned by QuadReal.
On rare occasions, we may disclose Personal Information without your knowledge or consent where we are required or permitted by law to do so (e.g. in response to a warrant or subpoena, in an emergency that threatens life or safety, etc.). When we are required or permitted by law to disclose Personal Information, we take reasonable steps to verify the lawful authority (where applicable) for the request and we disclose only the information that is legally required or otherwise permitted to be disclosed.
If QuadReal is a party to a business transaction (as set out in applicable privacy legislation, and which includes the purchase, sale or other acquisition or disposition of QuadReal or a part of QuadReal), we may disclose your Personal Information to the other party or parties to the business transaction for the purposes of their due diligence investigations. If the business transaction is completed, the parties to the transaction may use and disclose your Personal Information for carrying on the business or activity that was the object of the transaction, in accordance with privacy legislation.
Aside from disclosures such as those above, we may share Personal Information with our service providers and business partners when necessary to perform services on our behalf, such as:
- With third parties that provide services to QuadReal, such as web hosting, data analytics, payment processing, IT services, customer service and similar processing activities.
- With our business partners to help develop and market programs, products and services and present targeted content including targeted advertising.
Each of our service providers is required by contract or other binding means to comply with our privacy standards to protect the privacy of your Personal Information, and to only handle your Personal Information for QuadReal’s purposes (and not for its own purposes).
You may always choose not to supply us with your Personal Information. However, if you choose not to supply us with your Personal Information, it may impact our ability to offer you our products or services or respond to your needs.
We protect Personal Information against loss, theft, and unauthorized access, disclosure, copying, use, or modification with security safeguards appropriate to the sensitivity of the Personal Information. We protect Personal Information regardless of the format in which it is held.
At QuadReal, we comply with industry practices and employ reasonable security procedures to protect Personal Information in our custody and control. These include, but are not limited to, the following safeguards:
- Technical Safeguards: We employ reasonable technical safeguards, such as passwords, encryption, clear screen policy, the use of closed networks, and role-based access controls, for information systems from which Personal Information may be accessed.
- Physical Safeguards: We employ reasonable physical safeguards to protect Personal Information, such as by locking filing cabinets and by restricting physical access to offices and data centres.
We also protect the Personal Information we destroy and dispose of in order to prevent unauthorized parties from gaining access to the information during this process.
Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. If you have any reason to believe that your resident portal account, transaction or information is no longer secure, you should contact us immediately (see the “How to Contact QuadReal” section below.)
Currently, QuadReal retains all Personal Information it collects or receives on secure servers located in Canada.
The management of your Personal Information by our business partners is governed by the privacy policies of those businesses and is not the responsibility of QuadReal. Please contact these businesses directly for information about their respective data management practices.
We make reasonable efforts to ensure that Personal Information we use or disclose is as accurate, complete, and up-to-date as is necessary for the specified purpose.
Some Personal Information can be modified or corrected by you if you log in to your resident portal account to make such changes. You may also contact us should your information (e.g. address, vehicle ownership information) change (see “How to Contact QuadReal” section below).
Upon written request, we will inform you of the existence, uses, and disclosures of your Personal Information and give you access to that information, except where we are restricted from doing so by law. You should make clear in your request what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of the information you have provided to us.
You can request access to your Personal Information in our custody or control by contacting our Privacy Officer (see “How to Contact QuadReal” section below). If we are unable to provide access to all of the Personal Information that we hold about you, we will provide the reasons for denying access to you.
You will be required to provide sufficient information so that we can confirm your identity and process your request. We only use the information provided to accurately locate your Personal Information.
We will respond to all requests for access to information within 30 business days from the receipt of request and at minimal or no cost to you. In the case where there is a cost associated with processing the request, we will notify you in advance. You may then choose to withdraw your request.
If you find that the information provided to you is inaccurate or incomplete, you may contact our Privacy Officer (see “How to Contact QuadReal” section below) and we will amend this information, as appropriate.
When appropriate, we will also transmit the amended information to the organizations to which we originally shared the information so that the information is correct and complete within the organizations’ records.
If we determine that it is inappropriate to amend your information, we will note this within our records.
Please note that we may need to retain certain information for recordkeeping or legal compliance purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
HOW TO CONTACT QUADREAL
If you have any questions or concerns about your privacy or relating to the collection, use or disclosure of Personal Information by QuadReal, please contact:
The Chief Privacy Compliance Officer (CPCO)
4900 – 199 Bay Street, P.O. Box 373, Toronto, ON M5L 1G2
Phone: (416) 673-7588