POLICY RELATING TO THE PROTECTION OF PERSONAL INFORMATION
Effective date: September 22, 2023
1. Scope and application
This Policy applies whenever you interact with us or submit information to us in connection with the use of our services through our website, by e-mail, in person, by telephone or by any other means, including when you visit our buildings, visit our website or submit an online application from the site, apply to become a tenant or enter into an agreement with us, receive our services, or otherwise interact with us. In all these contexts, you thereby give your consent to the collection, use and disclosure of your personal information as more fully defined in this Policy.
This Policy does not apply to any third party web sites or services that may be accessed through links on our web sites and Beauward is not responsible for such third party sites or services. If you follow a link to a third party website, that third party will have its own privacy policies which you should review before submitting any personal information.
2. What is personal information?
Personal information” is any information that identifies or could reasonably be associated with an individual (“Individual” or “You”). Examples include your name, contact information, e-mail address and account information (as applicable). It may also include other, more technical types of information, but only where such information identifies you as an Individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered personal information.
3. What personal information do we collect?
We collect personal information in a variety of ways as further detailed in the section How we collect personal information. The personal information we collect may include:
- Identifiers and contact information, such as your name, e-mail and postal addresses, and telephone number;
- Transactional information, such as rental payment history or fees for services rendered;
- Information provided in connection with our promotions or contests, including all information listed herein;
- Payment information, such as bank account or credit card information;
- The information we need to process your rental application, including, in addition to the other types of information listed in this document, information relating to credit, financial situation and other information obtained as part of background checks;
- The information we need to process your job applications, including, in addition to the other types of information listed in this document, information relating to your employment history, your academic history and all information obtained and relevant in the course of your approaching us for a job offer;
- Audiovisual information, collected through our video surveillance on our premises, for security purposes and to prevent damage to our property;
- Browsing activities on our website, such as pages and offers viewed, opt-out preferences, email returns, clicks, social media content and IP addresses, if such information identifies you as an individual ;
- Geolocation information may be collected when you use our website, although this information may not identify you as an individual; and
- Any other information you provide to us.
4. How do we collect personal information?
We collect personal information in a variety of ways, including directly from you, through online technologies for example, when you interact with us through our website, platform, job application and third-party social networks. We may also collect information about you from other third parties such as credit bureaus or background check companies, but only with your consent or as permitted or required by applicable law.
5. How do we use personal information?
We may use all the categories of personal information detailed in the section What personal information do we collect? to :
- provide you with our services, for example, to verify your identity, process your transactions, respond to your requests or verify your instructions, create, administer and maintain your accounts, and with your consent, check your credit and other information obtained as part of background checks where such checks are required;
- to manage our business operations, for example, to notify you of changes to our services, terms and conditions or policies and to communicate administrative messages, legal or technical notices or security alerts; to manage our information technology systems, including our website; and to manage and maintain our properties and services;
- to communicate to you surveys, offers and information that we believe may be of interest to you. Please note that you may unsubscribe from our promotional communications at any time;
- to carry out research and analysis, for example, to understand and analyze your use of our properties; to manage, develop and improve our business, properties and services; to understand customer preferences, needs and interests, and tailor our marketing, website and services; and to evaluate the effectiveness of our marketing;
- for employment purposes such as hiring new personnel and processing employment applications;
- as permitted or required by applicable law, including, where necessary or appropriate, to : comply with legal process and law enforcement requests; respond to requests from public and governmental authorities; to enforce our terms and conditions; comply with our contractual, legal and regulatory obligations; protect our business or that of any of our affiliates ; to protect the rights, interests, privacy, safety or property of Beauward, you or others, including against error and fraud; and to enable us to investigate incidents, administer claims, pursue available remedies or limit damages we may sustain as permitted or required by law; and
- for other purposes with your implied or express consent, in accordance with applicable laws.
Wherever possible, we will use your information in aggregate and/or de-identified form..
6. How do we share your personal information?
No personal information about our users will be sold or otherwise transferred to unrelated third parties without the user’s consent. However, Beauward may disclose personal information where permitted by law or to its entities, subsidiaries and retailers (including, without limitation, our tenants) occupying our buildings and for purposes related to service providers retained to perform work on our behalf as well as in connection with a business transaction such as, for example, the merger or sale of Beauward.
If you submit a job application, we may also share your personal information with the retailer who is a tenant in one of our buildings and to whom the application is addressed.
Specifically, Beauward may share or disclose personal information as follows:
- within the Beauward group, including all its subsidiaries, affiliates and business partners, to enable each group entity to comply with applicable laws, regulations and requirements and to ensure that your information is consistent, accurate and up-to-date, for the purpose of promoting the services offered by the Company, its affiliates and subsidiaries, and for the purposes described in this Policy;
- with our third-party service providers who provide services such as web hosting, payment processing, infrastructure provision, IT services, customer service, e-mail delivery services, payment processing, audit services and other services, to enable them to provide these services;
- in connection with the sale of our business or other transaction, or in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock (including in connection with bankruptcy or similar proceedings). In such circumstances, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this policy. We do not sell or rent your personal information to unaffiliated third parties, except as permitted by law;
- as permitted or required by applicable law, including, where necessary or appropriate, to: comply with legal process and law enforcement requests; respond to requests from public and governmental authorities; enforce our terms and conditions; comply with our contractual, legal and regulatory obligations; protect our business or the business of any of our affiliates; to protect the rights, interests, privacy, safety or property of Beauward, you or others, including against error and fraud; and to enable us to investigate incidents, administer claims, exercise remedies available to us or limit damages we may sustain as permitted or required by law;
- in connection with the hiring of employees within Beauward, its subsidiaries and affiliates for employment and employment verification purposes; and
- with your implied or express consent, in accordance with applicable laws.
7. How do we protect and manage personal information?
We use administrative, physical and technical measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, taking into account, among other things, the sensitivity of the information and the purposes for which it is to be used. These measures include policies and practices governing the retention and destruction of personal information; the roles and responsibilities of personnel throughout the information life cycle; and a procedure for handling complaints about the protection of information. Our safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored.
You acknowledge, however, that there are security and privacy limitations beyond Beauward’s control; that the security, integrity and privacy of any information or data, in whole or in part, exchanged between you and Beauward through the Website or any other intermediary means cannot be guaranteed; and that such information or data may be viewed or tampered with by a third party.
In the event of a security incident involving your personal information, we may contact you by e-mail, mail, telephone or other secure means to notify you in accordance with applicable laws.
Please be aware that Beauward has a process and timeframes for retaining personal information to ensure that we keep our users’ personal information in secure locations and only for as long as is reasonably necessary for the purposes set out in this Policy to meet our legal obligations.
8. Cross-border transfers
We and some of our service providers may access, process or store your personal information outside the jurisdiction where we are located and where you reside. As a result, when your personal information is used or retained in a jurisdiction other than the one in which you reside, it may be subject to the law of that foreign jurisdiction, including any law authorizing or requiring disclosure of the information to the government, government agencies, courts and law enforcement authorities of that jurisdiction.
9. Quels sont vos choix en matière de communications promotionnelles?
Ceux qui ne veulent pas faire partie des efforts futurs de marketing de la Beauward ni recevoir de matériel promotionnel doivent en aviser l’administrateur du site par la poste à Beauward Immobilier Inc., à la responsable de la protection des renseignements personnels Nathalie Parent par courrier au 6010-430, boul. Arthur-Sauvé, Saint-Eustache, Québec, J7R 6V7 ou encore par courriel à firstname.lastname@example.org.
Nonobstant le désir des utilisateurs de ne plus participer aux efforts futurs de marketing ni recevoir de matériel promotionnel, Beauward se réserve le droit de faire des analyses statistiques en utilisant les données recueillies à l’aide du site web sur une base anonyme et cumulative dans le but de mesurer l’intérêt pour le site web et son utilisation.
11. What are your privacy rights?
You have the right to request access to or correction of your personal information in our custody or control.
To do so, or if you have any questions or complaints about this Policy or our privacy practices, please contact our Privacy Officer as set out in the How to Contact Us section. Your right to access or correct your personal information is subject to applicable legal restrictions. Upon request, we will provide you with access to your personal information as soon as reasonably possible in accordance with applicable laws. We may take reasonable steps to verify your identity before granting access or making corrections.
If you have consented to the collection, use and/or disclosure of personal information as set out in this document, please note that you may also withdraw your consent at any time by contacting our Privacy Officer as set out in How to contact us.
Please note that we may retain certain information to the extent required by law and applicable professional orders, as well as for archival purposes and/or to complete any transaction you have initiated prior to requesting modification or deletion.
12. Changes to our Policy
We may make changes to this Policy from time to time. Any changes we make will be effective when we post an amended version of the Policy on our website. If the changes we make are material, we will highlight them when required by applicable law. Your continued participation in our programs and/or use of our services or purchase of our products after the revised Policy has been posted or after you have been notified of such update constitutes your acceptance of the revised Policy. If you do not accept the changes to our Policy, it is your responsibility to stop using our services. It is your responsibility to ensure that you have read, understood and accepted the latest version of the Policy. The “Effective Date” at the top of this Policy indicates the date it was last updated.
13. How can you contact us?
If you have any questions about how we handle your personal information, please contact our Privacy Officer Nathalie Parent by mail at 6010-430, boul. Saint-Eustache, Quebec, J7R 6V7 or by e-mail at email@example.com.