INFORMATION COLLECTED FROM OR ABOUT YOU
In many cases, we collect personal information directly from you when you visit our premises, rent our premises or use our services, websites, mobile apps and/or Wi-Fi. 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 and/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 type of information when you are interacting with us, for instance when you make an inquiry or contact us in person or through our websites, when you register to receive our newsletter, when you enter a contest or promotion, when you use our website or Wi-Fi (if you chose to provide your information). When you use our guest services desks, payment information may also be collected, although your credit card will not be stored on our systems.
- OCCUPANTS OF THE BUILDING
We may collect your name, contact, information, e-mail address and other similar type of information when you are interacting with us, as referenced above, or when you download and/or use our tenant engagement platforms. When you use our chat services, we will also collect your messaging content.
- 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, and in certain circumstances, personal information collected in the context of a background check (such as employment records, credit records and criminal records) from our suppliers or business partners.
CIBC SQUARE collects personal information for general business related purposes such as to help prevent fraud, unauthorized activities, claims and other liabilities and to ensure the security of our properties. We may also use personal information to authenticate the identity of individuals contacting us by telephone, electronic means or otherwise, for internal training and quality assurance, and purpose to manage our business and ensure the efficiency, reliability and security of our systems and networks. We may also collect personal information for the following purposes:
We collect personal information from guests to provide you with the information requested or to contact you in order to answer your questions, requests or inquiries, to administer the contest or promotion which you have entered, or to send you our newsletter if you have registered to receive a newsletter through one of our websites or our mobile apps, or if we have your implied consent to send you such communications. If you visit our websites, use our mobile apps and/or Wi-Fi, we will use the technical information collected to measure, to monitor traffic to the websites and/or the mobile apps and improve the effectiveness of our websites and/or apps or enhance the experience for our guest. Moreover, we may use the 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;
We collect personal information from tenants to evaluate their creditworthiness, evaluate and process applications for tenancy, prepare leases and to 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 method, for insurance, security and risk management purposes, and generally speaking, to establish, manage and terminate our business relationship;
- SUPPLIERS AND OTHER BUSINESS PARTNERS
We collect personal information from suppliers and other business partners to evaluate and select them, to initiate orders, process payments, maintain our business relationship, to establish and maintain responsible business relations with clients and partners, to provide ongoing service and manage risk;
EXCEPTIONS TO CONSENT REQUIREMENT
In certain circumstances, your personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- where it is clearly in the interest of the individual and consent cannot be obtained in a timely way, such as in emergencies, where the life, health or safety of the individual is threatened, or where legal, medical or security reasons make it impossible or impractical to obtain consent;
- when information is being collected, used or shared for the detection, prevention of or remediation to, 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 by any regulatory bodies having jurisdiction.
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 is able to provide you and/or CIBC SQUARE may be prevented from entering into a business relationship, maintaining such relationship and/or interacting with you. You may also withdraw your consent as follows:
- E-MAIL 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 to share your information with our affiliates, subsidiaries and retailers from our properties and refuse that we contact you by email for marketing purposes or by email 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 always limit the commercial electronic communications that CIBC SQUARE sends to you. To opt-out of commercial communications, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still contact you when authorized by law, for instance with important information about our services, building information such as notices on fire-drills, your information or account.
- CHOICE WITH COOKIES
Personal information about our users will not be sold or otherwise transferred to unaffiliated third parties without your approval, except CIBC SQUARE reserves the right to disclose personal information when authorized by law or as follows:
- AFFILIATES AND BUSINESS PARTNERS
- THIRD-PARTY SERVICE PROVIDERS
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 CIBC SQUARE 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. They are prohibited from using the information for purposes other than to facilitate and carry 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
From time to time, 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 if CIBC SQUARE is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation, other legally valid request or enquiry 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.
In connection with your use of the [Services], we may collect your personal information and store it 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 disclose, use, store or otherwise process your personal information outside of Canada. To the extent we disclose your personal information outside of Canada, your personal information may be accessible by foreign law enforcement, regulatory bodies or other authorities. For more information about our practices and policies regarding the collection, disclosure or use of your personal information to or by foreign service providers, please contact us as described below.
CIBC SQUARE recognizes the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. Our services (including our websites, mobile apps and/or Wi-Fi) are not aimed at nor 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 websites, mobile apps and/or Wi-Fi), 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 websites, mobile apps and/or Wi-Fi) only with the involvement and permission of a parent or legal guardian. No personal information is purposefully or knowingly collected from children under the age of thirteen (13) by CIBC SQUARE without parental consent.
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.