Skip to main content
Enable accessibility for
visually impaired
Open the accessibility
menu
Legal
Last Updated:
05.05.2021

ACCEPTANCE OF PRIVACY POLICY

_

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

Privacy Policy

Bay Park Centre Limited Partnership (“CIBC SQUARE”) welcomes you to our property, website, mobile application 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 by CIBC SQUARE from or about Building occupants, guests, tenants, services providers or business partners (hereinafter “users”).The Privacy Policy is a statement of principles, guidelines and practices concerning the protection of personal information and of the choices you can make about the way your information is collected by CIBC SQUARE and how that information is used and/or shared. Our website and our web and mobile-app based tenant engagement platform are also governed by the Tenant Engagement Platform Terms and Conditions Of Use, and the use of Wi-Fi is governed by the Wi-Fi Terms and Conditions Of Use.  These documents can be accessed through the tenant engagement platform, the property website, the mobile app or Wi-Fi portal. A summary of provisions related specific 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, for example, your name, contact information, home address, telephone number, email-address, information relating to your inquiry with us, any complaints documented in a file or other personal or demographic information. It may also include other types of more technical information such as online/users’ IP addresses, user IDs, browser history (pages accessed, date of access, location when accessed), but only when this information can identify you as an individual.


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 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:


  • GUESTS
    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.
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 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:

  • GUESTS
    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;
  • TENANTS
    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;

Subject to our users’ Right to Withdraw Consent provided in this Privacy Policy, 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 or to provide you with offers for additional products and services that we feel may be of interest to you. For more details on the type of commercial electronic messages that you may receive from us, please refer to section Electronic Communications and Notifications of this Privacy Policy. Unless required or authorized by law, CIBC SQUARE will not collect or use personal information for any other or new purpose without obtaining further consent.

Your Consent

In general, by interacting and/or doing business with us, visiting our properties, subscribing to our newsletter to and/or submitting information to us in connection with using CIBC SQUARE services, visiting, interacting with and/or using our websites, mobile apps and/or Wi-Fi, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy and in the CIBC SQUARE Website and Mobile app Terms and Conditions Of Use (and/or the Wi-Fi Terms and Conditions of Use, as the case may be).


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.

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 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
    When visiting or using our websites and/or mobile apps, you can always 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 withhold consent, 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-on’s settings or visiting the website of its manufacturer.
Sharing of Personal Information

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
    Subject to our users’ Right to Withdraw Consent provided in this Privacy Policy, CIBC SQUARE may share personal information with its affiliates, subsidiaries and retailers (which may include our tenants) from our properties for purposes related to marketing the services offered by CIBC SQUARE, its affiliates, subsidiaries and such retailers, at all times in compliance with applicable privacy laws.
  • 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.

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 security and privacy limitations of the Internet which are beyond the control of CIBC SQUARE; (ii) the security, integrity and privacy of any and all information and data exchanged between you and CIBC SQUARE through our websites and mobile apps or when using our Wi-Fi cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party. Because of that we cannot ensure or warrant 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 as set out in our Privacy Policy, we may contact you by e-mail, letter, telephone or through other secure form of communication.

Retention of Personal Information

We have personal information retention processes designed to help ensure that we retain personal information of our users for no longer than as reasonably necessary for the purposes stated in this Privacy Policy or to otherwise meet our legal requirements.

Location, Storage, and Cross-Border Transfer

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.

Children

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.

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 websites have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to 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 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 means including, but not limited to, posting on our websites and our mobile apps, or by any other means by which you obtain notice thereof. If the changes are significant, we will provide a more prominent notice. Your continued use of our services, websites, mobile apps and/or Wi-Fi after such modifications will constitute your acknowledgement of the modified Privacy Policy and agreement to abide and be bound by the modified Privacy Policy.

Last Update: February 26, 2021

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.