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Privacy Policy.

INTRODUCTION

At SmartCentres (“us”, “we”, “our” or the “Company”) we value your privacy and the importance of safeguarding your data. This Privacy Policy (“Privacy Policy”) describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals.  In this Policy, “Personal Data” refers to any information that on its own, or in combination with other available information, can distinguish an individual, or any information with a high risk of harm that is linked directly to an individual (eg financial, medical, government).

As a Real Estate Investment Trust, SmartCentres properties can be found across Canada. SmartCentres’ home and regional offices can be found here.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), the EU’s General Protection Data Regulation (GDPR), and the applicable provincial legislations.

SCOPE

This policy applies to all SmartCentres websites, services, and properties.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non SmartCentres) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any personal data that you provide to these websites will be governed by the third-party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

PROCESSING ACTIVITIES

This Privacy Policy applies when you interact with us by doing any of the following:

  • Sign on with SmartCentres as a tenant, vendor, supplier, or associate
  • Visit any of our websites that link to this Privacy Statement
  • Visit any of our branded social media pages
  • Visit our physical offices
  • Attend any of our branded or sponsored events
  • Receive any communication from us including newsletters, emails, calls, or texts
  • Register for, attend and/or take part in our events, webinars, or contests
  • Visit physical retail or residential properties

PERSONAL DATA WE COLLECT

DATA YOU PROVIDE

We operate retail, office, industrial and residential properties.

As such we may collect personal data from our tenants including:

  • Contact information such as your name, company, email address, and phone number
  • Payment information such as your billing address, credit card, debit card or other payment method
  • Demographic Data including age, gender
  • Government Identifiers such as driver’s license numbers, SSN, passport numbers
  • Video captured on security cameras in public locations

For residential properties, we collect additional personal data from our tenants and their guests including:

  • Financial Information including credit card numbers and/or banking information
  • Location Data – tenants 

Note that we do not request, gather, or store the following information:

  • Mobile device specific identifiers such as make and model, IMEI and phone number
  • Biometrics such as finger prints, face scans, voice prints

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contacting us” section below.

DEVICE AND USAGE DATA

When you visit a SmartCentres website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

DATA WE COLLECT FROM THIRD PARTIES

We may receive your personal data from third parties such as companies subscribing to SmartCentres services, partners and other sources. This information is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your personal data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your personal data. Where that third party is unresponsive to your rights, you may contact the Data Privacy Officer at SmartCentres (contact details below) and we can assist you.

Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.

PURPOSE AND LEGAL BASIS FOR PROCESSING OF PERSONAL DATA

We collect and use personal data about you with your consent to provide, maintain, and develop our products and services and understand how to improve them.

These purposes include:

  • ·      Providing, Developing, and Improving our Products and Services 
    • Register both retail and residential tenants
    • Manage tenancy including rental agreements and lease payments
    • Enable you to access SmartCentres services and set up accounts on our Commercial Tenant Portal.
  • Building a Safe and Secure Environment
    • To Verify or authenticate your identity; and
    • Investigate and prevent security incidents such as breaches, attacks and hacks.
  • Provide you with technical and customer support.
  • ·      Organize and Deliver Advertising and Marketing
    • Aggregate your information in an anonymized form to generate usage statistics
    • Send you newsletters and other marketing communications about current and future products, programs and services, events, competitions, surveys and promotions held by us or hosted on our behalf; and
    • Organize events or register attendees and schedule meetings for events.

Where we process your personal data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services per your request and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.

INTERNATIONAL DATA TRANSFER AND STORAGE

We store and process all sensitive data on servers in Canada.  We will take appropriate steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy as well as applicable data protection law. For any EU members, Canada is considered to have adequacy with government protection standards and does not require additional transfer contracts to be signed.

SHARING AND DISCLOSURE

We will share your personal data with third parties only in the ways set out in this Policy or set out at the point when the personal data is collected. We consider your personal data to be a vital part of our relationship with you. We do not sell your personal data to third parties, including to third-party advertisers.

We also use Google Analytics to help us understand how our customers use the site. You can read more about how Google uses your Personal Information here:  ttps://www.google.com/intl/en/policies/privacy/.  

You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

LEGAL REQUIREMENT

We may use or disclose your personal data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

SERVICE PROVIDERS AND OTHER THIRD PARTIES

We my use a third party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your personal data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section below.

DATA AGGREGATION AND ANALYTICS

We may collate your personal data you provide to us or we collect and use it anonymously for analytics, benchmarking, and to effectively monitor our service and improve your user experience.

MERGER OR ACQUISITION

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred but will continue to be governed by the contract relationship you have with us.

Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

SECURITY

We are constantly deploying and updating our technical and organizational security measures to protect against loss, misuse or alteration of personal data that we have collected or received from a third party.

To the extent permitted by law, SmartCentres may review, scan or analyze communications for fraud prevention, investigation, regulatory compliance, risk assessment, research, product development, and customer support purposes.

We use industry-standard encryption technologies when transferring and receiving personal data, and network access control technology to limit access to the systems on which personal data is stored, and we monitor for possible vulnerabilities and attacks.

If you become aware that there has been a breach in security of any of the personal data that we store or that is stored by our third-party service providers, please contact us via the instructions provided in the Contact Us section.

RETENTION AND DELETION

We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent required by applicable law. When we no longer need personal data, we will remove it from our systems and / or take steps to anonymize it.

CHILDREN’S PRIVACY

We will not knowingly collect personal data from children under the age of 16 years.

YOUR RIGHTS FOR YOUR PERSONAL DATA

Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:

Right to Access (GDPR Article 15, PIPEDA)

You have the right to request a copy of the personal data we are processing about you.

Right to Rectification (GDPR Article 16, PIPEDA)

You have the right to have incomplete or inaccurate personal data that we process about you rectified.

Right to be Forgotten (right to erasure) (GDPR Article 17, Bill 64 – Quebec)

You have the right to request that we delete personal data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

WITHDRAWING CONSENT

If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to opt out from marketing messages that you receive from us.  If you wish to withdraw your consent, please contact us at [email protected].

HOW TO EXERCISE YOUR RIGHTS

You can make a request to exercise any of these rights in relation to your personal data by sending the request by mail to Data Privacy Officer of SmartCentres, 3200 Highway 7, Vaughan, ON L4K 5Z5 or email to [email protected]. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.

CHANGES

We may modify this Policy at any time. If we make changes to this Policy then we will post an updated version of this Policy on our website at https://smartcentres.com/privacy/. When using our services, you will be asked to review and accept our Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

CONTACT US

To contact us, please email to [email protected] or write to us at:

Data Privacy Officer of SmartCentres

3200 Highway 7
Vaughan, ON L4K 5Z5

COMPLAINTS

If you have a complaint about this Policy or any element of your personal information that we hold then please contact us at the above address. If you are not satisfied, then you have the right to lodge a complaint with the local data protection authority.

Last Updated: June 2023.

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