Last update: June 2023
Cominar Real Estate Investment Trust, its subsidiaries and affiliates (hereinafter referred to as "Cominar" or "We" or “Us”) outlines below its practices with respect to the management of Personal Information collected on Cominar's web sites or platforms, social media accounts (including but not limited to Facebook, Instagram, Twitter, and LinkedIn) or any mobile applications, if any (the "Site(s)").
"User" or "You" means an individual who (i) uses our Site; (ii) corresponds in any way with Cominar; (iii) participates in a Cominar survey, contest or promotion; (iv) is a member of a Cominar program, including loyalty, an email list or a newsletter; or (v) accesses, uses or buys any other service offered by Cominar.
"Collection" means the action of collecting, acquiring or obtaining Information in any way and by any means whatsoever, including from third parties.
"Disclosure" means the act of revealing Personal Information to a third party.
"Personal Information" means any personal information that relates to a natural person and allows that person to be identified.
"Privacy Officer" means the person referred to in section 10 of this Policy.
2. COLLECTION OF INFORMATION
Type of Personal Information collected
In order to provide our services, we have to collect certain Personal Information regarding a user which allow to identify him. Unless permitted by law or consented by yourself, we collect only the Personal Information that is necessary for our business, such as your name, telephone number, email address, postal code and language preference for communication purposes.
Means used for Collection
Cominar may collect information by traditional or technological means. We respect your privacy at all times and use only lawful means to collect your Personal Information.
In order to use certain features of our Site, we may ask you to provide Personal Information. We only collect Personal Information that is necessary to provide you with our various services. Wherever possible, we indicate which fields are required and which are optional.
If you use the contact features, such as "Contact", "Inquire Now" or "Maintenance Request" on our Site, we may collect your name, email address, telephone number, and other relevant information about your request. We use this information to respond to your enquiry or comments. If you send us emails or letters, we may collect Personal Information in a file about you.
If you subscribe to a mailing list, we will collect your name and email address to send you emails about various news and promotions. Even after you have subscribed to one or more newsletters and/or accepted one or more offers to receive marketing and/or promotional communications from us, you may choose to change your preferences by following the "Unsubscribe" link provided at the end of the email or communication received.
If you apply for a job through the “Career” section of the Site, we may collect the following personal information regarding your job application:
With your consent, these Personal Information can be used to communicate with you regarding other job opportunities similar to the one you applied.
When you visit our Site, we may collect information about your visit through cookies and similar tracking technologies.
Please note that if you purchase gift cards or make purchases on our Site, Cominar does not collect any information regarding your credit card. Those information are treated independently by third party service provider.
Unless permitted or required by applicable laws or regulations or unless we have your consent, we will retain your Personal Information only as long as necessary to fulfill the purposes for which it was collected, including legal, accounting or auditing requirements. Furthermore, Cominar does not sell your Personal Information to any third parties.
3. DISCLOSURE OF PERSONAL INFORMATION
Cominar will only disclose your Personal Information with your consent or if it is legally authorized to do so, including in the following situations:
By continuing to browse our Site and submitting Personal Information to us through the means listed above, you consent to the Collection, use and Disclosure of your Personal Information in accordance with this Policy.
Refusal to consent
Where a User refuses to consent to the Collection of Personal Information, we endeavour to provide the same services as if they had consented.
However, certain features and services of the Site require the Collection of Personal Information in order to function properly. Thus, it is possible that a User's refusal to consent to the Collection of Personal Information may result in a poorer quality service or a less efficient and/or adapted service. In some cases, services may not be rendered. If you do not consent to the collect of Personal Information or retreat it subsequently, there may have an impact on the rendered services.
You can unsubscribe from an advertising subscription at any time by clicking on the "Unsubscribe" link in any advertising email we send you.
You may also opt-out of receiving advertising by contacting the Privacy Officer by email or mail at the address provided in section 10 "Contact Us" below.
Cookies and other tracking technologies
5. USE OF THE INFORMATION COLLECTED
The information collected by Cominar allows us to achieve the following objectives: improve the user experience and promote and/or sell products and services.
The following is a list of the different uses of such information by Cominar:
• To personalize our establishments, our Site and our applications to Users’ preferences;
• To improve the performance of our Site and our applications provided to Customers;
• To distribute information bulletins;
• To distribute invitations;
• To answer requests for information;
• To conduct surveys;
• To compile statistics defining our typical User and their preferences;
• To conduct market studies;
• To provide services and partnerships tailored to our Customers’ needs and preferences;
• To advertise promotions and programs;
• To perform targeted advertising;
• To prevent fraud;
• Any other required use to achieve the objectives mentioned in the first paragraph of this section;
• Any other use to which the Customer expressly agrees.
Personal Information are kept until the finality of the collection is reached. Once the finality is reached, the Personal Information are destroyed or anonymized for subsequent use in conformity of the law.
If you would like to access your Personal Information, please submit your request in writing to the Privacy Officer at the address indicated above and by presenting satisfactory proof of identity and proof of your right of access, as well as details about the kind of information you seek. We will respond to such requests within the time prescribed by law, or in the absence of a prescribed time, within a reasonable time as soon as all this request’s relevant documents are received.