What is personal information
Personal information is any information about an identifiable individual. This could include information such as name, contact details, date of birth, bank account details or any similar information which would allow you to be identified.
In general, personal information does not include business contact information, including your name, title or position, business, business address, email address, phone or facsimile number.
Personal data that is de-identified or aggregated or cannot be associated with an identifiable individual is not considered to be personal information. We reserve the right to conduct statistical analyses through the use of personal information or data, including the data collected from individuals who enter our properties, through our websites, mobile apps and Wi-Fi on an anonymous or aggregated basis in order to understand users’ interests, improve our services and measure interest in and use of our properties, websites and mobile apps. We also reserve the right to provide our analyses based on such anonymous or aggregated data to third parties.
Information we collect, why we collect it, and how we use it
Lancaro collects personal information for general business-related purposes such as to develop our business interests, 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 to manage our business and ensure the efficiency, reliability and security of our properties, systems and networks.
We may collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.
In addition, if you wish to enter into a business or contractual relationship with us, including, without limitation, as a tenant, investor, broker or other service provider, we will collect information relating to your identity, and we may require at least one form of photographic identification (such as a passport, a driver’s licence or a government-issued identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill). We will also collect information to help us ascertain your creditworthiness and financial status, including but not limited to banking information, credit report and history, your liabilities and net worth.
If we are dealing with an entity such as a company, trust or charity, we may need to obtain personal information for the beneficiaries of the entity and those in a position of control, including but not limited to, their identity and address, as well as any information mentioned in the preceding paragraph.
We may also need to collect information on other individuals with whom we do not have a direct business relationship, such as, by way of example only, a tenant’s employee who is also a “key holder”, or a tenant’s or broker’s advisors, contractors and service providers.
We may also collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements.
Here are some specific examples of information we collect and the purpose and use of such information:
Sharing your personal information
We will never sell your personal information. However, we may disclose your personal information when authorized by law or as follows:
We may hire service providers, which may be affiliates, to provide services to us or to perform services on our behalf. This may include, without limitation, lawyers, finance and accounting professionals, architects, engineers, project managers, property managers, security contractors, lenders and financial institutions, brokers and a range of other professionals, service providers and contractors. 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.
From time to time, Lancaro 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 Lancaro 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 service providers, in an emergency or where required or permitted by law.
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.
If you complete and submit an employment application (including an online application found on our websites), you hereby consent to the disclosure of your completed on-line employment application to: (a) Lancaro personnel and contractors; and to (b) the retailer who is a tenant of our properties and to whom such application is being made.
Only those Lancaro employees, 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 of your personal information
Retention of your personal information
Location, storage and cross-border transfer of your personal information
Your personal information is stored in secured locations and on servers controlled by Lancaro or its service providers (such as Microsoft), located either at our facilities or at the facilities of our service providers. Lancaro and its third-party service providers may process or store your personal information outside of Canada. In accordance with the laws of those countries, in certain circumstances, 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 use of foreign service providers, please contact us as described below.
Privacy of children
Lancaro 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 Lancaro without parental consent.
Updating your information
At your request, we will use reasonable efforts to allow you to update or correct personal information which you state is incorrect to the extent that the information has been maintained by Lancaro and if so, that such update or correction will not compromise Lancaro’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 remaining on backups.
Your consent to the collection, storage and sharing of your personal information
In certain circumstances, your personal information may be collected, used or disclosed without consent. These circumstances may include:
Your consent to receiving electronic communications and notifications
You agree to receive the following type of electronic communications and notifications from Lancaro:
You may receive electronic notifications for various purposes including to facilitate or confirm a transaction such as your subscription to our services, to provide you with information about your ongoing use of our services or your ongoing subscription or accounts, to inform you of any incident regarding the security of your information or in order to enforce a legal right or obligation.
You may receive commercial electronic messages (CEMs) from Lancaro if we have your express or implied consent to send you CEMs. We may infer your implied consent if: (i) we have an existing business relationship with you or had a business relationship with you which terminated less than two years ago (for instance, you have purchased our services, you have entered into a lease with us, you have registered to use our Wi-Fi, you have accessed our website, etc.); (ii) we have received an inquiry from you within the last 6 months; and/or (iii) you have provided your electronic address to us and the CEM we sent complies with the Canadian Anti-Spam Legislation.
You may withdraw your consent at any time, subject to legal or contractual restrictions (for example, your consent may not be withdrawn during the term of a lease) and reasonable notice; however, without such consent, we reserve the right to limit or even terminate the services we provide you, or we may decline to enter into a business relationship, maintain such relationship or interact with you.
You may also withdraw your consent regarding mail marketing, telephone marketing and quality control communications. You may decide that you prefer Lancaro not to use your personal information to promote new or additional products and 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 mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by emailing us at email@example.com (please be sure to include “PRIVACY” in the subject line of your email).
Unless you are in a contractual relationship with us, you can always limit the commercial electronic communications that we send to you. To opt out of commercial communications, simply click the “unsubscribe” or “opt-out” link 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, your information or account.
How to contact us
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