This Privacy Policy reflects Lancaro’s commitment to protecting your privacy.  For the purposes hereof, “Lancaro”, “our”, “us” and “we” each mean Lancaro Inc., its subsidiaries and affiliates, the partnerships we invest in under the name Lancaro, as well as Axeum Inc. (who provides us with a suite of strategic, development, management and administrative services) which collect and use your information in the manner set out in this Privacy Policy. Any reference to “you”, “your” or “users” refers to anyone whose personal information we process.

This Privacy Policy covers:

  1. What personal information is;
  2. The personal information we collect, why we collect it, and how we use it;
  3. How we share your personal information;
  4. The security of your personal information;
  5. Retention of your personal information;
  6. Location and storage of your personal information, including cross-border storage;
  7. The privacy of children;
  8. How to update your information;
  9. Third-party websites;
  10. Your consent to the collection and sharing of personal information;
  11. Your consent to commercial communications and notifications;
  12. How to contact us;
  13. Changes to this Policy.

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:

  1. Guests: We may collect your name, contact information, email 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 websites or Wi-Fi (if you chose to provide your information) or when you download or use our mobile apps or any of our applications. When you use our chat services, we will also collect your messaging content.
  2. Tenants, as individuals: We may collect our tenants’ names, addresses, telephone numbers (office, home, cell), email addresses, credit reports, government issued identification, social insurance number, banking information, insurance policy numbers and other insurance information, access card photographs and swipe data, surveillance data, as well as information about any dispute between a consumer and a merchant. 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. We may also use tenants’ personal information for emergency, security or incident reporting, for insurance, security and risk management purposes, and generally speaking, to establish, manage and terminate our business relationship.
  3. Investors, as individuals: We may collect our investors’ names, addresses, telephone numbers (office, home, cell), email addresses, employment information, credit reports, government issued identification, social insurance number, banking information, and net worth information. We collect personal information from investors to evaluate their creditworthiness, determine their investor status and if they qualify as accredited investors, process applications for investment, prepare relevant documentation, to provide investors with relevant information, and generally speaking, to establish, manage and terminate our business relationship with investors.
  4. Suppliers and other business partners, as individuals. We may collect the names, addresses, 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) of our suppliers or 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, establish and maintain responsible business relations with clients and partners, provide ongoing service and manage risks.
  5. Employment candidates: We may collect the information which you have included in your resume when you submit a job application or when you apply for employment with us, including personal information collected in the context of a background check (such as employment records, credit records and criminal records). We collect personal information from applicants for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Lancaro and related entities, as well as other career development resources.
  6. Vehicle Information: If you park on one of our properties, we may collect information about your vehicle (including serial number or VIN and license plate information) for the purposes of managing our parking facilities, providing parking services, and enforcing our parking regulations.
  7. Information Collected Automatically: In some cases, we may collect information automatically which may or may not necessarily identify you as an individual. For instance, we may collect the following type of information:
  8. Video surveillance: As a security measure and in order to ensure the safety of our guests, tenants, and anyone using our properties, we may use video surveillance at various locations inside and outside our properties. Images captured through video surveillance may be shared outside of Lancaro in limited circumstances, such as with security contractors, law enforcement, governmental authorities or as may be required by law or a court order.
  9. Browser, Device and Technical Information: When you visit our websites, use our mobile apps or Wi-Fi, we may collect technical information using electronic means such as cookies. This may include information about your visit or usage, including the IP address of your device and which browser you used to access our websites, mobile apps or Wi-Fi, your operating system, screen resolution, location, browser language, the site you came from, keywords searched (if arriving from a search engine), the number of page views, as well as information you entered and advertisements you have seen. We may also collect your gender, age group and interests, but such information will be aggregated and not associated with any identifiable individual.
  10. Traffic, Anonymous Video Analytics and Device Count: In some cases, we may use cameras and other technologies in our properties to conduct anonymous video analytics (“AVA”) and anonymous traffic analysis. This allows us to track the number of individuals in our properties but does not allow us to identify any guests. We may use statistical data about traffic in our properties to help us manage our properties, including choosing the most appropriate tenants, and we may share this statistical information with our business partners, including our tenants.
  11. SMS and Webchat: When you use our chat services, we may collect meta data, such as your mobile phone number, email address and date time stamps, linked to your interactions. We may also gather certain information automatically from electronic communications with you and store it in log files. This information may include IP addresses as well as browser, internet service provider, referring/exit pages, operating system, date & time stamp and click stream data.
  12. Social Media: If you sign into one of our websites, mobile apps or Wi-Fi using a social media account, we will collect information that you have added in your registration profile from those accounts and which is made available to us by default by social media companies.

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

Lancaro maintains reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information we collect. Unfortunately, no collection, transmission, storage or retrieval of information can be entirely secure, especially when it involves electronic means, including over the Internet or other publicly accessible communications networks. You acknowledge and accept that: (i) there are security and privacy limitations which are beyond our control; (ii) the security, integrity and privacy of any and all information and data exchanged between you and Lancaro is not guaranteed; and (iii) any such information and data may be viewed or tampered with by an unauthorized 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 Lancaro as set out in our Privacy Policy, we may contact you by e-mail, letter, telephone or through other form of communication.

Retention of your 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 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.

Privacy policy of third parties

This Privacy Policy only addresses the use and disclosure of information by Lancaro. 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.

Your consent to the collection, storage and sharing of your personal information

In general, by interacting or doing business with us, visiting our properties, subscribing to our newsletter or other form of communication, visiting, interacting with, or using our websites, mobile apps 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 our Website  Terms Of Use(or the Wi-Fi Terms Of Use, as the case may be).

In certain circumstances, your personal information may be collected, used or disclosed without consent. These circumstances may include:

  1. 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;
  2. 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
  3. 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.

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 (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.

When visiting or using our websites or mobile apps, you can manage 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 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.

How to contact us

If you have any questions about this Privacy Policy or the privacy practices of Lancaro in respect of how we collect, use and share your personal information, please contact us at (please be sure to include “PRIVACY” in the subject line of your email) or by mail at: Privacy – Lancaro, 3301 Peak Drive, Whistler BC  V8E 0V4.

Changes to privacy policy

We reserve 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. Your continued use of our properties, 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.