POLICY FOR THE PROTECTION OF PERSONAL INFORMATION

POLICY FOR THE PROTECTION OF PERSONAL INFORMATION


PREAMBLE

Cominar Real Estate Investment Trust, its subsidiaries and affiliates (hereinafter referred to as “Cominar” or “We” or “Us”) would like to explain its personal information management practices. This Policy for the Protection of Personal Information (hereinafter referred to as the “Policy”) sets out the principles that guide the way we collect, use and disclose personal information on our Websites, our various social network accounts, and the different technologies installed or used in our establishments.



DEFINITIONS

“Consent Notice”     means a notice issued by Cominar to a Customer so that the Customer can provide valid consent to an upcoming Collection of Information.  

                                 

“Customer” or “You” means an individual who (i) uses any of Cominar’s services; (ii) visits Cominar’s establishments; (iii) corresponds in any way with Cominar; (iv) participates in a Cominar survey, draw, contest or a promotion; (v) is a member of a Cominar program, including loyalty, an email list or a newsletter; (vi) uses a Cominar Website or an application; (vii) uses a Wi-Fi or wireless service provided by Cominar; (viii) buys or uses a Cominar gift card; or (viii) accesses, uses or buys any other service provided by Cominar.


Collect”                  means the action of collecting, acquiring or obtaining Information in any way and by any means whatsoever, including from Third Parties.


Consent”                 means an explicit or implied agreement to Collect, Use and/or Disclose Information for the purposes determined by Cominar. Consent may be given directly by the Customer or their authorized representative. Explicit Consent may be given verbally, electronically or in writing. Implied Consent means that it can be reasonably deduced from a person’s actions or omissions.


Disclosure”             means the action of providing Information to a Third Party.


Information”          means any personal information about an individual that enables them to be identified.


Privacy Officer”     means the person mentioned in Section 10 of this Policy.


“Website(s)”            means Cominar’s Websites, including www.cominar.com, Cominar’s establishments’ Websites, Cominar or its establishments’ social network accounts (including FacebookInstagramTwitterLinkedIn, etc.) and any of Cominar or its establishments’ mobile applications, if applicable.


Third Party”           means a person other than a Customer, Cominar or their representatives.


INFORMATION COLLECTION

Type of Information Collected


We collect only customer information that is necessary for our business, including their names, phone numbers, civic address, email address, date of birth, gender, interests, geographical location, details of a request or a complaint, Information allowing us carry out a transaction, log-in ID, password, the Customer’s profile information when the settings allow us access, any posts about us on social networks or any media available to the public, and the IP address.


Collection Methods


Cominar may collect Information by traditional or technological means. We will respect your privacy at all times and use only lawful means of collecting Information. Here are some examples of the methods Cominar uses to collect information: through program registration, through surveys or competitions organized by Cominar, through your connection to our facilities’ Wi-Fi networks, from the information provided in a complaint sent to Cominar, from information displayed on your social network public profiles, as well as information collected by cookies when you visit our Websites.  

 

Collection By Third Parties


In some cases, Third Parties may collect Information about you in order to provide it to us. Depending on the circumstances, you may be required to consent to this exchange of Information.


INFORMATION DISCLOSURE

 

We may share your Information with a Third Party or authorize a Third Party to collect it as part of a mandate we have given to them. When this situation occurs, we will first seek your consent. Here are some examples:


To display advertising about products or services

We may authorize Third Parties to collect Information about our Website visitors in order to categorize them into different market segments, and display advertisements relevant to each of these segments on our Websites or in our establishments. This practice is called "online behavioural advertising".


To collect Information about the use of our Websites and services

We can authorize certain service providers to use the Information collected on our Websites and services to help us better understand our audience and to understand how our Websites are used.


To link your activity on our Websites to your social networks

Our Websites may contain functionalities enabling social networks (including FacebookTwitterLinkedInInstagram and Google+) to track their members’ activities and collect certain Information about their Website’s visitors. These features may use “plug-ins” and “widgets”Plug-ins establish a direct link between two Websites, and widgets are interactive mini-programs that provide other companies’ services on our Websites.


CONSENT

Consent Prior to Collection

The Collection of Information may be automatic or subject to your consent. The consent required might vary depending on the type of Information, the identity of the person who will use the Information, or the intended use of that Information.


We use a simple formula to solicit a Customer’s consent to collect their Information.


When we collect Information other than your name, phone number, civic address or email address to share it with a Third Party, we will seek your express, free and informed consent. The consent thus obtained must qualify as obvious, certain and indisputable, in addition to being given without restriction. We will properly inform you of the scope of your consent, that is, you will be told who will receive the Information and how your Information will be used. Implied consent meeting these requirements will be considered valid. Thus, certain actions will be considered as an implied consent to share Information with a Third Party as long as the Customer has been presented with this Policy and a Notice of Consent.


In other situations involving the collection of Information, it will be collected automatically and you will have the opportunity to agree or refuse that this Information be used for advertising purposes or communicated to a third party for these purposes. This option could take the form of a check box, for example.


Refusal to Consent

When a Customer refuses to consent to the Collection of Information, we will try to provide them with the same services as if they had consented. 


However, some programs and technologies require collected Information in order to work properly. Thus, it is possible that a Customer’s refusal to consent to the Collection of Information may result in a poorer or less personalized quality of service. Sometimes services cannot be provided. 


Advertising


You can unsubscribe from an advertising subscription at any time by clicking on the "Unsubscribe" link provided in the advertising emails we send you, if applicable.


You may also refuse to receive advertising by contacting the Privacy Officer, by email or by post mail, at the address provided in section 10 entitled "How to Contact Us".


USE OF INFORMATION COLLECTED

General

Information collected by Cominar helps us to achieve the following objectives: to improve the Customer experience as well as to promote and/or sell products, services and philanthropic causes. 


Here is a detailed list of how Cominar may use your information: 


-    To personalize our establishments, our Websites and our applications to the Customers’ preferences

-    To improve the performance of our Websites, our applications and the Wi-Fi access provided to Customers of our establishments 

-    To efficiently ensure our establishments’ security/safety

-    To distribute information bulletins

-    To distribute invitations 

-    To answer requests for Information 

-    To conduct surveys

-    To compile statistics defining our Customers and their preferences 

-    To conduct market studies 

-    To orient our investments 

-    To investigate complaints 

-    To define each establishment’s customer make-up 

-    To provide services and partnerships tailored to our Customers’ needs and preferences 

-    To enable our Websites and applications to remember our Customers’ usernames and passwords 

-    To distribute discounts

-    To manage the gift card program

-    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   

-    Any other use to which the Customer expressly agrees


STOCKAGE DES RENSEIGNEMENTS ET SÉCURITÉ

We protect your Information by deploying technical, physical and administrative security measures to reduce the risk of loss and misuse, or unauthorized access, disclosure or modification of such Information. 


Access

Access to Information held by Cominar is restricted to those employees whose duties require the use of this Information, and only to those subcontractors whose mandate or performance of a contract makes it necessary to use the Information. 


Hosting

We may use Canadian companies to securely process or store your Information. These specialized companies deploy Security measures such as secure servers and firewalls.  



USE BY MINORS

Our Websites and other services are not intended for use by persons under 14 years of age. If you are a parent or guardian and believe that we have collected Information about a child under the age of 14, contact the Privacy Officer at the contact information listed in section 10 "How to Contact Us" below.

  

MODIFICATION OF THE POLICY

This Policy is effective as of the date listed at the top of the Policy. Our Policy may be updated from time to time. We advise you to consult it frequently.


RIGHT TO ACCESS, MODIFY OR REMOVE YOUR INFORMATION

In accordance with the Personal Information Protection and Electronic Documents Act and with similar provincial legislation, you have a right of access to Information about you in some circumstances. Any request to access, modify or remove your Information must be made in writing and sent to us at the email or mailing address indicated in Section 10, “How to Contact Us” below.A request for access may be subject to a fee to cover the costs to disclose Information we hold about you.

HOW TO CONTACT US

If you have any questions or a request about this Policy, please communicate with the Privacy Officer by email or by post mail at the following address:


Att.: Privacy Officer
Cominar Real Estate Investment Trust
2820 Laurier Boulevard
Suite 850
Quebec (Quebec)  G1V 0C1

Fax: (418) 681-2946
legal@cominar.com


If you would like to access your 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.

Last updated: November 1, 2018