This policy statement (the “Policy”) sets out the privacy policies and practices for Concert Properties Ltd. and our affiliated companies (collectively, the “Sites”) with respect to the collection, use and disclosure of personal information. This policy may be updated by Concert Properties giving reasonable notice of the revised Policy (including by email or by posting at Concert Properties website at ConcertProperties.com) and this Policy may be supplemented or modified by agreements entered into between Concert Properties and an individual from time to time. Your use of the Sites is governed by the Terms of Use & Disclaimer.
1. Privacy Officer
The Privacy Officer is responsible for ensuring Concert Properties' compliance with this Policy.
Privacy Officer
8th Floor, 1190 Hornby Street
Vancouver, BC
Canada, V6Z 2K5
Tel: 604.688.9460
2. Collection, Use and Disclosure Purposes
We interpret the term “Personal Information” in accordance with applicable laws as referring to information that may be used to identify, contact or locate a specific person. We do not rent, sell, or share personal information about you with other people or non-affiliated companies except where otherwise required or permitted by law. We will inform individuals of the purposes for the collection, use or disclosure of the individual’s personal information, prior to collecting, using or disclosing that personal information. Concert Properties is not responsible for the privacy practices of other sites. We encourage you to read the privacy policy of websites operated by third parties. This Privacy Policy applies solely to information collected through the Sites.
We collect the following types of personal information:
- Contact information, such as your name, telephone, email address and mailing address.
- Other personal information, such as information that you provide or that we generate as part of our marketing, sales or leasing activities. This information may include financial, spousal and dependent, beneficiary, residency and other information relevant to residential leases as well as purchase and sale agreements.
- Background check information such as credit checks, criminal records checks, economic and other sanctions checks, credential checks and other background information.
- Communications, such as the content of your emails, voicemails and other communications with us.
- Communication preferences and interests, such as when you subscribe to receive our newsletters, updates or other materials.
- Feedback, such as when you fill out surveys or feedback forms.
- For security reasons, we may also utilize video surveillance to monitor our premises from time to time.
We use information collected from customers and potential customers to provide services required for rental apartments and condominiums, seniors' active aging communities industrial and commercial properties as well as public infrastructure. This may also include responding to requests for information regarding Concert Properties, for input on preferred features for future developments, mailing contacts for Concert Properties publications and newsletters, special event marketing and other marketing research activities, and for additional purposes that may be identified at or before the time that the information is collected.
We use personal information from purchasers for accounting, transaction completion or compliance purposes. We may disclose personal information to legal, financial and other professional advisors or in connection with the sale or reorganization of all or part of our business or operations. We also use personal information for recruitment activities such as processing your application for employment. We do not disclose personal information to third-parties other than service providers who process personal information on our behalf, or as may be required by applicable law.
We automatically receive and record information on our server logs, which information may include your computer’s IP address and “cookie” information. A cookie is a small text file that is stored on your computer. The only information a cookie can collect is information supplied by you. A cookie cannot read data off of your computer. If you have set your browser to warn you before accepting cookies you will receive the warning message with each cookie. You may configure your internet browser software to disable cookies though your ability to access some web pages may be affected.
3. Limits to the Collection of Personal Information
Except where required or permitted by law, we will limit the collection of personal information to that which is necessary to fulfill the purposes for which it is collected. Personal information will be collected by fair and lawful means.
4. Use, Consent and Retention
We will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Concert Properties will keep your information for as long as is reasonably necessary for the purposes set out in this Policy, and to fulfil our legal and regulatory obligations. Once the information is no longer required to fulfill its intended purposes and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed, erased, or made anonymous.
There may be several reasons why we might collect, use, share or otherwise handle your personal information. These include:
- With your explicit or implicit consent, such as when you provide the personal information as part of a request for services, when you provide the personal information for a specific purpose, or we ask you to consent to our use of your personal information for a purpose or for the purposes set out in this Policy.
- With the consent of someone with authority to provide the information to us, such as your employer or a third party who you provided the information and who has the legal right to share it with us.
- Where is necessary to fulfill our legal obligations, such as where we need to conduct anti-money laundering checks, or for other legal and compliance purposes where the law permits.
- For the purposes of responding to legal claims against us.
- To conduct investigations where the law permits us to handle personal information without your consent.
We may use your business contact information to contact you in your business, role, function or occupation without your consent. If we send you commercial electronic messages, we will comply with Canada’s Anti-Spam Legislation, subject to any exceptions permitting us to send unsolicited commercial electronic messages. You may unsubscribe from our communications at any time.
You have the right to ask us to cease collecting, using or sharing your personal information in some cases. We will do so if we have no further purpose for handling your personal information. You can unsubscribe from any of our electronic marketing communications using the unsubscribe links provided. You may communicate other requests to withdraw consent from Concert Properties personnel who are assisting you or you may make a request to the Privacy Officer.
5. Accuracy
We will make reasonable efforts to ensure that any personal information collected by Concert Properties, or on our behalf, is accurate and complete if the personal information is likely to be used to make a decision that affects the individual to whom the personal information relates or if the information is likely to be disclosed to a third party.
6. Security
The security of personal information is extremely important to Concert Properties, and therefore have measures in place to ensure it stays safe, is not damaged, destroyed or misused, and prevents unauthorized access. The nature of these safeguards will vary depending on the sensitivity of the personal information that has been collected. The measures include, but are not limited to:
- Client information in systems and storage – Concert Properties' systems and storage have reasonable physical and technical measures and protections in place that align with industry best practices to protect personal information against loss or theft, unauthorized access, use or disclosure. Concert Properties works with our service providers to ensure that if they or their service providers require access to your information in order to perform necessary services, they also protect, use and disclose your personal information in accordance with applicable laws.
We inform employees about Concert Properties policies and procedures for protecting personal information and employees will be required to conform to Concert Properties Privacy Policy. Privacy training is provided to all employees and workers who need access to and process personal information.
7. Openness
Upon request, we will make information available about our personal information policies and practices, and our complaint process.
8. Individual Access, Corrections & Complaints
Canadian privacy laws provide you with certain rights. Please see the top of the Policy for the contact information of our Privacy Officer to exercise these rights.
- Access rights – You have the right to ask us if we have collected information about you and to obtain access to that information. If you wish to exercise this right, please send a written request to our Privacy Officer. We will ask you for information to confirm your identity and may ask you to assist us in describing your relationship with us so that we can locate the relevant personal information. Please note that we may withhold disclosure of personal information in certain cases under applicable laws.
- Correction – You have the right to ask us to correct any incomplete or inaccurate personal information we hold about you. If we disagree with your correction request, we will insert a note in our files explaining the basis of our refusal to correct the information. We recommend that you raise any issue with incorrect, incomplete or inaccurate personal information with the Concert Properties personnel who are assisting you. However, you may also make a request to the Privacy Officer.
- Complaints – You have the right to make a complaint to our Privacy Officer about our compliance with this Policy or applicable privacy laws. We encourage you to raise your concern with the Concert Properties personnel who are assisting you. However, if you make your complaint to the Privacy Office, we will investigate the matter and report to you about the investigation findings.
9. Challenging Compliance
An individual may direct a complaint concerning compliance with the Policy to the Privacy Officer. The complaint must be in writing. Within a reasonable time of receipt of the complaint, the Privacy Officer will investigate the complaint. The format of this investigation will vary depending on the circumstances and may or may not involve an interview of the complainant and/or Concert Properties employees conduct by the Privacy Officer.
Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, that the complaint is either: (a) denied (if, in the Privacy Officer’s opinion, it has no merit): or (b) allowed (if, in the Privacy Officer’s opinion, the complaint is valid).
If the Privacy Officer allows the complaint, Concert Properties will take appropriate measure necessary to rectify the source of the complaint.
10. Changes to the Privacy Policy
We may update this Privacy Policy from time to time. It is your responsibility to periodically review this Privacy Policy to remain informed of the current privacy practices of Concert Properties.
Privacy Policy Last Updated: 2024/10/02