Online Privacy Statement
GWL Realty Advisors Inc. (“GWLRA”, “we”, “us” or “our”) is committed to respecting your privacy and the confidentiality of information we receive in accordance with this Online Privacy Statement, and with applicable law.
The Online Privacy Statement applies to GWLRA websites, mobile applications and other online and digital offerings (such as tenant mobile applications, digital tools and portals) that link to or otherwise incorporate by reference this Online Privacy Statement, including the VC Complex App (the “Online Services”). It explains how we collect, use and disclose your personal information when you use Online Services. Our Online Services may provide you with additional information about privacy when certain features enable you to enter personal information or ask to use your personal information. Please review this information before using those features.
Personal Information is information about an identifiable individual.
Your Consent
By using Online Services, you acknowledge that you have read and understand this Online Privacy Statement and consent to the collection, use and disclosure of your personal information as described herein. This Statement may be changed without notice to you, so we recommend you review it regularly.
The statement supplements our Social Media Guideline, Privacy Guidelines and any other terms or agreements that may apply to your relationship with us.
Privacy and Confidentiality
We have safeguards in place to protect the security and confidentiality of your personal information. However, the Internet is not a secure place where privacy and confidentiality can be guaranteed. Your confidential use of Online Services can’t be guaranteed, and you acknowledge that your use of the Online Services may be subject to access or manipulation by, or disclosure to, third parties. GWLRA is not responsible or liable for any damages that you or any other person may suffer in connection with any such violation of privacy, confidentiality or security.
Collection & Use of Personal Information
Certain Online Services may require or ask you to provide personal information or may otherwise involve the collection of personal information. The personal information that is collected will depend on the features and functionality of the Online Services that you use but may include the following:
- Registration information. For Online Services requiring you to register, we may ask you to provide your name, employer name and location, business telephone number and business email address. We will match this information with information collected from your employer to verify your eligibility for the Online Services. We will also ask you to create a username and password. For certain types of services, we may request your mobile number (for example, to send you verification codes). We use the information we collect to confirm your identity when registering for or logging in to the Online Services. We also use this information to provide you with the Online Services you request, provide technical support, respond to your requests, inquiries or complaints, and to provide you with information relating to the Online Services (such as notification of updates to the Online Services terms of use).
- Information collected through building systems. We may also collect personal information though building systems that are connected to the Online Services such as surveillance cameras, people counting systems, access card systems, room, elevator or amenity booking systems, and heating, cooling and lighting systems. This information may include your photograph (for example, your pass card photograph), date, time and location where pass card was used, video footage from surveillance cameras, the location, date, time and duration of a room, elevator or amenity booking, and your preferred temperature and lighting settings. If you book a meeting, we may collect the email addresses of meeting attendees in order to send them an invitation.
- Information about your use of Online Services. We collect information about your use of the Online Services you choose to use, including date and time of access, duration of use, actions performed, features used, and whether you click on links to third party services accessible through the Online Services. We use this information to provide the Online Services. We may also use this information to generate aggregate statistics to perform analytics and to help us improve the Online Services. For example, we may use this information to understand which Online Services are most popular, or to provide information to users about when a particular amenity is booked or likely to be busy so they can plan their use of amenities accordingly.
- Location information. Certain Online Services offer location based functionality, such as wayfinders, maps and access card and elevator booking systems. In order to use these services, we will collect information about your location or the location of your device. You may be asked to enter this information manually, or to allow your device to share this information with us.
- Calendar and contacts. We may offer Online Services that allow you to integrate your calendar or address book with the Online Service (for example, to facilitate meeting room amenity bookings and invitations). If you choose to use these integrations we may collect information from your calendar or address book in order to provide the Online Services.
- Purchases. If you choose to make a payment through the Online Services you will be asked to provide your payment card information and billing information in order to process the transaction. Payment card information is processed by our third-party service provider and is not retained by us.
- Work Orders. If you submit a work order through the Online Services, we will use the information you provide in order to process and communicate with you in respect of your work order. In certain circumstances you may also be asked to provide a signature.
- User submissions. The Online Services may include features that allow you to post or share content with other users. Please note that any information or images you post or share in these areas are publicly available and may be accessible to anyone. We cannot control what others do with this content. As such, you should not use these features to share personal information and should exercise caution and good judgement when posting content through these features.
- Communications. We use the personal information we collect to communicate with you in respect of the Online Services, including by email, in-app notifications or push notifications. If you email or otherwise communicate with us through the Online Services, we will use the personal information you choose to provide to reply to you.
- Forgotten User Name or Password: If you forget either your user name or password, you may be able to recover them by going through the Forgotten User Name or Password feature, where available. To confirm your identity, we may match what you enter against the information collected during your registration.
- Feedback, surveys, contests and promotions. From time to time, we may ask for feedback about our Online Services or other services or offer sweepstakes or other promotions. The Online Services may also include features that allow you to provide us with feedback or make complaints. If you choose to provide us with your comments, complaints, suggestions or feedback, or participate in our sweepstakes or promotions, we will use the personal information you provide to improve our Online Services and other services, respond to your concerns and administer the sweepstakes or promotions.
- Marketing: With your consent, we may use your personal information to send you information about GWLRA and its affiliates, including information about products, services, offers and events. We may also occasionally run promotions or other campaigns. If you choose to participate, we will collect and use your personal information to administer the promotion or campaign.
In addition to the uses described above, we may also use the personal information we collect for the purposes described in our Privacy Guidelines.
Personal Information Sharing
Our Online Services are made available to our commercial tenants and their workers. We may share information with our commercial tenants about how their workers are using and interacting with our Online Services. In most cases the information that we share with our commercial tenants will be aggregate (e.g., number of workers who have installed or used a workplace mobile application). However, in some circumstances we may share identifiable information. For example, we may share access card information with a tenant in the event of a security incident, to monitor compliance with and enforce workplace policies or government orders, or in situations relating to health, safety or security of persons or property. We may exchange personal information with tenants in order to administer a user’s access to, or termination from, Online Services. If you submit feedback or a complaint through the VC Complex App that is more appropriately handled by our commercial tenant, we will share your information with the tenant so they can address your concerns.
Some of our Online Services may involve sharing personal information with other users. For example, as a convenience to users, we may provide a live video feed of certain public spaces to allow tenants to select an appropriate time to use the space. We may also offer community pages or features that allow users to share information with each other. You should not share any sensitive personal information through these community pages or features.
We use service providers to perform certain functions or provide or support certain Online Services on our behalf, such as software services, data hosting and processing, analytics, payment processing, technical and customer support and similar services. These service providers will access, store and process personal information as necessary to perform these services on our behalf.
We may also share anonymized or aggregated data with third parties, including our service providers and affiliates.
In addition to the above, we may also share your personal information as described in our Privacy Guidelines.
E-mail security
The security of email communication can't be guaranteed. Sensitive information (including personal information such as your Social Insurance Number or birthdate) should not be sent to us by email. If you wish to communicate or send private or confidential information to us or to a third party, you may do so by other means.
Information Collected Automatically
We use cookies and other technologies, such as web beacons, to collect information automatically when you use our Online Services. “Cookies” are small items of data that websites store in your browser. These data files contain information the website can use to track and organize the pages you have visited, remember your preferences and settings, and to gather information. Some of our web-based applications use “cookie” technology to measure website activity and tailor information to fit your personal interests. GWLRA uses both “session” and “persistent” cookies, both of which help us deliver a superior website experience that is designed to be fast, secure and personalized. You can accept or decline cookies through our cookie consent tool or through your browser settings or other tools as described below, but if you decline all cookies, this may lead to reduced website functionality. Web beacons are also referred to as "pixel tags." They are embedded in a web page and are not usually visible to you. Web beacons are used for many of the same purposes as cookies. They allow us or agents acting on our behalf to gather aggregate statistics about website usage patterns, including how many times a link or a page on a website is visited.
The type of data being collected
GWLRA and our service providers gather data through the use of cookies and similar technologies when you interact with our websites, apps and other Online Services. The data we collect includes IP address, device ID or other unique identifiers, Internet service provider name, device model, browser type, device parameters, information about how visitors explore our Online Services and about the number of new and repeat visitors, the pages they visited on our website, the date and time of their visits, the length of the visits, the referral URL, and information about the device and browser used and other similar details.
With whom the data is shared
We use third party web analytics tools on our Online Services, including our website and mobile applications (Google Analytics and Adobe Analytics). We also use third party advertising tools provided to us by advertising partners like Google, Facebook, LinkedIn and Twitter. Advertising pixel tags on our website are deployed through Adobe Tag Manager.
These third parties use cookies and similar technologies to collect and analyze information about your online activity on our Online Services or in reaction to online advertisements.
The information collected by these online tracking tools may be combined with your personal information if you have entered your access ID and password or provided it to us through your persistent cookie.
Your choices
You can use our cookie consent tool to choose whether to allow cookies and similar tools to collect your information. You can also turn off personalized ads in the settings of Facebook, LinkedIn, or Twitter, turn off cookies through your browser settings (see How to Block Cookies below), or opt out of targeted advertising through industry tools such as the Digital Advertising Alliance of Canada’s website.
How to Block Cookies
You can change your browser settings to block cookies from being stored on your computer or mobile device. The ‘help’ menu of your browser should provide information on how to manage your cookie settings.
To block cookies when using the browsers on your mobile device, refer to the procedure for turning cookies on or off in the Chrome and Safari apps. Please be aware, however, that blocking cookies may prevent some pages on our website or some parts of our application from displaying correctly, and some features may not be available.
Links to other Websites or services
Some of our Online Services contain links to third party websites, apps, mobile apps or digital platforms or services (“Third Party Services”), or allow you to interact with Third Party Services, that are not managed, maintained or controlled in any way by GWLRA. We don’t control and are not responsible for any of these Third Party Services or their content, and as a result such links or features are not to be viewed as an endorsement, by GWLRA or any other party, of the products, services, advice or opinions or any other content of such services. These features and links to services that aren’t maintained or controlled by GWLRA are provided for convenience only.
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Revised September 2023