Privacy Policy

Updated July 20, 2016

Welcome

The Cadillac Fairview Corporation Limited welcomes you to our properties, websites and mobile applications. As a guest, service provider or client (which includes retailers and occupants of our properties), we want you to understand our personal information management practices. In this Privacy Policy, you will find information about the principles that guide us in how we collect, use and disclose personal information through our websites, mobile applications and technologies installed on or used in our properties, and your choices regarding the use of your personal information.

Overview

We collect personal information that you provide to us as well as information on how you use our websites, mobile applications, WIFI, and other products and services. We use this information for the purposes of providing services, securing our properties, websites and mobile applications, meeting our legal obligations, advertising and marketing our services and, in some cases, the products and services of our clients (including developing interest-based advertising using information about your interests, your use of our websites, mobile applications, WIFI, products and services, and your visits to our properties). We also use this information for researching and developing new products and techniques to improve our services, business, our properties, websites, and mobile applications.

We use third parties to assist us in our business. Some of our third party service providers and partners use cookies, beacons and other technologies to track users to deliver interest-based advertising and to learn how you use our websites and mobile applications.  CF participates in the Adobe Marketing Cloud Co-op.  Participants use the Adobe Marketing Cloud Co-op to create and share device identifiers so that they can link different devices that you use to access their websites and mobile applications.  The only information that is shared by participants is the fact that you are linked to two or more devices and the identifiers for those devices.  We do not share other information about you.  To learn more, to manage your devices or to opt-out, please visit https://cross-device-privacy.adobe.com.

We take measures, and we require our service providers to take measures, to protect your personal information; however, no system of protection can guarantee the protection of your personal information.

We may share the results of our research with others, including our clients. However, we do not disclose your personal information except (a) with your express or implied  consent (for example, so that you can receive offers from our clients) and (b) where permitted or required by law to disclose your personal information without your consent. If we sell all or part of our business, your personal information may be disclosed in the course of deciding to enter into that sale and as part of the sale.

We hope that you find this Privacy Policy informative. Please check back frequently for updates. Your visits to our properties and your use of our websites and mobile applications will be subject to the most current version of the Privacy Policy at the time of your visit or use.

Getting Help

• If you have any questions about this Privacy Policy, please contact us by email or in writing to cfprivacy@cadillacfairview.com   
  

          Chief Privacy Officer
          The Cadillac Fairview Corporation Limited
          20 Queen Street West
          Suite 500
          Toronto, ON M5H 3R4
          Email: cfprivacy@cadillacfairview.com
          Fax: (416) 598-8222

• If you have a question regarding our mobile applications, gift cards, marketing or customer-related issues, please send your request to cfshop@cadillacfairview.com.

Quick Links to More Information

Use these links to quickly find what you are looking for:

Our Statement of the Privacy Principles that Guide Us

Quick Answers to Your Questions

• What does this Privacy Policy cover?
• What do you mean by “personal information”?
• What types of personal information do you collect and use?
• Do you customize promotional offers and other benefits for me?
• Do you use cookies, web beacons, ibeacons and other similar technologies?
• What choices do I have?
• Where do you store and process my “personal information”?
• Is my personal information secure?
• Do you sell, rent or share my personal information with other companies?
• How can I get help?
• Do you cooperate with law enforcement?

Our Privacy Principles

Cadillac Fairview is committed to protecting the privacy of our guests, service providers, clients (which include retailers and occupants of our properties) and others with whom we do business. These are the Privacy Principles that we use to manage the personal information that we collect, use, retain and disclose. To help you understand how we apply these Privacy Principles, we have included links to “Quick Answers to Your Questions.”

  1.  Accountability

We have appointed a Chief Privacy Officer who is responsible for our compliance with privacy legislation. See “How can I get help?” for more information.

We manage personal information in accordance with applicable privacy legislation in the jurisdictions in which we carry on business. In Canada, we abide by the principles of Canada’s Personal Information Protection and Electronic Documents Act and the substantially similar provincial legislation of Canada.

In this policy, “personal information” means any information, either factual or subjective, about an identifiable individual. Personal information does not include the name, title, business address or telephone number of an employee of an organization. For more information, see “What do you mean by “personal information”?”

  2.  Identifying Purposes

We collect personal information that is relevant for the purposes of providing services to our guests, service providers and clients (which includes retailers and occupants of our properties); securing our properties, websites and mobile applications; meeting our legal obligations; promoting, advertising and marketing our services and, in some cases, the products and services of our clients; and researching and developing new products and techniques to improve our services, business, our properties, websites, and mobile applications.

We identify the purposes for which we collect personal information at or before the time the information is collected, unless that purpose is implied by the context.

For more information, see “What do you mean by “personal information?”, “What types of personal information do you collect and use?”, “Do you customize promotional offers and other benefits for me?” and “Do you use cookies, web beacons, ibeacons and other similar technologies?”

  3.  Consent

Generally, we obtain your consent to the collection, use or disclosure of personal information at or prior to the time of collection. However, we may collect, use or disclose personal information without your knowledge or consent in certain circumstances that are permitted or required by law. For example, we may disclose personal information in response to a court order, subpoena or warrant, in connection with legal proceedings to enforce our rights, or in connection with an emergency involving a person’s life, health or security. See “Do you cooperate with law enforcement?” for more information.

Consent may be expressed in writing or implied, and in some cases, it may be provided verbally, electronically, or through an authorized representative, provided such representative has the appropriate written authorization to do so.

You may withdraw your consent to the further use of your personal information at any time, subject to any legal or contractual restrictions, and upon reasonable notice to us.

We also provide you with choices regarding some of our uses of your personal information. See “What choices do I have?” for more information.

  4.  Limiting Collection

We collect information that is necessary to provide you with products and services, business innovation, and to meet our legal and contractual obligations. See “What types of personal information do you collect and use?” for more information.

  5.  Limiting Use, Disclosure and Retention

We do not sell personal information to third parties, except as part of the sale of all or part of our business or a property.

We may employ third parties to process personal information or perform tasks on our behalf. We seek assurances to ensure the personal information is similarly protected by these third parties.

We have established guidelines and put procedures in place for the appropriate retention and destruction of personal information. See “Where do you store and process my “personal information”?” for more information.

  6.  Accuracy

Any updated personal information provided by you will help to ensure that we are using accurate and up-to-date information when we provide you with products and services. See “How can I get help?” for information on how to contact us.

  7.  Safeguards

We use safeguards and security measures to protect personal information. Paper records are physically secured and access is limited to authorized personnel who are trained and aware of the requirements of our privacy practices. We also protect electronic records by limiting access to authorized personnel and using electronic security devices. See “Is my personal information secure?” for more information.

8.  Openness

• Our Privacy Policy is available to anyone upon request. Individuals are invited to contact our Chief Privacy Officer directly if they have any questions, concerns or Our Privacy Policy is available to anyone upon request. Individuals are invited to contact our Chief Privacy Officer directly if they have any questions, concerns or complaints about privacy. Such requests should be sent by email or in writing to the following address: cfprivacy@cadillacfairview.com             

              Chief Privacy Officer
              The Cadillac Fairview Corporation Limited
              20 Queen Street West
              Suite 500
              Toronto, ON M5H 3R4
              Email: cfprivacy@cadillacfairview.com
              Fax: (416) 598-8222

•     If you have a question regarding our mobile applications, gift cards, marketing or customer-related issues, please contact cfshop@cadillacfairview.com.

  9.  Individual Access

If you require access to your personal information please first check any account profiles that you have with us. If you are unable to locate the information you require access to, please make your request in writing to the Chief Privacy Officer at the address provided above and include satisfactory identification and proof of entitlement as well as details regarding the type of information you are seeking. We will respond to such requests within the time period prescribed by law.

If your personal information is inaccurate or incomplete, we will make the appropriate amendments, based on the receipt of satisfactory evidence.

In certain circumstances, we may be unable to provide access to personal information. Exceptions may include: information that contains references to other individuals or contains confidential commercial information if such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege. See “How can I get help?” for more information.

 10.  Challenging Compliance

We review all complaints and respond within the time period prescribed by law. If a complaint is found to be justified, we will take prompt and appropriate measures. In the unlikely event that a complaint cannot be resolved satisfactorily, the complainant will be advised of further complaint procedures that may be available to them. See “How can I get help?” for more information.

Quick Answers to Your Questions

Here are some quick answers to questions you may have about how we manage your personal information. If you would like to learn more about our guiding principles, you can access them under the heading “Our Privacy Principles”.

What does this Privacy Policy cover?

This Privacy Policy governs the collection, use and disclosure of personal information by us during the course of our business activities, such as:

• our corporate website: cadillacfairview.com;
• our individual property-specific websites on which this Privacy Policy appears;
• our individual properties;
• our mobile applications cfshop.ca;
• our contests; and
• our electronic communications with you (such as email, text/SMS, and push notifications).

What do you mean by “personal information”?

Personal information is information that is about you as an identifiable individual. It usually does not include your business contact information.

In some cases, we may collect information about our interactions with you without knowing who you are or being able to identify you. For example, we may count the number of individuals who enter our properties or monitor foot traffic patterns within our properties. This will not be personal information unless you have specifically identified yourself to us and provided consent.

What types of personal information do you collect and use?

We collect information that is relevant for the purpose of providing services to our visitors, customers and clients, securing our properties, WIFI services, websites and mobile applications, meeting our legal obligations, advertising and marketing our services and, in some cases, the products and services of our clients (which includes retailers and occupants of our properties), and researching and developing new products and techniques to improve our services, business, our properties, websites, and mobile applications. Examples of some of the personal information that we collect and use are:

• Requests. If you communicate with us to request customer assistance or services, we will collect information that is necessary to respond to your request. This may include contact information, details of your request and our response.
• Registration Information. If you register for email communications, we will collect your email address. If you enter a contest or promotion, we will collect personal information from you to administer the contest or promotion. When you create an account with us, including through our mobile applications, you provide us with registration information (this may include your name, email address, and password). If you sign into our websites, mobile applications or WIFI using a social media account such as Facebook or Twitter, we will collect information that you have added in your registration profile from those accounts. We use this information to process your registration request and to authenticate you. We may also use this information to personalize our products and services for you.
• Location Information and Video Cameras. Our properties are equipped with video surveillance cameras for security purposes. We use location-based information to understand how our premises are used, and to provide you with location-based offers. Some of our properties are also equipped with technologies such as ibeacons (sensors) and cameras that we use to monitor foot traffic patterns and may that may assist us in predicting demographic information about our visitors during your visit to our properties. In addition, if you are logged into one of our mobile applications, we will receive location data about your device from GPS-enabled devices and from third-party telecommunications services.
• Your Customized Content. If you use our mobile applications or other services to create customized shopping lists, create “wish lists” and take photos of products, we will collect this information to store it with your account and to learn about your preferences so that we can provide you with future offers and promotions.
• Social Media. We may collect information through social media when you post information that mentions us, our services or one of our properties or is tagged with the location of one of our properties. We only collect this information if your privacy settings permit us to see your post. We use this information to understand what our visitors, customers and clients are sharing.
• Facebook Ads from Cadillac Fairview.  We may display interest-based ads to you when you are using Facebook.  We do this using tools that Facebook makes available to us.  Using a tool provided by Facebook, we convert your e-mail address or telephone number that you provided to us to a unique number that Facebook uses to match to unique numbers that Facebook generates from information you provided to Facebook.  We also use Facebook pixel tags on our website that allows Facebook to recognize that you visited our website.  These tools allow Facebook to show you Facebook Ads from Cadillac Fairview and will provide us with analytics information regarding the effectiveness of Facebook Ads from Cadillac Fairview.  You may opt-out of customized ads by adjusting your Facebook Ads setting on Facebook or selecting “Why am I seeing this” in the Facebook Ad from Cadillac Fairview or one of its shopping centres.  You may also opt-out of us using your e-mail address or telephone number to create personalized Facebook Ads from Cadillac Fairview by email at newsletter@cadillacfairview.com. You may opt-out of Facebook pixel tags by visiting the Digital Advertising Alliance. 
• Cadillac Fairview Shop Card. If you register your Cadillac Fairview SHOP! CARD gift card we will track your account balance for you.
• Transaction Information. We collect information such as your name, address and payment information if you make gift card purchases or rent equipment from us. We will also collect contact information to deliver communications and packages to you.
• Usage Information. We collect information on how you use our websites, mobile applications, and WIFI services, and how you respond to our advertising and promotional communications. When you use our WIFI services, we collect information such as clickstream data, session data and pages viewed or searched for to facilitate and improve your access to our WIFI services and to measure and understand the effectiveness of advertising and to deliver promotions to you.
• Browser and Device Information. In some cases, we may be able to associate you with a browser or device that you use to access our websites, use our mobile applications or in our properties, such as when you use our WIFI services. We collect browser and device information such as browser type and version, operating system and device type in order to properly format information for your device and to recognize you when you return to our websites or use our WIFI services. We may also use device information such as MAC address or other device identifiers to track foot-traffic, deliver relevant promotions and offers, customize your online experience, and to provide and manage our WIFI services.
• Vehicle Information. If you park on one of our properties, we may collect information about your vehicle for the purposes of managing our parking facilities, providing parking services to you, and enforcing our parking regulations.
• Applications for Employment. If you seek employment with us, we will collect information that you provide to us in connection with your employment application, which may include previous work experience, education, and other relevant information. We use this information to assess your suitability for employment with us.

We may also collect other information as we develop new products, services and techniques for delivering improved or personalized services to you.

We are continually innovating. We may use all of the information we collect to conduct research and development for new products, services and business methods, as well as to continually improve our ability to detect and address potential security issues.

Please see Our Privacy Principles for the principles that guide our collection and use of your personal information.

Do you customize promotional offers and other benefits for me?

We may personalize the promotional offers and other benefits that we offer to you. We use information that you provide to us as well as other information that we collect regarding our interactions with you and other visitors and customers in order to anticipate your preferences and interests. In some cases, we combine this information with information about you that we receive from third parties who disclose it to us with your express or implied consent. We use this information to provide you with better and more personalized offers and benefits. Please see “What choices do I have?” for information on opting-out of these personalized promotional offers and other benefits.

Do you use cookies, ibeacons and other similar technologies?

Like many other companies, we use technologies such as cookies, pixels and other technologies to collect information on how users navigate our websites and WIFI services, use our mobile applications and respond to our promotional communications. We may also use this information to personalize the content of our websites and communications to you and to provide you with personalized advertising through third party ad networks when you are visiting other websites.

For example, some of our websites and promotional communications use cookies, pixel files and other digital markers. A cookie is a small data file of information offered to your computer or device by web servers to keep track of your browser as you navigate our websites or use our WIFI services. Using this information, we learn how you interact with our websites and WIFI services, how we can improve the design and content of our websites and manage our WIFI services, and how to improve your experiences. We do not use cookies to access personal files on your computer or device.

Some of our websites and email communications use pixel files to manage our on-line advertising programs. Pixel files keep track of your browser so that you will be recognized when you visit other websites. We also use pixel files to determine when you have opened a promotional communication from us. These pixel files are generally valid for a limited number of days and are provided by our ad management providers. Our ad management providers may use cookies and pixel files to populate an advertisement for us when you visit certain other websites.

We participate in the Adobe Marketing Cloud Co-op and may collect and share information about which of your devices are linked to you. We use this information to create interest-based advertising and to understand how you use our websites and mobile applications on different devices. The Adobe Marketing Cloud Co-op allows participating organizations to understand when two or more devices are linked to the same person. When you visit a website or use a mobile application that participates in the Adobe Marketing Cloud Co-op, your device is assigned an identifier. If you use a login ID to access services through a website or a mobile application on one device and then login to that same website or mobile application on a different device, those devices will become linked. The Adobe Marketing Cloud Co-op shares that information with other participants, so that they can also recognize that your devices are linked when you visit other participants’ websites and use other participants’ mobile applications. Only the fact that the devices are linked to the same person is shared among participating organizations. No other information about you or how you use our sites is shared with other organizations through the Adobe Marketing Cloud Co-op.

Our websites may use analytics services, including Google Analytics, a web analytics service provided by Google, Inc. These analytics providers use cookies to help the website analyze how users use the site. In some cases, the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by analytics providers on servers outside of Canada. This information is used for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Analytics providers may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of the website.

We also use a variety of technologies to track foot traffic and mobile devices within our properties. This technology allows us to gather information on how our properties are used and also allows us (with your permission) to provide you with special location-based offers.

Please see “What choices do I have?” for information on opting-out of our collection and use of information by these technologies.

What choices do I have?

We also provide you with choices regarding some of our uses of your personal information.

• Interest-Based Advertising and Analytics. You can opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page, NAI Opt-Out Page and the Ad Choices Opt-Out Page. These websites provide tools that identify member companies that have placed cookies on your browser and provides mechanisms to opt-out of those cookies. You will still receive other types of advertising from participating companies; however, it will not be based on your interests. Deleting browser cookies can remove your opt-out preferences, so you should use these tools periodically to ensure that your preferences are up-to-date. Want more information on how we use web beacons and other digital markers? See “Do you use cookies, web beacons, ibeacons and other similar technologies?”.
• Cross-Device Tracking. You can opt-out of our participation in the Adobe Marketing Cloud Co-op, which provides us with information about how you use our websites and mobile applications on different devices. To opt-out, please disconnect your device by visiting https://cross-device-privacy.adobe.com. In order to ensure that your changes take effect as soon as possible, please close all your browsers and apps on your device and restart them after you have disconnected your device. Your device may become relinked if you use a new browser or app on that device that participates in the Adobe Marketing Cloud Co-op or if you clear cookies on the device. Please visit Adobe Marketing Cloud Co-op regularly to manage your cross-device tracking privacy preferences: https://cross-device-privacy.adobe.com. 
• Cookies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. Want more information on how we use cookies? See “Do you use cookies, web beacons, ibeacons and other similar technologies?”.
• Location Information. We only collect your location information in a manner that is associated with you if you are logged into our mobile applications and authorize your device to provide us with GPS information.

Where do you store and process my “personal information”?

For the most part, we collect, use and store your personal information in Canada. However, we may use service providers who process or store 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.

Is my personal information secure?

We employ administrative, technical and physical safeguards to protect personal information from unauthorized access, use, modification, disclosure or destruction. The types of safeguards that we employ and that our service providers employ depend on the sensitivity of the information. Although we take care to secure your information, no system of safeguards can provide you with a guarantee of security.

You have a shared responsibility to keep information secure that is collected or created through our websites and mobile applications. Please take the following steps to secure your data:

• Install the latest security updates and anti-virus software on your device to help prevent malware and viruses
• Reset your account password frequently
• Use complex passwords to lock your device and mobile applications. Complex passwords include capital letters, numbers and special symbols
• Do not use the same password for multiple sites
• Do not share your password with others

Do you sell, rent or share my personal information with other companies?

If you consent, we may share your personal information with third parties for specific purposes. For example, we may offer you the opportunity to participate in services to allow retailers to provide you with discounts or promotions.

We use third-party service providers to assist us in our business. We will provide your personal information to those third parties to perform services on our behalf.

In addition, we may share information in aggregated statistics and de-identified form with third parties for their own use, such as learning about the types of visitors to our website or properties.

We may sell or purchase assets. If another entity acquires us or all or a portion of our assets, information that we collected from you may be shared with that entity. The information may also be shared for the purpose of that entity considering whether to enter into the transaction and also to complete the transaction.

How can I get help?

• We are here to help. If you have created an account on one of our websites, you may access and amend your personal information by logging into your account profile.

If you require access to your personal information please first check any account profiles that you have with us. If you are unable to locate the information you require access to, please send a written request to the Chief Privacy Officer at the address provided below and include satisfactory identification and proof of entitlement as well as details regarding the type of information you are seeking. We will respond to such requests within the time period prescribed by law.

Please also note that in some cases we may legally deny you access to the information that we have collected about you. For example, this may occur where the information is subject to solicitor-client privilege or consists of references to other persons or proprietary information that cannot be severed from the record.

Chief Privacy Officer
The Cadillac Fairview Corporation Limited
20 Queen Street West
Suite 500
Toronto, ON M5H 3R4
Email: cfprivacy@cadillacfairview.com
Fax: (416) 598-8222

• If you have a question regarding our mobile applications, gift cards, marketing or customer-related issues, please contact cfshop@cadillacfairview.com.

Although we will make efforts to comply with any request that you may make to destroy personal information about you that is not otherwise required by us to fulfill legal requirements or to protect our interests, you should be aware that it is not always possible to completely remove or delete all of your personal information from our databases without some residual copies of data because of backups, archival systems and for other reasons.

Do you cooperate with law enforcement?

We may disclose personal information on our own initiative to a government institution if we have reasonable grounds to believe that the information relates to a breach of an agreement or a contravention of the laws of Canada, a province or a foreign jurisdiction that has been, is being or is about to be committed or we suspect the information is relevant to national security or the defence of Canada.

We will also respond to lawful requests for information from law enforcement agencies and other government institutions.

We may also disclose your personal information in the following circumstances: (a) if such disclosure is necessary for us to receive legal advice; (b) to collect a debt from you; (c) for business or security purposes if we are otherwise permitted or required to do so by applicable law.