Hines Living and its respective subsidiary, parent and affiliated companies (“Hines”, “we,” “us,” or “our”) values your privacy and cares about the treatment of your personal information.
This Privacy Policy describes the personal information we may collect, use, disclose and otherwise process about individuals, as well as our personal information handling practices and the rights individuals have about their personal information. This Privacy Policy applies to:
- Visitors of our website (https://westhouse.ca/) (the “Site”);
- Individuals who apply for residency at a property that we manage in Canada;
- Individuals who are residents at a property that we manage in Canada; and
- Individuals who communicate or otherwise interact or engage with us through our Site, the App or in the provision of our services.
Collectively, the foregoing are referred to in this Privacy Policy as the “Services”.
By providing your personal information to us, you understand and acknowledge that our processing of personal information is subject to this Privacy Policy, and you authorize Hines, its affiliates and service providers to process your personal information (to the extent local privacy laws require and/or allow) for the purposes set out in this Privacy Policy or otherwise disclosed to you.
1. Collection of Personal Information - What Personal Information do we Collect?
For the purposes of this Privacy Policy, “personal information” is information about an identifiable individual and that directly or indirectly allows that person to be identified. For the purposes of this Privacy Policy, personal information does not include information normally used to contact an individual at their place of business, except as required by applicable privacy laws.
Personal Information Collected Directly from You. While the personal information we collect about you varies depending upon your use of our Services and our interactions with you, in general, we may collect the following personal information directly from you:
a) When You Use the Site:
- Identifiers and contact information. When contacting us through the Site, we collect your name and e-mail address, and any further personal information that you may choose to share with us.
b) When You Apply to be a Resident or are a Resident at a Property that we Manage:
- Information that is reasonably required to process and manage your rental application or tenancy. This may include, but is not limited to: name, contact information (e.g. phone number(s), e-mail address(es), current and previous address(es)), preferred means of communication, employer and job title, income information, credit check information, date of birth, marital status, gender, government identification numbers (e.g. driver’s license number and/or social insurance number), vehicle license and registration numbers, pet information, and information about household members.
- Communication and Interactions. When you email, call, chat, text, or otherwise communicate or interact with us, including if you complete forms on our Services, sign up for our mailing lists, or otherwise enter information into public-facing comment fields or forums sponsored by or affiliated with Hines, we may collect, process, and maintain records of your contact details, communications and interactions with us and others, including your posts or submissions, texts, information about the nature of your inquiry and our responses and any other information that you choose to provide.
- Property Use Details. We may also collect personal information related to your use of property and use of our Services, as well as other requests that you submit to us related to our Services. For example, if you register a guest or visitor(s) at a property, register your presence at our office(s), book the use of a desk or room at a property, request catering or other services, report facilities related issues or request maintenance services, etc.
- Transactions and Billing Information. We also collect personal information about you in connection with a purchase or payment you submit to us. This may include collection of your name, address, payment method, payment history and other transaction details.
- Promotional Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your profile, including the Services, Site and features you use in order to provide you with marketing communications about products and services we think you may like. If you participate in special activities, offers, programs, promotions, or sweepstakes we offer, we may also collect certain contact details, your age, and any other information that may be required by law. If you win a contest, promotion, or sweepstakes, we may also collect certain tax information and/or waivers and releases, depending on the prize and as required by applicable law.
- Preferences and Other Requests. We may also collect information about your preferences, including communication preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.
c) Personal Information Collected and Processed Automatically. We may collect and process personal information about how you use our Services and your interactions with us and others, including information we collect automatically (e.g. using cookies), as well as information we derive about you and your use of the Services. Such information includes:
- Device and browser information: Like most websites and other internet services, we may use cookies, local shared objects, log files and other technologies to automatically collect certain technical and device information, including personal information, about you when you interact with our Services, including but not limited to, device ID, internet browser, language, computer operating system used, IP address, general location, domain name of your internet service provider, access times, referring and exiting URLs, and other and similar device and usage information.
- Activity and usage information: When you visit our Site, engage with the App and when you communicate with us, we may collect information, including personal information, about how you interact with us, such as domain name, pages you accessed and when, date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the Site, including content viewed or downloaded, features used, links clicked, etc.
2. Purpose for Collection, Use and Disclosure - Why Do We Collect Your Personal Information?
We may collect, use and disclose your Personal Information for the following non-limited purposes, in accordance with applicable law:
- to communicate with you regarding your rental application, your tenancy, other property management related matters, and to respond to your inquiries and requests for customer support purposes;
- to process and administer your rental application(s), including to conduct credit and reference checks; to manage and administer your tenancy, including to process rent payments, payments for other products or services, and to maintain financial records;
- for event planning and property management including registration, attendance, connecting you with event attendees and service providers, and contacting you about relevant events and services;
- to provide property management services, including to receive and respond to maintenance and service requests and inquiries, investigate and respond to complaints, and ensure the security and safety of the property and its resident;
- to authenticate your identity;
- to monitor your compliance with any of your tenancy or other agreements in respect of the property(ies);
- to operate, customize and improve the quality of the Services, including our Site and App, advertisements, products and similar on and offline services;
- to tailor content and ads we may send or display to you and to otherwise personalize your experiences and offerings based on your needs and interests;
- to provide you with newsletters, promotions and other similar (electronic) commercial messages as well as information you may be interested in or request from Hines;
- to provide information to you regarding Hines products, services and property management services or third party products and services, unless you opt-out of receiving that information;
- to conduct financial, tax and accounting audits, audits, and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes;
- to maintain appropriate business records and enforce our policies and procedures;
- to prevent and protect Hines, yourself, and others from fraud and error and to safeguard Hines’ business interests, including but not limited to, to conduct in-depth threat analysis, administer and maintain the security of its databases and systems,
- to collect debts owed to Hines;
- to obtain legal, accounting or other professional advisory advice;
- to comply with applicable laws, rules and regulations; and
- otherwise with your consent or as required or authorized by applicable law.
3. Disclosure of Personal Information – How do we Share Your Personal Information?
We process Personal Information in accordance with applicable laws. We will take necessary steps to ensure that the personal data is accessed only by authorized employees, representatives and service providers of Hines who have a need to access your Personal Information for the purposes described in this Privacy Notice, except as otherwise required or authorized by applicable law.
In order to fulfil one or more of the above purposes, we may disclose your personal information to third parties as required or permitted by law or as consented to from time to time by you. The categories of organizations to which Hines may disclose personal information include, but are not limited to:
- our group members, affiliates and business associates, as reasonably required in connection with the operations of Hines;
- professionals advising or working on behalf of Hines such as lawyers, auditors and consultants;
- vendors and service providers to Hines;
- banks and other financial institutions;
- insurance companies; and
- government agencies.
We may also disclose your personal information if it is required or authorized by law.
From time to time, we may facilitate Third-Party Services at our residential buildings as an additional benefit to our residents. Your use of such services is voluntary. Should you choose to take advantage of such Third-Party Services, your personal information will be transferred to the Third-Party for the purpose of registration or facilitation of the service, after which time the processing of your personal information will be governed by the relevant Third Party’s policies and procedures. Please ensure to review the Third Party’s privacy practices and ask the Third Party any questions that you may have.
4. Cookies, Tracking and Site Analytics
Hines and our third-party providers may use cookies, local shared objects, and other tracking technologies (referred to herein as “cookies”) to collect browsing, activity, device and similar usage information within our Sites.
A “cookie” is a unique, alphanumeric identifier that we transfer to your computer’s hard drive through your web browser for record-keeping purposes and to customize your Site or App experience. Some cookies can enhance your user experience by, for example, allowing you to personalize the look of the Sites, save your preferences, make it easier for you to navigate and log in to our Sites. Other cookies are used to support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Although you are not required to accept all cookies when you visit our Services, you may be unable to use all of the functionality of the Site if you reject certain cookies.
Cookies can be first party cookies (cookies set by Hines which are primarily used to ensure the technical functionality and security of the Sites and App) or third party cookies (cookies set by someone other than the website you are visiting, such as third-party partners and service providers, to monitor and evaluate the use of the website). Some cookies will be stored only for the period of time that you are visiting our Site or App (i.e. session cookies) and are automatically deleted once you close your web browser. Other cookies may be stored for a longer period (i.e. persistent cookies).
The types of cookies that Hines uses are set out in the “Cookie Preferences” section in our Site website footer. Where required by applicable laws, we ensure we have your consent before placing any cookies that are not essential/strictly necessary:
- Essential Cookies. These cookies and services are essential to this website serving its primary functions. Without these cookies and services, essential functionality-like pricing and availability-would become unavailable.
- Performance and Functionality Cookies. These cookies and services enhance the performance and functionality of this website. Without these cookies and services, certain functionality-like maps & video-may become unavailable.
- Analytics and Customization Cookies. These cookies and services help us understand user flows, preferences and interactions. Without these cookies and services, certain user-based interactions and knowledge on how to improve the website may become unavailable.
- Analytics Cookies. These cookies and services help us connect users with their optimal purchase. Without these cookies and services, certain user-based functionality-like special marketing messages or offers-may become unavailable.
- Social Networking Cookies. These cookies and services help us understand which socially based external sites are best used to communicate to our users. Without these cookies and services, knowledge of which social platforms to ally with and communicate on may become unavailable.
- Conversational Cookies link interactions to a specific visitor on our website, particularly when engaging with our chatbot. Accepting these cookies is necessary for interacting with the chatbot on our websites.
5. Third-party Sites and Services
Our Sites may contain links to third-party websites, applications, software, or internet resources including social media sites (“Third-Party Services”) that are provided solely for your convenience and information. When you click on one of those links, you are leaving our Services and your interaction with these Third-Party Services will be subject to their respective privacy policies and practices, which may differ from this Privacy Policy and our practices.
We do not endorse, and are not responsible for, those Third-Party Services or their collection, use or disclosure of your personal information. We expressly disclaim any liability related to such collection, use or disclosure.
Please note that if you provide information to us via a social media site or participate in a social media site linked to the Platform, you consent to our use of your information for any reason in accordance with this Privacy Policy as if it were submitted to us directly via the Platform.
6. Cross-Border Transfers
As a global company, Hines may need to transfer your Personal Information outside of your jurisdiction of residence in order to fulfill any of the above purposes, including to service providers in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure and data protection laws in those jurisdictions. Where your personal information is transferred to another jurisdiction, we will implement are adequate safeguards to protect your Personal Information.
7. Protection of your Personal Information
Hines takes the security of your personal information seriously. We've put in place reasonable precautions and measures to keep your information safe and secure from loss, misuse, unauthorized access, disclosure, alteration and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
If you want more details about how we protect your personal information, just reach out to our Privacy Officer as set out in Section 12 below.
8. Retention of your Personal Information
We will generally retain your personal information for the period of time required to fulfill the purpose(s) for which it was collected, as identified in this Privacy Policy, or as otherwise required to comply with applicable legal requirements.
9. Marketing Communications and Preferences
If you don't want to get marketing messages from us, no problem! You can opt of marketing communications at any time by unsubscribing, sending us an email, or writing to us at the contact details listed in Section 12 below. If you opt-out of marketing communications, we may still send you transactional communications to manage your tenancy or relationship with us.
10. Your Personal Information Rights
You may have a right to access your personal information, to be informed how we process your personal information, or request correction of your personal information held by us:
- If you request a correction to your personal information and Hines is satisfied on reasonable grounds that there is an error or omission in your personal information, Hines will correct the personal information as soon as reasonably possible and send the corrected personal information to each third party to whom the personal information was disclosed, all in accordance with applicable law. If we do not correct the information, we will annotate it to show that a correction request was made.
- If you request to access your personal information and that request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
These rights are not absolute, but subject to limits in applicable law.
11. Changes to this Privacy Policy
This Privacy Policy is current as of the “last revised” date above. We reserve the right to revise this Privacy Policy from time to time. In the event of any changes, we will post any changes on our Site. If we make any changes to this Privacy Policy that materially affect how we process the personal information we have previously collected from you, we will endeavor to inform you in advance.
12. Contact Our Privacy Officer
If you have questions regarding this Privacy Notice you may contact our Privacy Officer at canada.DPO@hines.com.
