Privacy Policy

Ivanhoé Cambridge Inc. (“Ivanhoé Cambridge”) welcomes you to our properties, websites, mobile applications and other digital channels. This privacy policy (the “Privacy Policy”) of Ivanhoé Cambridge generally applies to any personal information (as defined below in the section entitled Definition of Personal Information) collected by Ivanhoé Cambridge from or about guests, tenants (which includes retailers and occupants of our properties), services providers or business partners (hereinafter “users”).

The Privacy Policy is a statement of principles, guidelines and practices concerning the protection of personal information and of the choices you can make about the way your information is collected by Ivanhoé Cambridge and how that information is used and/or shared. Our websites and mobile apps are also governed by the Website and Mobile App Terms and Conditions Of Use, and the use of Wi-Fi is governed by the Wi-Fi Terms and Conditions Of Use. These documents can be accessed through each property website, mobile app or Wi-Fi portal.

DEFINITION OF PERSONAL INFORMATION

Personal Information. When used in this Privacy Policy, personal information means “any information about an identifiable individual”. This may include, for example, your name, contact information, home address, telephone number, email-address, information relating to your inquiry with us, any complaints documented in a file or other personal or demographic information. It may also include other types of more technical information such as online/users’ IP addresses, user IDs, browser history (pages accessed, date of access, location when accessed), but only when this information can identify you as an individual.

Non-Identifiable Information. Personal data that is de-identified and/or aggregated and cannot be associated with an identifiable individual is not considered to be personal information. Ivanhoé Cambridge reserves the right to conduct statistical analyses through the use of personal information and/or data collected, including the data collected from individuals who enter our properties, through our websites, mobile apps and/or Wi-Fi on an anonymous and/or aggregated basis in order to understand users’ interests, improve our services and measure interest in and use of our websites and/or mobile apps. Ivanhoé Cambridge reserves the right to provide its analyses based on such anonymous and/or aggregated data to third parties.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Information Collected From or About You. In many cases, we collect personal information directly from you when you visit our premises, rent our premises or use our services, websites, mobile apps and/or Wi-Fi. You will therefore know when we collect this information. In some other cases, we may collect personal information from third parties (for example, from credit score companies or when conducting a background check) but at all times, with your prior consent and/or as authorized by law. More specifically, we may collect personal information from you in the following situations:

Information Collected Automatically. In some cases, we may collect information automatically which may not necessarily identify you as an individual. For instance, we may collect the following type of information:

WHY DO WE COLLECT PERSONAL INFORMATION?

Ivanhoé Cambridge collects personal information for general business related purposes such as to help prevent fraud, unauthorized activities, claims and other liabilities and to ensure the security of our properties. We may also use personal information to authenticate the identity of individuals contacting us by telephone, electronic means or otherwise, for internal training and quality assurance, and purpose to manage our business and ensure the efficiency, reliability and security of our systems and networks. We may also collect personal information for the following purposes:

Subject to our users’ Right to Withdraw Consent provided in this Privacy Policy, we may use your information to contact you regarding future services and/or to conduct surveys on the quality of our products, services or customer service or to provide you with offers for additional products and services that we feel may be of interest to you. For more details on the type of commercial electronic messages that you may receive from us, please refer to section Electronic Communications and Notifications of this Privacy Policy. Unless required or authorized by law, Ivanhoé Cambridge will not collect or use personal information for any other or new purpose without obtaining further consent.

ELECTRONIC COMMUNICATIONS AND NOTIFICATIONS

You may receive the following type of electronic communications and notifications from Ivanhoé Cambridge:

For more information on how you may unsubscribe from receiving such commercial electronic messages (CEMs) please refer to the section Right to Withdraw Consent of this Privacy Policy.

YOUR CONSENT

In general, by interacting and/or doing business with us, visiting our properties, subscribing to our newsletter to and/or submitting information to us in connection with using Ivanhoé Cambridge services, visiting, interacting with and/or using our websites, mobile apps and/or Wi-Fi, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy and in the Ivanhoé Cambridge Website and Mobile app Terms and Conditions Of Use (and/or the Wi-Fi Terms and Conditions of Use, as the case may be).

Exceptions to consent requirement. In certain circumstances, your personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:

For more information on how Ivanhoé Cambridge may share your personal information, please refer to the section Sharing of Personal Information of this Privacy Policy.

RIGHT TO WITHDRAW CONSENT

Consent may be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice; however, without such consent, Ivanhoé Cambridge may in some cases limit the services it is able to provide you and/or Ivanhoé Cambridge may be prevented from entering into a business relationship, maintaining such relationship and/or interacting with you. You may also withdraw your consent as follows:

SHARING OF PERSONAL INFORMATION

Personal information about our users will not be sold or otherwise transferred to unaffiliated third parties without your approval, except Ivanhoé Cambridge reserves the right to disclose personal information when authorized by law or as follows:

Only those employees of Ivanhoé Cambridge or trusted third party contractors, who need access for business reasons, or whose duties reasonably so require, will be granted access to personal information about our users.

SECURITY

Ivanhoé Cambridge maintains reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure. You acknowledge that: (i) there are security and privacy limitations of the Internet which are beyond the control of Ivanhoé Cambridge; (ii) the security, integrity and privacy of any and all information and data exchanged between you and Ivanhoé Cambridge through our websites and mobile apps or when using our Wi-Fi cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party. Because of that we cannot ensure or warrant the security of any such information. In the event there is a security incident concerning any of your personal information collected and retained by Ivanhoé Cambridge as set out in our Privacy Policy, we may contact you by e-mail, letter, telephone or through other secure form of communication.

RETENTION OF PERSONAL INFORMATION

We have personal information retention processes designed to help ensure that we retain personal information of our users for no longer than as reasonably necessary for the purposes stated in this Privacy Policy or to otherwise meet our legal requirements.

LOCATION, STORAGE AND CROSS-BORDER TRANSFER

Your personal information is stored in secured locations and on servers controlled by Ivanhoé Cambridge or its service providers, located either at our facilities or at the facilities of our service providers. Notwithstanding the foregoing, Ivanhoé Cambridge and its third-party service providers may process or store your personal 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.  For more information about our practices and policies regarding the use of foreign service providers, please contact us as described below.

CHILDREN

Ivanhoé Cambridge recognizes the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. Our services (including our websites, mobile apps and/or Wi-Fi) are not aimed at nor intended for children under the age of thirteen (13). If you are under the age of thirteen (13), please do not use our services (including our websites, mobile apps and/or Wi-Fi), and if you are over the age of thirteen (13) but under the age of majority in the province in which you reside, you should use our services (including our websites, mobile apps and/or Wi-Fi) only with the involvement and permission of a parent or legal guardian. No personal information is purposefully or knowingly collected from children under the age of thirteen (13) by Ivanhoé Cambridge without parental consent.

UPDATING AND ACCESSING YOUR INFORMATION

At your request, Ivanhoé Cambridge will: (a) provide reasonable access to your information that is in Ivanhoé Cambridge’s records; and (b) use reasonable efforts to allow you to update/correct personal information which you state is incorrect to the extent that the information has been maintained by Ivanhoé Cambridge and if so, that such updating/correction will not compromise Ivanhoé Cambridge's privacy or security interests, subject to legal or contractual restrictions as well as the understanding that it may be impossible to completely delete your information without some residual information because of backups. You may access your profile in the Preference Center to update your communications preferences by clicking on the link provided in the Ivanhoé Cambridge communications which you receive. For access to your personal information, please contact our privacy officer at the contact number or e-mail address provided in the Contacting Ivanhoé Cambridge section of this Privacy Policy.

PRIVACY POLICY OF THIRD PARTIES

This Privacy Policy only addresses the use and disclosure of information by Ivanhoé Cambridge. Other websites that may be accessible through our websites have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

CONTACTING Ivanhoé Cambridge

If you have any questions about this Privacy Policy or the privacy practices of Ivanhoé Cambridge in respect of how we collect, use and share your personal information, please direct your inquiry to the Communications and Public Affairs Service of the Society, Ivanhoé Cambridge, 1001, square Victoria, Suite C-500, Montreal (QC) H2Z 2B5 Canada or contact us at secretariat@ivanhoecambridge.com / privacy@ivanhoecambridge.com or at (514) 841-7600.

CHANGES TO PRIVACY POLICY

Ivanhoé Cambridge reserves the right to change this Privacy Policy at any time by notifying you of the existence of a new Privacy Policy. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, posting on our websites and our mobile apps, or by any other means by which you obtain notice thereof. If the changes are significant, we will provide a more prominent notice. Your continued use of our services, websites, mobile apps and/or Wi-Fi after such modifications will constitute your acknowledgement of the modified Privacy Policy and agreement to abide and be bound by the modified Privacy Policy.

Please note that this version does not substantively change the way we treat personal information compared to the previous version of the Privacy Policy.