Full text of the privacy policy. Last updated: September 20, 2023

This Privacy Policy applies to Sebastien Deshaies (collectively, “we,” “us,” or “our”) and sets out the principles by which Sebastien Deshaies handles privacy matters.

This Privacy Policy is intended to inform you about how we collect, use, disclose, store, protect, and process personal information.

We want you to be well-informed about your rights, why we collect personal information, and how we process it. Therefore, please read this Privacy Policy carefully. We know that protecting your privacy is extremely important to our clients, tenants, visitors, service providers, and all other individuals who interact with us (collectively, “you” or “your”). We therefore want to be clear and transparent about all our practices regarding your personal information.

Important

By submitting personal information to us, including by visiting our facilities or websites, you agree to and acknowledge that we may collect, use, and disclose this personal information in accordance with this Privacy Policy and applicable laws. If you do not agree to the terms of this Privacy Policy, you may not use our services or products, and you must not visit our websites or properties.

Please note that our websites may contain links to other websites, which are provided for informational purposes only. The privacy policies and practices of third-party websites may differ from ours, and you should review them carefully.

1. What is personal information?

Personal information is information about an identifiable individual or information that can be used to identify an individual. Among other things, personal information includes your name, home address, telephone number, email address, license plate number, video image, banking information, and credit information.

Personal information may also include other, more technical types of information, such as IP addresses, geolocation data, device IDs, browsing history, and cookies, but only when this information can identify you as an individual. Non-personal information does not directly or indirectly reveal your identity or is not directly linked to an identifiable individual. Examples of non-personal information include statistical or aggregated data, including data derived from personal information.

2. What information do we collect?

The type of personal information we collect depends on your interactions with us. While this Privacy Policy aims to provide a detailed description of the personal information we collect, please keep in mind that we may also collect other information as we develop new products, services, and technologies to provide you with new, improved, and personalized services.

First, we collect information when you provide it to us directly, such as by filling out forms or submitting a request, like an information request. You also provide us with information when you interact with us through public websites, including social media and social networking sites.

Second, we collect information through video recordings, cookies, and other automated technologies when you browse our websites. Information collected automatically may include certain demographic and similar information gathered through anonymous video and traffic analytics, usage information, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Third, we also collect information about you from third parties. Third-party sources may include public databases, identity verification partners, resellers, channel partners, joint marketing partners, internet search engines, and social media platforms. We receive personal information when you link to a third-party service, which may include interactions with our social media sites. Please note that third-party websites are governed by their own privacy policies; you should review these policies before using them.

3. We collect and use the information you provide to us

When you create an account

When you create an account with us, including through our mobile applications (each an “Account”), we may ask for your name, email address, title, date of birth, home address, phone number, password, and information about your interests or background. Depending on the type of account you create, we may also ask you to provide certain biographical, employment, and educational information. If you log in to our websites, mobile applications, or Wi-Fi network using a social media account (such as Facebook, Instagram, or Pinterest), we collect profile information from those accounts and other information you have consented to provide to create your account. We will use this social media account information to register and authenticate you. We may also use the information we collect and associate with your account to tailor our products and services to your interests.

When you submit a request

We collect the personal information you provide as part of your job application. Subject to applicable laws, this personal information may include details about your current employment, previous work experience, education, professional licenses and accreditations, criminal record, credit report, information about your vehicle(s) (such as make, model, and license plate), insurance, and other related information. We use this information to assess your suitability and determine whether we wish to proceed with your application. Once we have made a decision regarding your application, we may retain your personal information in accordance with our retention policy.

When you contact us

If you request assistance or customer service, we collect the information necessary to respond to your request. The information we collect will largely depend on the nature of your request. This may include, among other things, your contact details, details of your request, including the circumstances or causes that led to your request, how you communicated with us, our response, and information regarding the resolution of your request.

If you visit one of our offices, we may collect your contact information, such as your name, address, and phone number, and ask you to answer certain screening questions. We collect this information for safety and security purposes and to comply with certain public health guidelines.

We may collect information when you sign up for a newsletter, contest, or service. This information may include your contact information. If you sign up for email communications, we generally only collect your email address. If you enter a contest or promotion, we will collect your personal information to administer the contest or promotion.

We may collect information if you interact with us on social media. We may review and share posts that mention our services or properties. We can only review and share this information if your privacy settings allow us to see your post. We use this information for marketing purposes, to understand visitor trends, and to understand what visitors and tenants are saying about our properties and services. We may also retain the services of third parties who analyze social media and other sources of information to identify threats to our assets and personnel.

4. We automatically collect information when you visit our websites

When you use our websites or apps, we automatically collect information from your device or current session as part of the normal process of delivering online content. In some cases, we may also analyze this information to detect cybersecurity threats. We automatically collect two main types of information: technical information and usage information.

Technical and Usage Information

Technical information includes, but is not limited to, your IP address, browser type and version, advertising IDs, and information about your application or device (e.g., device model, browser type, IP address, and physical device location). Among other things, this technical information allows us to properly format our content for your device.

Usage information includes data about the duration of your visits to our websites and apps, the pages you visited, the features you used, the searches you performed, and your other activities. We collect this information because it helps us understand how you use our websites and apps; it also helps us better meet your needs and improve our business. Usage information also helps us understand which advertisements and promotional communications have been effective, allowing us to tailor your experience to your interests, including the advertisements you see. We collect both technical and usage information through various means, including cookies and pixels.

Cookies

Cookies (or tracking cookies) are small text files sent from a website to your device’s hard drive (e.g., computer or phone) to store information about you. First-party cookies are placed directly on your device by our website, allowing us to collect analytics and provide other useful features that create a good user experience.

Third-party cookies are placed on your device by a third party (e.g., an advertiser or analytics provider). Third parties that place cookies on our site may link your name or email address to other information they collect, such as past online or offline purchases, or information about your web usage. We may use a third-party cookie to obtain reports on where visitors to our website come from and which web pages and mobile app features are useful. Examples of third-party cookies our website may use include those provided by Facebook, Twitter, LinkedIn, Google, and Bing.

Cookies are very useful and can be used for various purposes. Among other things, they allow you to navigate efficiently between pages, facilitate the automatic activation of certain functions, remember your preferences, and make your interaction with the website faster, easier, and smoother.

Most browsers can be configured to reject some or all cookies. Some cookies are necessary, and others are optional. Necessary cookies are used to ensure our digital services function correctly and to track certain page analytics. Optional cookies include cookies used for advertising and to recognize you when you use different devices. If you choose to modify your browser to reject all cookies, some pages on our website may not function optimally or may not function at all. Please note that due to a lack of industry consensus on this issue, our websites do not currently respond to web browsers that do not track signals.

Pixels

Pixels, or tracking pixels, are small image files that appear on our web pages or in advertisements. We may use these technologies for various business purposes, including remembering your device, keeping you logged in, tracking how you use our websites and apps, delivering online advertising, determining whether our emails have been opened or links in our promotional emails and advertisements have been clicked, and recording your location. Among other things, we may use pixels provided by Facebook and Google. For example, if we advertise on Facebook, both the advertisement and our website may contain pixels so we understand that a website visitor saw the Facebook ad. This helps us determine whether the ad was useful and relevant.

5. We automatically collect information when you visit our properties

Our properties are equipped with video surveillance technology that will capture images of you and your vehicle (including your license plate) when you are on one of our properties. We collect this information for security purposes. In some cases, the cameras on our property may capture images of people who are near the perimeter of our properties. We also employ security guards to monitor and protect our buildings. If an incident occurs, these security guards may collect information about the people involved in the incident, information from witnesses, and other information they receive or about what they have observed. We use the information we collect through our building security programs to help secure and protect our property, to create a safe environment for our tenants, building occupants, and visitors, to respond to emergencies, to investigate violations of our policies or laws, and to investigate claims (such as property damage or injuries).

Access to certain properties or areas within our properties is restricted. To access these properties or areas, you may be required to provide us with additional information, and in some cases, we may issue you a physical or digital pass. We will collect information about you and your business (if applicable) to enable us to issue you a pass. Our pass readers collect records of the dates and times these passes are used.

Information we collect using anonymous video analytics technologies

We may use cameras, image sensors, and other technologies (anonymous video analytics and anonymous traffic analysis) at our physical locations, information kiosks, or advertising installations to measure your engagement with and interest in certain visual media and other elements and aspects of our properties, as well as to measure viewer demographics, including age and gender. These technologies are used strictly for general analysis purposes (i.e., for purposes other than identifying individuals) and do not store images of individuals for extended periods.

We may also use other technologies to analyze traffic in a de-identified manner, including by tracking devices that have communicated with our Wi-Fi systems. For example, we may use third-party service providers to generate traffic analytics based on the Media Access Control (MAC) address of your mobile device, which is broadcast by Wi-Fi devices when Wi-Fi is enabled. When you drive or park on our properties, we may collect information about your vehicle, such as its make, model, and license plate number.

We collect and use this information to improve our displays and signage, justify the value of advertising space and manage the scheduling of advertising content, forecast trends and traffic, improve resource allocation and management, and for health and safety purposes. Please note that we may share aggregated statistical information collected through the use of these technologies with our business partners, including advertisers.

6. Why is your information collected and used?

We collect, use, and disclose information to better serve you and to fulfill our obligations to you and other parties, as required by applicable laws. Knowing that you help us understand your needs allows us to communicate effectively with you and provide the services you want. In addition to the reasons set out in this policy, we collect, use, and disclose your personal information for the following purposes (the “Specified Purposes”):

To evaluate, establish, and maintain an employment or business relationship;
to determine service rates, administer accounts, make and receive payments, and fulfill contractual obligations;
to provide you with the services you have requested, including responding to inquiries and other requests for assistance;
to research, develop, manage, protect, and improve our services, including conducting surveys that provide us with feedback;
to update and verify our databases and information provided by third parties;
to ensure the consistency and quality of our products and services or those of our suppliers;
to develop and manage our knowledge management and precedent systems and databases;
Administer our gift card program;
administer contests and promotions;
establish, manage, and enforce parking regulations;
investigate and resolve complaints;
compile statistics, conduct market research, and report to the owners of the properties we manage;
distribute personalized messages and interest-based advertisements, newsletters, promotional information, coupons, and other materials;
track your use of our websites, including transaction history and trends;
monitor your use of our Wi-Fi network on or near our properties;
create reports on customer behavior;
investigate specific transactions or transaction trends to detect unauthorized, fraudulent, or illegal activity;
maintain appropriate operational records;
facilitate business transactions, including the evaluation, execution, monitoring, and management of investments;
conduct business transactions;
to develop, market, and sell new products and inform you of their new features, including those of third parties; to facilitate safety and security;
to perform functions required or authorized by law;and for any other purpose to which you consent.

7. Legal basis for the collection and processing of your information

When we collect your personal information, subject to applicable laws, we rely on several legal bases to collect and process it. Generally, we will only collect or process personal information when we are legally required to do so, when processing is necessary to perform contracts we have with you (or to take steps at your request before entering into a contract with you), for our legitimate interests in operating our business, to protect our property and your property, our rights and your rights, or our safety and your safety, or when we have obtained your consent. In each case, we will only do so to the extent necessary to fulfill that obligation, interest, or purpose.

We value you, your rights, and your interests regarding the protection of your personal information. Therefore, when we collect or process your personal information based on our legitimate interests, we ensure that we consider any potential impact on you and your rights.

When we obtain your consent, subject to legal requirements, this consent can be withdrawn as described in more detail below. Withdrawing your consent does not affect the lawfulness of any processing we carried out before the withdrawal. Once we receive notification that you have withdrawn your consent, subject to applicable laws and this Privacy Policy, we will no longer process your personal data for the purposes to which you initially consented, unless we have another legitimate legal basis to do so.

8. Who do we share your personal

information with?

Third-party service providers

While providing our programs, products, services, promotions, contests, and events, we may share some or all of your personal information that we have collected with third-party service providers who perform services on our behalf.

These service providers help us operate our business. They provide office, legal, and other professional services; respond to customer inquiries; process credit card and other payment payments; conduct credit checks; send emails and postal mail; operate call and data centers; provide software and technical solutions; administer contests and promotions; manage our marketing and advertising campaigns; and provide analytics services (e.g., tracking the effectiveness of our marketing campaigns and analyzing the use of our websites and applications). We require these service providers, which may be organizations and individuals, to limit their access to and use of your personal information to what is necessary to provide their services, and to respect personal information as well as data security and protection procedures.

Sale or transfer of business

We may disclose your personal information to a third party in connection with a sale or transfer of our business or assets, a merger, reorganization, or the financing of a portion of our business (including in connection with insolvency or bankruptcy proceedings). If such a transaction occurs, your personal information will remain protected under applicable laws. If such a transaction does not occur, we will require the other party not to use or disclose your personal information in any way and to delete it, in accordance with applicable laws.

Law Enforcement

Sometimes, we need to share personal information with the police, government agencies, or other law enforcement officials. If a criminal incident occurs on one of our properties, we may share your personal information related to that incident with the police. We may also share your relevant personal information when required to complete a police report or respond to a police request.

Insurers

We share information with our insurers, as well as with those pursuing or defending legal action, when an incident occurs on one of our properties and the information is reasonably necessary to file an insurance claim or report. This may include CCTV footage, incident reports, and other relevant data, which may include your personal information.

Other permitted purposes. Except as noted above, from time to time, we may share your personal information with:

a financial institution, confidentially and solely for the purpose of receiving a payment, providing a guarantee, or other financing arrangements;
a person who, in our reasonable judgment, provides or requests the information as an agent;
any other party or third party, when you consent to such disclosure or when disclosure is required or permitted by law.

We will not disclose your personal information to any unaffiliated third party without your prior consent, except as provided in this privacy policy or as permitted by applicable law.

9. Your rights

Right to access your personal information

If you wish to access personal information we hold about you, you may submit a written request to the Sebastien Deshaies Privacy Office using the contact information provided below. To avoid delays in obtaining your information, please provide sufficient detail to allow us to identify you and locate the specific information you are requesting.

Once your request has been verified, we will give you a reasonable opportunity to review your personal information. You will generally have access to your personal information within 30 days of receiving your request. We may extend this 30-day period for up to an additional 30 days if meeting this deadline would unreasonably harm our business operations or if the time required to conduct the necessary consultations to respond to your request makes this timeframe impossible.

Please note that there may be instances where access is restricted by law. We will inform you of the reasons why we are restricting access due to legal or regulatory restrictions. Among other reasons, we may restrict your access to information that is excessively expensive to provide, that contains references to other people and cannot be disclosed for legal, security or proprietary reasons, or that is subject to legal privilege.

We do not charge an administrative fee for processing your access request. However, if you require copies of your personal information or need access to your information in a specific format, we will provide you with an estimate of the cost to fulfill your request and obtain your consent before incurring any costs on your behalf.

Right to correct erroneous information

To minimize the possibility that inappropriate information may be used to make a decision about you, we take reasonable steps to ensure that the information we collect is accurate and complete for the purposes for which it is collected.

We understand that some of the purposes for which we collect your information, such as when you submit a request for services, are very important to you, and we take this into account. We also take reasonable steps to ensure that your personal information remains accurate, complete, and up-to-date. However, we do not routinely update personal information without a business reason.

If the personal information we hold about you is inaccurate or incomplete, you have the right to have it corrected. If we have disclosed your personal information to others, we will notify them of the correction to the extent possible. If you request it, and if it is possible and legal to do so, we will also inform you of who we have disclosed your personal information to so that you can contact them directly.

Right to deletion

You can contact us to withdraw your consent to the use of your personal information or to request that we delete your personal information if we no longer need it.

Sometimes, we may still need to retain your personal information after you have asked us to stop using it and delete it. If this is the case, we will tell you. For example, we may be legally required to retain your personal information, or we may need the information for our accounting records. We may also retain information if we believe there is a risk of litigation or that the information is related to an investigation. If your information is in electronic form, it may be stored in our backup data. If so, we will retain it until we replace or delete our backups.

Right to dispute

You have the right to ask questions, request additional information, and challenge our compliance with this Privacy Policy and any applicable law. We will investigate all complaints regarding the handling of your personal information fairly and equitably, taking into account your privacy rights and interests, and we are committed to resolving these complaints. If we determine that a complaint is justified, we will take appropriate action, including amending our policies and practices, if necessary.

If you are not satisfied with the explanations provided or the actions we take to correct a situation, you will be informed of your other rights, including the right to lodge a complaint with the appropriate regulatory body, and you will receive clear instructions on how to do so.

Unsubscribe from marketing emails

You have the right to unsubscribe from the communications we send you. For example, if you signed up for one of our email newsletters and no longer wish to receive them, you can unsubscribe at any time. The quickest way to unsubscribe is to use the unsubscribe link in the last email we sent you. You can also contact us, and we will process your request.

Non-discrimination

You have the right not to be discriminated against for exercising your rights, and we will not retaliate or discriminate against you if you choose to exercise any of your rights.

Rights specific to the geographical location

Depending on where you live, you may have additional legal rights related to your personal information. For example, you may have the right to refuse the sale of your personal information. You can learn more about these rights and exercise them at any time by contacting us. Please note that we may refuse to comply with your requests, in whole or in part, as permitted by applicable law.

10. Where do we store your personal information?

Your personal information is stored in secure locations and/or on servers controlled by Sebastien Deshaies, located in our offices or in the offices of our service providers (which may be located outside of Canada). We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as long as may be required to comply with applicable laws. Video footage is generally kept for 30 to 60 days and is automatically deleted if no cause is found. If necessary, targeted video footage of an event (such as an accident, incident, or crime) may be archived for a longer period and is generally retained until it is no longer needed for an insurance claim, litigation, or law enforcement application, including any related appeals or statutes of limitations.

If you are a resident of Canada, we prefer to store and process your personal information in Canada. However, this is not always possible. Our service providers may be located outside of Canada, or they may store and process data outside of Canada. If so, your personal information may be transferred to other countries. While we use contractual safeguards when transferring personal information to other countries and consider the protections offered by the laws of the other country, we cannot guarantee that your personal information will receive equivalent protection when transferred. In certain circumstances, your personal information may be accessible under the laws of those other countries by foreign law enforcement agencies, regulatory bodies, or other authorities.

11. How do we protect your personal information?

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards.

We use these safeguards to protect the confidentiality of personal information and to protect it from loss or theft, as well as from unauthorized access, disclosure, copying, use, or modification, taking into account, among other things, the sensitive nature of the information and the purposes for which it is to be used.

Here are some examples of how we protect your personal information:

Employee training on privacy and security, and ongoing reminders in these regard;
restricting access to personal information to employees who need it;
technical measures (where feasible), such as encrypted connections, strong passwords, multi-factor authentication, firewalls, and other technical security tools;
physical measures, such as locked storage areas and restricted access to our offices and other locations where personal information is stored;
requiring service providers who process your personal information on our behalf to commit to protecting your personal information when they enter into contracts with us.

These safeguards also apply when we delete your personal information. We monitor potential privacy breaches and provide appropriate notice of any breach that could result in a real risk of serious harm to an individual or that could pose a risk to an individual’s rights or freedoms. Where required by law, we will notify the affected individuals and the relevant supervisory authorities without undue delay.

While we take care to protect your personal information, no safeguard can guarantee its absolute security. We believe we have developed and maintain administrative, technical, and physical safeguards designed to comply with applicable legal requirements and industry standards.

However, it is possible that hackers, employees or service providers acting contrary to our policies and procedures, or other individuals, could circumvent these safeguards to gain inappropriate access to our systems or documents, or to the systems or documents of our business partners, agents, or service providers, and to access, obtain, or misuse customer digital assets and funds. The methods used to gain unauthorized access, disable or degrade services, or sabotage systems are constantly changing and evolving, and can be difficult to predict or detect over extended periods.

The security of your information is also a shared responsibility. Please take the following steps to protect your personal information:

Install the latest security updates and antivirus software on your device to help prevent malware and viruses;
use the latest version of your browser;
change your account password frequently and do not share it with others;
use strong passwords to lock your device and mobile apps;
never use the same password for multiple sites;
use two-factor or multi-factor authentication whenever possible;
learn to spot phishing scams and be generally wary of unknown emails, phone calls, and flyers;
limit the amount of personal information you share on social media platforms.

12. Changes to this Privacy Policy

This Privacy Policy was last updated on the date indicated above and is effective as of that date. We reserve the right, at our sole discretion, to modify or add to this policy from time to time. If we make a change to this Privacy Policy, we will post those changes on our website at https://sebastiendeshaies.com and make the revised policy and changes available upon request to the Sebastien Deshaies Privacy Office.

Subject to applicable laws, the changes are binding upon you and will take effect immediately upon posting the revised Privacy Policy on our website. If you do not agree with the revised Privacy Policy, you may not use our services or products and must not visit our websites or properties.

We will obtain the necessary consents under applicable laws if we need to collect, use or disclose your personal information for purposes other than those for which your consent is obtained, unless required or permitted by law.

13. Contact us

Sebastien Deshaies a nommé un chef de la protection des renseignements personnels pour surveiller la conformité à la présente politique sur la protection des renseignements personnels et aux lois applicables sur la protection des renseignements personnels.

Vous pouvez communiquer avec notre bureau de la protection des renseignements personnels par écrit pour poser une question ou déposer une plainte. Vous pouvez également communiquer avec notre bureau de la protection des renseignements personnels pour demander l’accès à vos renseignements personnels ou leur correction, ou pour demander la suppression de données que nous ne croyons plus avoir besoin de conserver. Nous devrons peut-être voir une pièce d’identité pour vérifier que vous êtes bien qui vous dites être.

Pour plus de renseignements sur les pratiques de Sebastien Deshaies en matière de protection des renseignements personnels, communiquer avec notre chef de la protection des renseignements personnels à l’attention de :

Responsable de la protection des renseignements personnels
M. Sebastien Deshaies
Sweb_guit@hotmail.com