Last Updated: October 1, 2020
If you are a California resident, see Section 6 for information provided pursuant to the California Consumer Privacy Act, including how to request that we not “sell” your personal information by clicking Do Not Sell My Personal Information.
SECTION 1. We collect and use personal information from and about you. The information we collect depends on how you interact with us.
SECTION 2. We use personal information as described here. We may use personal information for marketing, to respond to your requests, to provide you with services, to improve our products and services, to comply with our obligations, to administer our websites, apps and services, for internal operations and security purposes, for hiring purposes, to comply with the law or to protect ourselves, as part of a transaction, and as otherwise disclosed or permitted by law.
SECTION 3. We collect personal information about you from various sources. These sources include collecting information directly from you and your device, from our vendors and other sources, and by combining information.
SECTION 4. We share your personal information with other parties. For example, we may share personal information with parties including the Brookfield Properties family of companies and business units, service providers and vendors who perform services on our behalf, our business partners and marketing companies, with others to comply with the law or to protect ourselves, our customers and others, or as part of a transaction, and as otherwise disclosed or permitted by law.
SECTION 5. You have certain choices about how we use your personal information. You can opt-out of some of our uses of personal information. This includes certain of our online tracking and advertising tools, and our promotional email.
SECTION 6. Your California Privacy Rights. Residents of California have additional choices under California law. You can learn about these in this section.
SECTION 7. Your EU Privacy Rights. Residents of the EU have additional rights under EU law. You can learn about these in this section.
SECTION 8. Your Australian Privacy Rights. Where we are subject to Australian privacy law, Australian residents whose personal information we hold will have additional rights under Australian law. You can learn about these in this section.
SECTION 9. Your Canadian Privacy Rights. Residents of Canada have additional rights under Canadian law. You can learn about these in this section.
SECTION 10. Your Privacy Rights under Dubai International Financial Centre (“DIFC”) law: Where your personal data is controlled or processed in the DIFC in Dubai, United Arab Emirates, additional rights may apply under the DIFC’s data protection law. You can learn about these in this section.
SECTION 11. We may process and store information in the United States. Information processed and stored in the United States may be accessed by United States law enforcement according to United States law.
SECTION 12. Our websites, apps and services are not intended for children.
SECTION 13. We use standard security measures. However, the internet is not 100% secure, and we cannot promise that your information will be completely safe.
SECTION 14. We may link to third party sites or services we don’t control. We are not responsible for these sites or services.
SECTION 15. Feel free to contact us.
SECTION 1. We collect and use personal information from and about you.
Brookfield Properties (and the vendors and other parties we use to perform services on our behalf) collect, receive, and develop several categories of personal information about you depending on the nature of your interactions with us. For example:
We collect Contact Information. For example, we might collect your name, email address, account username and password, social media account handles, phone number, and mailing address.
We collect Commercial and Preference Information. For example, we may collect information about your purchase history, retailer preferences, leasing details, apartment rental history, and your other transactions and preferences. We may also collect your comments that you post on our websites or blogs and your responses to surveys you complete. We may also collect information in connection with our loyalty programs and certain convenience services, including wheelchair and stroller rentals, delivery services, valet parking, and device charging services. In certain circumstances such as in the case of a residential home purchase or a rental or lease application, we may collect or ask you to provide additional personal information such as government issued identification, financial and tax information, employment information, and rental history information. At parking garages, lots, and facilities at certain of our properties, we may use license plate reader technology to collect license plate and vehicle-related information including a photograph of the license plate (which may include parts of the vehicle surrounding the license plate), the GPS location of the vehicle, and the time and date of the read.
We collect Device, Internet and Network Activity Information. For example, if you use our websites or apps, we may collect information about the browser, device and operating system you are using, signal strength, device identifiers, MAC address, and your IP address. We might also collect information about how you use our Wi-Fi network and other services, such as the websites you visit while using our Wi-Fi network. We might collect information at the site you came from, or the site you visit when you leave us. We may collect page interaction information (such as what areas of the websites you visit and for how long, what search terms you enter, and what products or content you view and click on), and methods used to browse away from the page. If you use our mobile apps, we may also look at how often you use the app and where you downloaded it.
We collect Location Information. We may automatically collect your precise GPS location when you access our apps or our websites, or when your Wi-Fi or Bluetooth-enabled device connects to, or is detected by, the wireless networks at our properties. We also collect information about your general location, using your zip code or postcode and IP address.
We collect Demographic Information. We may collect information like your ethnicity, gender, birth date, age, language spoken, housing status, current household size, current household type, annual household income, desired housing characteristics and desired housing location or community.
We collect Payment Information. For example, we collect your credit card and other payment details if you make a purchase or sign up for or through some of our services.
We collect Employment-Related Information. When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa or require sponsorship, and/or salary expectations. We may also conduct a credit check, background check, and employment verification to the extent permitted by applicable law. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, and/or veteran status.
We collect Audio/Visual/Thermal Information. For example, when you visit certain properties, we may record audio and video at the property. We may also collect information using infrared and heat sensing technologies.
We collect and develop Inferences. Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.
SECTION 2. We use personal information as described here.
We use the above-referenced categories of personal information for the following purposes:
We use information to provide you with services and fulfill your transactions.
We use information for marketing purposes. For example, we might use personal information to provide you with information about special promotions, retailer discounts, purchase incentives, prize promotions, shopping guides, or offers. At some of our properties, we may collect and process audio and video to evaluate general shopping habits and reactions to advertisements. We might also use this information to send push notifications on our app and to serve you ads about our products and offers. We might tell you about new features or services. These might be our own offers or products, or third-party offers or products we think you might find interesting. You may opt-in to receive our email newsletters or to receive text messages from us. To learn about your choices for these communications, read the Choices section below.
We use information to analyze and improve our products and services. For example, we may use your information to make our websites, apps, services, and products better. We might use your information to customize your experience with us and to conduct research and analysis.
We use information to comply with our obligations, administer our websites and services, and for property management or internal operations. For example, we use personal information to administer the websites, such as troubleshooting, data analysis, and testing.
We use information for security, safety, and due diligence purposes. For example, we may use personal information to protect our company, customers, and business partners and their respective personnel. We may also use personal information to protect our websites or our services, as well as to detect and investigate activities that may be illegal or prohibited (such as cyber-attacks or fraudulent transactions). We may also use information to conduct background, employment, and credit checks and to assess financial, reputational, credit, and other risks arising from any relationship or prospective relationship with you.
We use information for hiring purposes. For example, we use Contact Information and Employment-Related Information to review your job applications and contact you about employment opportunities. If you choose to voluntarily submit your ethnicity, gender, disability status, and/or veteran status in connection with a job application, we will use that information for statistical tracking purposes (not for hiring decisions), in accordance with applicable law.
We use information as otherwise required, disclosed or permitted by law, or as we may notify you. We may use personal information to create deidentified or aggregated data which does not identify you or any other individual, or from which your identity cannot reasonably be ascertained. We may use and disclose this anonymous or aggregated data as we choose.
SECTION 3. We collect personal information about you from various sources.
We collect personal information about you from various sources, directly and indirectly, including from the following sources:
We collect personal information directly from you. For example, we collect information if you sign up for an account, register to access the wireless network at our properties, enter into an agreement, participate in a promotion, contact us, sign up for our text and other messages, or sign up for investor alerts or other emails. We also collect Payment and Commercial and Preference Information if you make a purchase and we collect Employment-Related Information if you apply for a job. We also collect any personal information you provide if you post a comment, make a request, or complete a survey.
We receive personal information from vendors we hire to work on our behalf. For example, vendors that host or maintain our websites and apps and send promotional emails for us may give us information. Our employment and recruiting vendors also give us information. Our marketing agencies, advertising technology vendors, and analytics providers may also provide us with information.
We receive information about you from other sources. Other parties may give us personal information about you. These other parties might also include business and marketing partners and social media platforms that give us information they have collected either directly or indirectly from you. We may also receive personal information from your employer, credit check databases, background check providers, record verification providers, real estate brokers, and other parties in the real estate sector. We may also receive Employment-Related Information from a job network or social network if you choose to import your information from those platforms when applying for a job with us. We also use features that let your friends give us your information.
We combine information. We may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other consumers’ information to understand preferences and trends over time.
SECTION 4. We share your personal information with other parties.
We share your personal information with our business partners and marketing companies. We might share information with third parties who co-sponsor a promotion or promote our services. Some of these partners may send you information about products or services by mail or email. They may share your information with other third parties. We may also share the above categories of personal information with companies that help us with our marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, we may share email addresses or other contact information with social media platforms so they can serve our advertising to you on their platform. Personal information received by our partners and other parties may also be subject to their privacy policies.
We will share your personal information for safety and security purposes, if we think we have to in order to comply with the law, or to protect ourselves, our customers and others. We may share any or all personal information to respond to a court order or subpoena. We may also share any or all personal information if a government agency or investigatory body requests it. We might share your personal information in order to enforce our agreements and to protect our rights and/or the rights of others. We might share your personal information when we are investigating potential fraud. This might include fraud we think has happened during a promotion. If you are the winner of a sweepstakes or contest, we may also share certain Contact Information of yours with anyone who requests a winner’s list.
We may share your personal information as part of a transaction, financing, due diligence or for other business needs. For example, if Brookfield Properties sells any of its businesses or assets, applies for loans, or opens bank accounts, we may disclose your personal information to the prospective buyer, lender or bank, as the case may be, as part of certain due diligence processes. We also share information for the purpose of management and administration of Brookfield Properties’ business.
We may share your personal information with a successor to all or part of our business. If part of our business (including any of our affiliates, divisions, and business units) is acquired by a third party, we may include personal information as part of that transaction, which may include some or all categories of your personal information. We may also share your personal information if there is a change to our corporate structure. We may also share your information with others as they conduct diligence of our corporate changes.
We may share personal information for other reasons we may describe to you from time to time or as permitted or required by law.
SECTION 5. You have certain choices about how we use your personal information.
You can opt out of receiving our marketing emails and text messages. To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us. If you receive promotional text messages from us, you may opt out by replying “STOP”. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.
You can control if we share information with third parties for their marketing purposes. To opt out of having us share your information with third parties for their promotional purposes, please send an email to firstname.lastname@example.org.
You can control certain location tracking tools. To control the collection of your precise location on your mobile device, you can adjust the settings on your mobile device, such as by disabling location services or by turning off the Bluetooth and Wi-Fi.
You can control certain cookies and tracking tools. To learn more about the cookies we use and to set your cookie preferences, click on the Cookie Settings link in the footer of each Brookfield Properties website you visit. If there is no link available, then follow the instructions outlined below. Keep in mind that the cookies used on our various websites will differ and you will need to set your preferences on each Brookfield Properties site you visit. Your browser may also give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies. Since flash cookies do not reside in your browser, your browser settings will not affect them. To control flash cookies, you thus need to click here.
We and third-party advertising networks, social media companies, and other services may collect information about your use of our websites and apps over time so that they or we may display interest-based advertising using information gathered about you over time across multiple websites or other platforms. To do this, we and our vendors use several tracking tools, such as browser cookies, web beacons, and other technologies. To set your preferences related to this type of information collection and use, click on the Cookie Settings link in the footer of each Brookfield Properties website you visit. You can also visit www.aboutads.info/choices and https://optout.privacyrights.info/ to opt out of certain uses of cookies for advertising purposes. We use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our site may not work. If you block or reject cookies, not all the tracking described here will stop.
Options you select and choices you make are browser, website and device specific. If you clear your cookies or your browser’s cache, you will need to set your preferences again.
SECTION 6. Your California Privacy Rights.
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.
If you reside in California, you can make the following more specific requests with respect to your personal information:
- Access – You can request that we disclose to you the categories of personal information we collected about you, the categories of sources from which we collected the personal information, the categories of personal information we sold or disclosed, our business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we shared the personal information, and the specific pieces of personal information we collected about you over the past 12 months.
- Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
Brookfield Properties will not discriminate against you because you made any of these requests.
California residents can make these requests online by clicking here, by emailing us at email@example.com or by calling us at (855) 834-8394. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Except as otherwise provided by applicable California law, note that for purposes of these requests under this Section, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.
We will take reasonable steps to verify your identity prior to responding to your requests. For example, we may utilize a third-party verification provider to assist with verifying your identity. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us.
California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
- We may collect, use, and disclose for our business and commercial purposes, categories of personal information as set forth in applicable California law, including: Identifiers; payment and customer records information; characteristics of protected classifications under California or federal law (such as demographic information like age and gender); commercial information; professional or employment information; internet or other electronic network activity information; geolocation data; education information; audio, electronic, visual, thermal, or similar information; and inferences. See Section 1 above for additional detail.
- We collect these categories of personal information from the sources described in Section 3 above.
From time to time, we may offer financial incentives in connection with the collection or use of personal information. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at firstname.lastname@example.org or by calling us at (855) 834-8394.
SECTION 7. Your EU Privacy Rights.
As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that Brookfield Properties holds. We may require you to prove your identity with approved identification if you request this information.
Lawful basis for processing your personal data.
We process on the following legal bases:
- Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract.
- Legitimate Interests: We are permitted to process your personal data if it is based on our legitimate interests. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support. You can object to the processing that we carry out on the grounds of legitimate interests. See the section “Rights of data subjects” below to find out how.
- Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
- Legal Claims: We need to process your personal data to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).
Rights of data subjects
You have the following rights, where provided under applicable law, regarding your information (each of which are subject to various exceptions and limitations):
- The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
- The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.
- The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests. You also can object at any time to your information being used for direct marketing purposes (including profiling related to such direct marketing). Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
- The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the UK Information Commissioner’s Office (ICO): https://ico.org.uk/concerns/.
SECTION 8. Your Australian Privacy Rights.
We may store your personal information in physical and electronic formats and may outsource our electronic storage to a third party to store information on our behalf. In addition, we may transfer your personal information outside Australia, including to (but not limited to) the jurisdictions in which we operate. A list of certain of our offices can be found on our website at https://www.brookfieldproperties.com. We utilise a mix of security measures in connection with the information we hold including certain technological measures.
Residents of Australia may access, request correction of, and complain about the handling of, your personal information held by us. We will investigate and attempt to resolve all requests and complaints in a timely manner. If you are not satisfied with our handling of your request or complaint, Australian residents may be entitled to make a complaint to the Office of the Australian Information Commissioner.
SECTION 9. Your Canadian Privacy Rights.
Residents of Canada may access, review, and request correction of their personal information held by Brookfield Properties.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
We reserve the right not to change personal information if we disagree that it is incorrect, but we will append your requested alternative information. We may not provide access to personal information where permitted or required to deny access by the applicable law, for example, where the information requested would disclose the personal information, including opinions, of another individual or if it is subject to solicitor-client or litigation privilege.
You have the right to refuse to provide or to withdraw your consent to processing of your personal information at any time with effect for future processing. This would not affect processing where the applicable law allows us to process personal information without consent.
SECTION 10. Your Privacy Rights under DIFC law.
If we control or process your personal data in the Dubai International Financial Centre (DIFC), we must adhere to the DIFC’s data protection laws.
If we control or process your personal data in the Dubai International Financial Centre (DIFC), your rights as a data subject include, but are not limited to, the right to request confirmation of the type of personal data held by us and the purpose(s) for which that data is processed, the right to request rectification and, in certain circumstances, the erasure of your personal data. Such rights are subject to our right to retain and process personal data for legitimate and lawful processes.
To enquire as to what personal data (if any) we control or process in the DIFC, or where your personal data is controlled or processed in the DIFC, or to otherwise exercise your rights as a data subject, please contact us at email@example.com or write to us at ICD Brookfield Place Limited, PO Box 507034, Dubai International Financial Centre, Dubai, United Arab Emirates.
For further information regarding data subject rights under DIFC law, or if you have any concerns, please contact the DIFC Commissioner of Data Protection.
SECTION 11. We may process and store information in the United States.
Information we collect from you may be transferred to, processed in, or stored in the United States or another destination outside of the European Economic Area (“EEA”), Canada, or your jurisdiction of residence. Information may be processed by personnel operating in these locations who work for us or one of our business partners. As a result, this information may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. The standard of data protection in the United States and in certain other countries where we may process your information is considered by the European Commission to be not adequate when compared to the data protection standards of the EU and EEA. By using our websites or submitting your personal data, you consent to such transfer, storing and processing.
SECTION 12. Our websites and services are not intended for children.
Our websites and our services are meant for adults. We do not knowingly collect personal information from children under 16. If you are a parent or legal guardian and think your child has given us information, you can contact us at firstname.lastname@example.org.
SECTION 13. We use standard security measures.
SECTION 14. We may link to third-party sites or services we don’t control.
SECTION 15. Feel free to contact us.