PRIVACY POLICY

PRIVACY POLICY

Last Updated: November 29, 2019

This Privacy Policy describes how Brookfield Properties collects, uses, and discloses your personal information both offline and on the websites, apps, and services where this Privacy Policy appears or is referenced. This Privacy Policy does not apply to personal information Brookfield Properties collects from its employees and contractors.

By accessing a Brookfield Properties website on which the Privacy Policy is available, you confirm that you have read, understand, and consent to the terms of this Privacy Policy. For the purpose of European data protection laws, Brookfield Properties act as a controller in connection with certain personal information described in this Privacy Policy.

We collect and use personal information from and about you.

Brookfield Properties (and the vendors we hire 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 Purchase and Preference Information. We may collect information about your purchase history, retailer preferences, apartment rental history, and your other transactions and preferences.  We may also collect your comments that you post on our websites and your responses to surveys you complete.

We collect Internet and Network Activity Information. If you use our websites or apps, we may collect information about the browser you are using and your IP address. We might also collect device identifiers and information about how you use our Wi-Fi network and other services. 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 automatically collect your precise GPS location when you access our apps or the mobile version of our websites. 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 gender, birth date, and age.

We collect Payment Information.  We collect your credit card and other payment card details if you make a purchase.

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 to work in the United States, and/or salary expectations. 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 Information. When you visit certain properties, we may record audio and video at the property.

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.

We use personal information as described here.

We use the above-referenced categories of personal information for the following purposes:

We use information for marketing purposes. For example, we might use personal information like Contact Information, Purchase and Preference Information, Internet and Network Activity, Demographic Information, Location, and Inferences to provide you with information about special promotions, retailer discounts, prize promotions, shopping guides, or offers.  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.  If you register with us, you may opt-in to receive our email newsletter. To learn about your choices for these communications, read the “You have certain choices” section below.

We use information to respond to your requests or questions. We use Contact Information to contact you in response to your feedback or other matters related to our relationship with you (such as about this Privacy Policy or our Terms of Use). If your inquiries or feedback relate to your leases, purchases, or an account, we may also use your Purchase and Preference Information and/or Payment Information to address the matter.

We use information to provide you with services and fulfill your transactions. For example, we use Contact Information, Purchase and Preference Information, Location Information, and Payment Information to process transactions.

We use information to improve our products and services. For example, 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 internal operations. For example, we use all categories of personal information to administer the websites, such as troubleshooting, data analysis, and testing.

We use information for security purposes. For example, we may use Internet and Network Activity, Audio/Visual Information, and other categories of personal information to protect our company, our customers, and our business partners.  We also may 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 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 to verify requests made pursuant to this Privacy Policy.  We will use certain pieces of personal information to verify your identity if you make requests pursuant to this Privacy Policy.  The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.

We use information as otherwise disclosed or permitted by law, or as we may notify you.

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 Contact Information if you sign up for an account, enter into an agreement, contact us, or sign up for our investor alerts or other emails. We collect Purchase and Preference Information and Payment 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 collect personal information from your devices. We use tracking tools like browser cookies and web beacons to automatically collect information about you (including Internet and Network Activity, Purchase and Preference Information, Location Information and Inferences). We collect this information when you interact with our websites, our apps, our ads, or our emails that we or our vendors send to you.

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 Contact Information and Internet and Network Activity Information. Our employment and recruiting vendors give us Contact Information and Employment-Related Information. Our marketing agencies, advertising technology vendors, and analytics providers may provide us with Contact Information, Purchase and Preference Information, Internet and Network Activity Information, and Location 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 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.

We share your personal information with other parties.

We share personal information under the following circumstances:

We may share each category of personal information within the Brookfield Properties family of companies. This includes our subsidiaries and affiliates.

We share your personal information with vendors who perform services on our behalf. We may share personal information with vendors who send emails for us, help us manage and operate our websites and apps, manage our properties, fulfill purchases, provide tenant and guest services, provide advertising or marketing services, provide analytics and search engine support, track advertising impressions, investigate and prevent data incidents, audit our business and financial statements, vet job applicants, provide legal advice, and place our advertisements on other platforms. Some transfers of your personal information to our vendors may be viewed as a “sale” under certain state laws.

We share your personal information with our business partners and marketing companies. We might share Contact Information, Purchase and Preference Information, Internet and Network Activity, and Location 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. Some transfers of your personal information to our business partners and marketing companies may be viewed as a “sale” under certain state laws.

We will share your personal information 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 categories of personal information to respond to a court order or subpoena.  We may also share this 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 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 your certain Contact Information with anyone who requests a winner’s list.

We may share your personal information as part of a transaction, financing, or for other business needs.  For example, if Brookfield Properties sells any of its businesses or assets, applies for a 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 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 similar 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 as permitted by law.

You have certain choices about how we use your personal information.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, you can follow the instructions in any promotional message you get from us or email us at dataprivacy@brookfieldproperties.com. 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 dataprivacy@brookfieldproperties.com.

You can control certain cookies and tracking tools.  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 parties may display interest-based advertising using information gathered about you over time across multiple website or other platforms. To do this, we and our vendors use several common tracking tools, such as browser cookies, web beacons, and similar technologies. If you do not want to be tracked online for interest-based advertising purposes, you can opt-out here.

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 of the tracking described here will stop.

Options you select are browser and device specific.

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 have the right to make the following more specific requests with respect to your personal information:

  • Access – You have the right to 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.
  • Opt-out – You can request to opt-out of the sale of your personal information. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration.

Brookfield Properties will not discriminate against you because you exercised any of these rights.

California residents can exercise these rights by emailing us at dataprivacy@brookfieldproperties.com.  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.

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.

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.

For purposes of exercising these rights, please note the following regarding how we collect and use your personal information as described in this policy:

  • We may collect, and use for our business and commercial purposes, the following categories of personal information as set forth in applicable California law: Identifiers; payment information; characteristics of protected classifications under California or federal law; commercial information; professional or employment information; internet or other electronic network activity information; geolocation data; audio, electronic or visual information; and inferences
  • We may disclose each of the foregoing categories of personal information for a business purpose to the extent permitted by applicable law
  • We may sell the following categories of personal information: Identifiers; commercial information; Internet or other electronic network activity; geolocation data; and inferences

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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):

  1. The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.
  2. The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your information in accordance with data protection law.
  3. The right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
  4. 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.
  5. 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.
  6. The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services and platforms.
  7. 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.
  8. 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/.

Please note your rights in relation to your personal data are not absolute. We may, for example, deny you access to your personal data when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy.

We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements

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”). Information may be processed by personnel operating in these locations who work for us or one of our business partners. 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.

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 dataprivacy@brookfieldproperties.com.

We use standard security measures.
The Internet is not 100% secure. We cannot promise that your use of our websites, apps, or services will be completely safe. Any transmission of your data to our websites is at your own risk. We encourage you to use caution when using the Internet. We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep information as otherwise required by law.

We may link to third party sites or services we don’t control.
If you click on a link to a third party site or a third party app, you will be taken to a website or service we do not control. This Privacy Policy does not apply to the privacy practices of that website or services, which may collect information from you. Read the privacy policy of other websites, apps, and services carefully. We are not responsible for these third party websites or services or their policies.  At certain public locations like malls operated by Brookfield Properties, guests who wish to access Wi-Fi services may be required to agree to a different privacy policy at the time of access.

Feel free to contact us.
If you have any questions about this Privacy Policy or want to access, correct or update your information, please email us at dataprivacy@brookfieldproperties.com.

We may update this Privacy Policy.
From time to time we may change Privacy Policy. We will notify you of any material changes to our Privacy Policy to the extent required by law. We will also post an updated copy on our websites. Please check our websites periodically for updates. Your continued use of our websites means that you consent to the collection, use and disclosure of your personal information as set out in the updated Privacy Policy.

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