Privacy Policy
Last updated June 15, 2020.
The Shore Commercial Developments Commitment to Privacy
The Shore LLP and its affiliates and subsidiaries (the “Shore“, “we” or “us”) is committed to maintaining the security, confidentiality and privacy of your personal information. This Privacy Policy documents Shore’s on-going commitment to you, whether you are a customer, contractor, visitor or otherwise, and has been developed in compliance with the British Columbia Personal Information Protection Act(“PIPA”). To that end, this Privacy Policy outlines our privacy practices and provides details to help you make informed decisions about your privacy and information.
Shore may occasionally update this Policy. When it does so, it will revise the “last updated” date at the top of this Policy, and will notify you of any significant change, for example by placing a notice on its website or via email alert to you.
Application and Scope
This Privacy Policy generally applies to all personal information collected by Shore about any individual that interacts with us, including users of our website located at www.theshorekelowna.com and any other website or mobile application where this Privacy Policy is posted (collectively, “Website”), current and prospective customers, our tenants and visitors of our properties.
Because PIPA does not impose any requirements on Shore’s collection, use, or disclosure of your business contact information or certain publicly-available information, this Policy does not apply to such information
In this Privacy Policy, we describe what personal information we collect; how we use, share and manage it; how you can access, update and/or correct your personal information and the privacy choices available to you.
Personal Information We Collect
As part of its business activities, Shore may collect some or all of the following from you, either directly or indirectly from various other sources (as noted below):
- Identifiers, such as your name, IP address and unique identifiers;
- Contact information, such as email address, home address, and phone numbers;
- Banking information, such as your bank account or payment card information;
- Credit information
- Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, such as browsing history, your interaction with our websites and other information we may collect automatically when you interact with us online;
- Geolocation data;
- Professional or employment-related information;
- Information we may collect automatically when you visit our properties, such as images captured by video surveillance cameras;
- Other information provided to us in connection with the provision of our services;
- Inferences drawn from any of the information listed above.
Means of Collecting Personal Information
Most of your personal information will be collected directly from you, for instance when you interact with us as a customer or by visiting our Website. We may also collect personal information automatically using certain tracking technologies when you visit our Website or visit our properties.
More specifically, we may collect personal information as follows:
- Directly from you – We collect personal information directly from you, with your consent, or otherwise as permitted or required by law. For instance:
- We may collect the name, address, telephone numbers, email addresses, credit information, government issued identification, banking information, employment information, insurance policy number and other information regarding insurance and photograph for access card purposes.
- We may collect information, inquiries or comments you provide to us when you contact us through our Website, including name, address, email address, telephone number and other contact information.
- We may record phone calls for quality assurance purposes.
- We may collect the information that you have included in your resume when you submit a job application or when you apply for employment with the Shore.
- From Other Sources – In certain cases, we may collect personal information from other sources such as credit bureaus, real estate agents, financial institutions and publicly available sources, depending on the Shore’s relationship with you.
- Information Collected Automatically – In some cases, we may collect the following type ofinformation automatically:
- Video Surveillance: In order to ensure the safety of our customers and visitors and to protect our property, we may use video surveillance (Closed Circuit Television or CCTV) at our properties. This collection is subject to applicable privacy laws and may be shared in limited circumstances, as detailed in section Sharing of Your Personal Information of this Privacy Policy.
- Browser, Device and Technical Information: We may collect certain types of personal information automatically when you use our WiFi or interact with our Website, email, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons or single pixel gifs. The use of WiFi is also governed by our Acceptable Use Policy, which you must accept when you connect to our WiFi networks. The information we collect helps us understand what actions you take on our Website and how you use our WiFi, and allows our Website and WiFi to work correctly. You may delete or disable certain of these technologies at any time via your browser. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our Website.
- We may use analytics engines, such as Google Analytics, to allow us to see information on user website activities including, but not limited to, page views, source and time spent on our Website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page.
- We may use Google AdWords Remarketing to advertise the Shore across the Internet and to advertise on third party websites (including Google) to previous visitors to our Website. AdWords remarketing will display ads to you based on what parts of our Website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who haven’t completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our Website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
Use of Personal Information
Your personal information helps us to better understand your needs and allow us to provide you with the services you want. We may use your personal information to provide our services (including our real estate leasing services), for our own internal purposes as well as for marketing and advertising purposes, although in this last case, subject to your right to withdraw consent as set out in this Privacy Policy.
In particular, we use your personal information as follows:
- to authenticate your identity and preserve your privacy when you contact Shore by telephone, electronic means or otherwise;
- to provide you with the services we offer, and ensure all related transactions are supported and implemented;
- to use for accounting and transaction completion purposes;
- to establish and maintain personalized communications with customers, contractors, visitors or others and to respond to inquiries or resolve any complaints;
- to evaluate, establish and maintain commercial relationships (including landlord/tenant relationships), determining rental rates, administering accounts and fulfilling contractual obligations;
- to determine your eligibility to lease premises managed by Shore (including evaluating credit standing and matching credit reporting agency information) and for products and services that may be of interest to you from organizations with whom we have strategic alliances;
- to maintain accurate customer records and to protect you and Shore from error and fraud;
- for internal training and quality assurance purposes;
- to meet legal and regulatory requirements and allow us to meet contractual requirements relating to the services we provide;
- to generally enhance your customer experience with us;
- to understand and assess the interests, wants and changing needs of customers with a view to improving its services and developing new ones ;
- subject to your right to withdraw consent outlined below, to deliver online advertising relevant for you, to conduct surveys on the quality of our services or customer service or to provide you with information that we think may be of interest to you or meet your changing needs, such as e-mail notifications, literature requests, and newsletter subscriptions
When possible, rather than using personal information, we will anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for the purposes mentioned above or any legal purpose.
In addition, we collect personal information from tenants to evaluate their creditworthiness, evaluate and process applications for tenancy, prepare leases and to provide tenants with relevant information and services throughout the term of the lease (including specialized services and memberships, such as for parking and fitness facilities). We may also use tenants’ personal information for emergency, security or incident reporting involving video, swipe card and other surveillance method, for insurance, security and risk management purposes, and generally speaking, to establish, manage and terminate our business relationship.
If you have applied for employment with Shore, the personal information submitted with your job application will be used for recruitment and other customary human resources purposes. For example, we may send you information about new job opportunities within Shore as well as other career development resources.
If Shore wants to use your personal information for a new purpose, it will obtain your consent to do so unless the new use is otherwise authorized or required by law.
Sharing of Your Personal Information
Shore may share personal information it collects with our service providers and another business in the context of a business transaction. In some situations, we may also provide your personal information to third parties as permitted or required by law (such as in response to a court order or as permitted by law).
Your personal information may be made available by Shore to third parties or service providers to fulfill the purposes for which it has been collected or as set forth in this Privacy Policy. Shore will not sell, rent or trade your personal information to any third party. However, we may share your personal information when authorized by law or as follows:
- Within the Shore Group of Companies – The various entities within Shore may share personal information with each other and use it for purposes described in this Privacy Policy. This allows each Group entity to comply with applicable laws, regulations and requirements and ensures that your information is consistent, accurate and up-to-date. In addition, this facilitated access to your information within the Shore Group of Companies helps improve the quality and relevance of the services you receive and helps improve your interactions with Shore.
- Service Providers – We may hire service providers to perform services on our behalf. This may include, without limitation, internal audit, management, billing, website hosting or similar services, or otherwise to collect, use, share, store or process personal information on our behalf for the purposes described in this Privacy Policy. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and to comply with our privacy requirements.
- Business Transactions – We may share personal information to third parties in connection with the proposed or actual sale, transfer, amalgamation, re-organization, financing, securitization, insuring or assignment of all or parts of our business or assets. Assignees or successors of Shore or our business or assets may use and share your personal information for similar purposes as those described in this Privacy Policy. However, in the event the transaction is completed, your personal information will remain protected by applicable data protection laws. In the event the transaction is not completed, we will require the other party not to use or share your personal information in any manner whatsoever and to completely delete such information.
- Legal and Regulatory Requirements – From time to time, Shore may be compelled to share personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or enquiry (including as required by applicable Canadian and foreign laws applicable to Shore or its agents and service providers, and including lawful requirements to share personal information to government authorities in those countries). In these circumstances, Shore will protect your interests by making reasonable efforts to ensure that orders or demands comply with the laws under which they were issued, that it shares only the personal information that is legally required and nothing more, and that it does not comply with casual requests for personal information from government or law enforcement authorities.
- With your consent – Other than for purposes listed above, we may share your personal information outside of our group of companies, in accordance with applicable law. Your consent can be given expressly, impliedly, or through an authorized representative such as a lawyer, agent, or broker. It can also be given verbally, in writing, electronically, through inaction (e.g. if Shore notifies you (for example through this Policy) that it intends to collect, use or disclose your personal information forspecified purposes and you do not object). You may withdraw your consent at any time (subject to certain legal and contractual restrictions) if you give Shore reasonable notice in writing (for contact information, see How to Contact Us, below). After Shore receives such notice, it will inform you of the likely consequences of withdrawing consent, which may include its inability to provide certain services to you or to continue its relationship with you. The withdrawal of such consent may limit the services we are able to provide you.
Limits for Using, Disclosing, and Retaining Personal Information
Your personal information is stored in a secure location, is accessible by only our designated staff. Shore will only use and disclose your personal information for the purposes which are listed in this Policy or to which you have otherwise consented, or as authorized or required by law.
You can always limit the electronic communications that we send to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about services you have purchased from us. If you have any questions about your choices or if you need any assistance with opting-out, please contact us using the information detailed in the How to Contact Us section below.
For information on how you can limit the type of information that we collect, use or share about you when you visit and/or use our Website, please refer to the How We Collect Personal Information section of this Privacy Policy
Shore will securely destroy, erase or make anonymous any documents or other records containing personal information as soon as it is reasonable to assume that: (a) the original purpose is no longer being served by retention of the information, and (b) retention is no longer necessary for legal or business purposes.
Shore will take due care when destroying personal information to prevent unauthorized access to such information.
Links to Other Websites
Our Website may contain links or references to other websites. Please be aware that we do not control other web sites and that, in any case, this Privacy Policy does not apply to those websites. We encourage you to read the privacy policy of every website you visit.
Safeguarding Personal Information
We strive to protect your personal information against unauthorized access.
We use reasonable physical, technical and administrative security measures to safeguard your personal information. These measures are appropriate to the sensitivity of the information we collect, and are designed to protect personal information from loss, theft, misuse, and unauthorized access, use, copying, sharing, modification, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from our Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Personal Information Outside of Canada
We may store your personal information outside Canada and, as a result, it may be made be subject to the laws of other jurisdictions and made available to foreign government authorities.
In some cases, we may transfer your personal information outside Canada, such as to our service providers or within the Shore Group of Companies. In that case, the personal information is subject to the law of the jurisdiction in which it is used or stored, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
Access and Correction of Personal Information
Shore respects your right to access your personal information that we hold and have it corrected.
Under Canadian data protection laws, you have the right to access the personal information we hold about you, subject to any legal restrictions. It is your responsibility to provide accurate, correct and complete information. To request access to your personal information or request that your personal information be corrected, you can contact us in writing by email or through the post (for contact information, see How to Contact Us, below). We may take reasonable steps to verify a person’s identity before granting access or making corrections.
How to Contact Us
If you have questions, concerns or complaints regarding this Privacy Policy or the personal information that Shore has about you or that it may have shared to third parties, please contact us:
By mail: 218 – 3477 Lakeshore Road, Kelowna, BC V1W 0A7
By phone: 778.214.1536
By e-mail: live@theshorekelowna.com
Updates to this Privacy Policy
Shore may occasionally update this Policy and the new version will become effective immediately once posted to the Website. When we do so, we will update the “Last updated” date at the top of this Policy. It is your duty to ensure that you have read and understood the latest version of the Privacy Policy.
If we make significant changes to the Policy, we will post a more prominent notice on our Website. By continuing to use our services after the modified version of the Privacy Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements which may apply. If you do not agree to the changes to our Privacy Policy, it is your responsibility to stop using our services. We will not materially change this Privacy Policy in a way that makes it less protective of the personal information we have previously collected from you without notifying you.