Application and Scope
Personal Information We Collect
The personal information we collect may include:
- Identifiers, such as your name, IP address and unique identifiers;
- Government issued identification including without limitation social security number or social insurance number, driver’s license numbers, state or provincial identification cards or similar identifiers;
- Contact information, such as email address, home address, and phone numbers;
- Financial 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 including insurance information;
- Inferences drawn from any of the information listed above.
Means of Collecting Personal Information
We usually collect personal information directly from you, for instance when you interact with us as a tenant 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.
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:
- Tenants and Guests. We may collect the name, address, telephone numbers, email addresses, credit information, insurance information, government issued identification including without limitation social security number or social insurance number, driver’s license numbers, state or provincial identification cards or similar identifiers, financial banking information, employment information, insurance policy number and other information regarding insurance and photograph for access card purposes.
- Information provided through our Website. We usually 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.
- Phone Calls. We may record phone calls for quality assurance purposes.
- Employment Applications. 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 GWT.
- From Other Sources. In certain cases, we may collect personal information from other sources. In these cases, we receive your personal information from these other sources with your consent or if the law requires or permits us to do so. For instance, we may collect credit information about you from credit reporting agencies, with your consent, if you have applied for a lease.
- Information Collected Automatically. In some cases, we may collect information automatically. For instance, we may collect the following type of information:
- 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 (see below for explanations of these technologies). 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. The technologies we use may include:
- Cookies,which are small text files that are saved on your computer when you visit a Website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our sites.
- Web beacons,and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a Website or open an email. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
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.
We may use Google AdWords Remarketing to advertise GWT 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
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. We may also anonymize and/or aggregate personal information so that it no longer identifies an individual, and use it for any legal purpose.
In particular, we use your personal information as follows:
- to establish, develop and preserve our business relationship with you;
- to provide you with the services we offer, and ensure all related transactions are supported and implemented;
- to reply to your requests, inquiries and comments;
- to authenticate your identity and preserve your privacy when you contact GWT by telephone, electronic means or otherwise;
- to ensure our records are accurate and to protect you and GWT 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.
We collect personal information from guests to help us book reservations, process payments, provide customer service to guests, and keep in touch with guests after departure for the purposes of guest satisfaction reviews and future booking opportunities.
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’ and guests’ 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 GWT, 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 GWT as well as other career development resources.
Unless required or authorized by law, GWT will not collect or use personal information for any other or new purpose without obtaining further consent.
Sharing of Your Personal Information
GWT 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.
Links to Other Websites
Security of 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.
Retention of Personal Information
We only retain your personal information for the time period necessary to fulfill the purpose for which it was collected, unless authorized or required by applicable law.
We only retain your personal information as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once your personal information is no longer required, it will be securely destroyed, erased or anonymized (so the information no longer identifies you).
Your Consent and Right to Withdraw Consent
You can withdraw your consent for GWT to collect use and share your personal information at any time, subject to legal or contractual restrictions and reasonable notice by communicating with us using the information detailed under the section Contact Us. However, without such consent, GWT may limit the services it is able to provide you.
ADDITIONAL INFORMATION FOR EU DATA SUBJECTS
You also have the right to request that we delete your personal information.
We are not required to comply with your request to delete personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.
Right to restrict the processing of your personal information: You have the right to restrict the processing of your personal information in the following circumstances: (i) you contest the accuracy of the personal information; (ii) the processing is unlawful but you wish to restrict rather than prohibit the processing of your personal information; (iii) the purposes for processing your personal information no longer exist, but you require the personal information for the establishment, exercise, or defence of legal claims; or (iv) you have legitimately objected to the processing of your personal information and the processing is therefore restricted pending the verification of whether the legitimate grounds of the controller override your objection.
Please note that we may lawfully continue to process your personal information following a request for restriction:
- if we have your consent;
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to data portability: To the extent that we process your personal information (i) based on your consent or under a contract and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information: You can object to any processing of your personal information which is based on our legitimate interest (or those of a third party) if you believe your fundamental rights and freedoms outweigh such legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.