Last Updated: July 30, 2021
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. For disclosures and ways to exercise your data access and other rights specific to the EU, UK, Australia, Canada, Dubai, and Brazil, see Sections 7-11, or click here.
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, including, for example, building managers, real estate brokers, and service providers) 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 and Other Identifiers. For example, we might collect your name, email address, account username and password, alias, government-issued ID (including, for example, driver’s license and passport), social media account handles, phone number, date of birth, government ID numbers (including, for example, tax ID number, Social Security number), and mailing address. At our security desks, for example, we might also collect information from your driver’s license, photos, or other identification documents you provide.
We collect Commercial, Customer Records, and Preference Information. For example, we may collect information about your purchase history, retailer preferences, leasing details, apartment rental history, property records, tenant data, signatures, 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 collect information at the site you came from, or the site you visit when you leave us. We may collect and record page and app interaction information and other electronic communications and content from your use of the site and app (such as content entry, mouse movements, screen captures, the date, time, and location of your visit, what areas of the websites you visit and for how long, what search terms or other data you enter, and what products or content or links 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 may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may also collect information from your devices if they connect to, or are detected by, the wireless networks at our properties. 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 may engage or otherwise permit other parties to also collect information in these ways.
We collect Location Information. We may automatically collect your precise GPS location when you access our apps or our websites. We may also automatically collect your precise GPS location 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, sex, gender, birth date, age, language spoken, disability, housing status, household size, household type, family members, marital status, annual household income, desired housing characteristics and desired housing location or community.
We collect Payment Information. For example, we collect your credit and debit card, bank account information, and other payment details if you make a purchase or sign up for or through some of our services.
We collect Employment-Related and Education 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 capture or collect photographs and record audio and video at the property (including through the use of CCTV cameras and other technologies). We may also collect information using magnetometers, infrared and heat sensing technologies at certain properties. We may also record audio during customer service calls. At certain properties in select locations, we may use image and video analytics technologies including on digital signage. For example, we may use these technologies to help us understand general demographics information, general shopping patterns, and how visitors engage with and react to advertisements.
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 collect Information You Submit, Provide, or Post. For example, we collect feedback and any other information you provide when you contact us.
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 our services and fulfill transactions. For example, we use information in connection with the management, operation, leasing, acquisition, and divestiture of real estate holdings, developments, and properties. We also use information to fulfill your requests and provide you with products and services.
We use information for marketing purposes. For example, we might use personal information in connection with 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 apps 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 Section 5 below.
We use information to test, develop, analyze, improve, and provide our products, properties, and services. For example, we may use your information to make our websites, apps, services, properties, 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 also use personal information when onboarding vendors.
We use information for security, safety, compliance, and due diligence purposes. For example, we may use personal information to protect our company, properties, customers, business partners and their respective personnel. We may also use personal information to protect our websites, apps, or services, as well as to detect and investigate activities that may be fraudulent, or otherwise illegal or prohibited (such as cybersecurity events or fraudulent transactions). We may use information in connection with physical access control. 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 where permissible by law.
SECTION 3. We collect personal information about you from various sources.
We and our vendors 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. When you visit certain properties, we may collect video or image information about you using cameras and sensors.
We receive personal information from vendors we hire to work on our behalf. For example, vendors that host or maintain our websites and apps or 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 clients, tenants, 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 email@example.com.
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 and turning off the Bluetooth and Wi-Fi. To learn more about mobile location analytics and certain options with respect to mobile location analytics, visit https://smart-places.org.
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 of 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 firstname.lastname@example.org 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, gender, and disability); 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 and Section 3 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 email@example.com or by calling us at (855) 834-8394.
SECTION 7. Your EU and UK Privacy Rights.
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 process your personal data if it is based on our legitimate interests. For example, we may process personal data in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of our products, services, and platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud. 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 a supervisory data protection authority. If you are a UK resident, 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. You can submit a request regarding your personal information online by clicking here or by emailing us at firstname.lastname@example.org. 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. You can submit a request regarding your personal information online by clicking here or by emailing us at email@example.com.
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,
submit a request online by clicking here, email us at firstname.lastname@example.org, 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. Your Privacy Rights under Brazil Law.
Pursuant to article 18 of the LGPD, residents of Brazil and those that have had their personal data collected and/or processed in Brazil by Brookfield Properties Brazil have the following rights regarding personal data (each of which may be subject to various exceptions and limitations):
- Confirmation of the existence of processing: you have the right to confirm the existence of any processing of your personal data.
- Access to personal data: you have the right of access to your personal data and obtain information about yourself.
- Correction of incomplete, inaccurate or outdated personal data: you have the right to keep your data updated and corrected.
- Anonymization, blocking or deletion: you have the right to request any of such options whenever there is unnecessary or excessive processing of your personal data, or processing of your personal data in violation of the provisions of the LGPD.
- Portability of personal data: you have the right to obtain your personal data in a structured condition, so that it can be transferred to another service provider, supplier, or data controller.
- Deletion: you have the right to delete your personal data processed pursuant to a consent, except in case of legal or regulatory obligation which allows the processing or transfer to third parties or in case of data anonymization for exclusive use of the controller.
- Information on sharing of personal data: you have the right to know which public and private entities with which your personal data has been shared.
- Denial of consent: you have the right to refuse any consent requested from you, and to be informed about the consequences of such denial.
- Withdrawal of consent: you have the right to withdraw the consent any time.
Any request made pursuant to the above may be made online by clicking here or via email to email@example.com (all Brazil requests will be routed to the Brazil Data Privacy Officer). All requests will be processed within a reasonable term provided for by the LGPD and other regulations. For the fulfillment of the request for access and/or confirmation of existence of processing of your personal data, the response time may take up to15 days, commencing upon the confirmation of your identity.
SECTION 12. 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”), the United Kingdom, 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 and the UK government to be not adequate when compared to the data protection standards of the EU, EEA and the United Kingdom. By using our websites, apps, and services or submitting your personal data, you consent to such transfer, storing and processing.
SECTION 13. 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 14. We use standard security measures.
SECTION 15. We may link to third-party sites or services we don’t control.
SECTION 16. Feel free to contact us.