PRIVACY NOTICE

This Privacy Notice is your guide to understanding how Hines Living (“we,” “us,” or “our”), handles your Personal Information.

Capitalized terms used in this Privacy Notice have the same meaning as defined in the applicable Data Protection Laws.

1. What Personal Information do we process?
   0. 1. In the context of this website
   1. Identifiers and contact information:  when contacting us, we collect your full name and e-mail address, and any further personal information you choose to share with us.
   2. Online identifiers: we collect online identifiers through cookies and other similar technologies that help us to offer you a better browsing experience, enhance site navigation, analyze site usage, and assist in our marketing efforts.
   3. Information you provide us through the website: we collect your personal information to enable specific features within the App. These include: registering visitors, when registering your presence at the office, booking a desk/room, registering a guest, requesting catering, requesting service, reporting facilities-related issues, etc.
      2. In the context of property management managing your application or residency

1. Contact information: full name, phone number, email address
2. Your date of birth, marital status and legal gender
3. Government issued information like SIN number and/or details regarding other documents of identification
4. Employment information: occupation and employment
5. Address information: both current and historic
6. Vehicle information
7. Pet information
8. Financial information: information on historic bankruptcy and income
9. Information about household members
10. Any information provided in communications

2. How We Use Your Personal Information

Your Personal Information may be stored and processed by us in the following ways and for the following purposes:

• To process rental applications
• To manage your tenancy and provide property management services
• To communicate with you regarding your application, tenancy and property-related matters
• To process rent payments and maintain financial records
• To conduct credit and reference checks
• To respond to maintenance requests and inquiries
• To investigate complaints
• To ensure the security and safety of the property
• To comply with legal and regulatory requirements
• to deal with your question or message sent through our contact forms;
• for ongoing review and improvement of the information provided on the website to ensure it is user friendly and to prevent any potential disruptions or cyber-attacks;
• to conduct the analysis required to detect malicious data and understand how this may affect your IT system;
• for statistical monitoring and analysis of current attacks on devices and systems and for the ongoing adaptation of the solutions provided to secure devices and systems against current attacks;
• to understand feedback on Hines Products and Services and to help provide more information on the use of those products and services quickly and easily;
• for in-depth threat analysis;
• to understand your needs and interests;
• for the management and administration of our business;
• to anonymize personal data and prepare and furnish aggregated data reports showing anonymized information;
• enforcing our terms and conditions or other legal rights;
• to comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
• for the administration and maintenance of databases storing personal data; or
• to improve our website and services

We process Personal Information in accordance with applicable laws. We will take necessary steps to ensure that the personal data is accessed only by authorized employees, representatives and service providers of Hines who have a need to access your Personal Information for the purposes described in this Privacy Notice, except as otherwise required or authorized by applicable law, and that, in any case, are subject to confidentiality obligations.

3. Cookies and similar technologies 

‍Cookies are small pieces of data being placed on the hard drive of your device. With the help of cookies, we can store information for a certain period and identify your device for the purposes mentioned below. These periods may vary depending on the type of cookies. Some cookies will be stored only for the time you are visiting our website (session cookie) and are automatically deleted once you close your browser, others cookies will be stored for a longer period than your session (persistent cookies).

On this website, we also use technologies that function similarly to cookies such as local shared objects. These are small data files that enhance your web-browsing experience, for example, by allowing you to personalize the look of a website that you frequently visit.

We transparently inform you about our use of cookies and similar technologies in the sections below. In case you would like to further understand more about these technologies, you can also set your browser settings to inform you about the cookies or similar technologies downloaded to your device.

• Strictly Necessary Cookies:

Strictly necessary cookies maintain website security, facilitate network management, ensure site functionality, and enhance accessibility. You have the option to disable strictly necessary cookies in your browser settings, although this may impact your website experience.

• Functional or Preference Cookies:

Preference cookies allow us to store specific user selections or preferences, leading to a more personalized website experience. These cookies are activated only with your consent. 

• Analytics:
  Statistical analytics gauge website performance and gather aggregated information on your site usage to optimize your digital experience. This method does not collect individual-level behavioral data. On European sites, these cookies are only active upon clicking “Accept.” Non-European sites allow you to opt out.”
• Marketing/Tracking/Profiling Cookies:

Marketing/tracking/profiling cookies, typically placed by advertising networks, deliver relevant content and assess campaign effectiveness. Information regarding website usage and visits may be shared with third-party organizations such as advertisers. These cookies are activated only with your consent.

• Conversational Cookies:

Conversational cookies link conversations and interactions to a specific visitor on our website, particularly when engaging with our chatbot. Accepting these cookies is necessary for interacting with the chatbot on our websites.

The table below sets out the type of cookie used, what its purpose is, and how long it lasts.

Cookie	Domain	Description	Duration	Type
__cf_bm	.prospectportal.com	This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.	1 hour	Necessary
_gcl_au	.twoparkcentral.com	Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.	3 months	Analytics
_ga_*	.twoparkcentral.com	Google Analytics sets this cookie to store and count page views.	1 year 1 month 4 days	Analytics
_ga	.twoparkcentral.com	Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.	1 year 1 month 4 days	Analytics
_ga_*	.twoparkcentral.com	Google Analytics sets this cookie to store and count page views.	1 year 1 month 4 days	Analytics
_fbp	.twoparkcentral.com	Facebook sets this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising after visiting the website.	3 months	Analytics

4. Social media plug-ins

We place various social media buttons on our website in the form of a plug-in. Following are the social media buttons used:

• Facebook
• Instagram

Please be aware that by visiting a website that integrates social media plugins, certain data (your current IP address, visited sites, the date and time the website etc.) is forwarded to these social media services even if you are not registered with these services. If you are already logged into the social media service when you click on the social media button, the social media service may also use this data to identify your username and possibly even your real name. We have no control over the extent, nature, and purpose of such data processing by the social media service. Please note that the social media service is perfectly capable of using this data to create pseudonymized and even individualized user profiles.

You can find further information about data protection regarding social platforms on the privacy policies provided by the social media platforms.

5. Third-party linked sites

Our website contains links to other websites, including social media sites, which may have privacy policies that differ from our own. We are not responsible for the collection, use or disclosure of information collected through third-party websites and expressly disclaim any liability related to such collection, use or disclosure. We are not responsible for any information or content contained on such sites. Links to other websites are provided solely as a convenience. Your browsing, use and interaction on any other websites, including websites which have a link to the Platform, are subject to that website’s own rules and policies. Please review the privacy policy posted on any website that you may access through, or which links to the Platform.

Please note that if you provide information to us via a social media site or participate in a social media site linked to the Platform, you consent to our use of your information for any reason in accordance with this Privacy Policy as if it were submitted to us directly via the Platform.

6. Sources from which we collect your Personal Information

We process personal information directly collected from you (e.g. through the application process), or collected by the property owner. In some circumstances we may collect personal information from other third parties in accordance with applicable law.

7. Sharing of Personal Information with third parties

In connection with one or more of the purposes outlined in the “How We Use Your Personal Information” section above, we may disclose your personal information to third parties such as our group members, our professional advisers, our external and internal service providers providers that need to access the information for the purposes of their duties and responsibilities to us. We are using special platforms to store, unify and process our consumer data with care and certified security.

We may disclose your personal information for the purposes set out above and only for specific purposes according to the relevant data protection laws. Those service providers are bound to process your personal data only on our strict instructions and when they can offer adequate technical and organizational measures to protect your data.

We may also disclose your personal information if it is required or authorized by law, where disclosure is necessary to prevent a threat to life, health or safety, or where we are otherwise permitted by the relevant data protection laws.

8. International data transfers

As a global company, Hines may need to transfer your Personal Information out of the country or jurisdiction in which it was originally collected. In such cases, Hines will ensure that there are adequate safeguards in place to protect your Personal Information with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Notice.

For transfer of Personal Information outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements, and Hines will take reasonable steps (for example through a contract with the overseas recipient) to ensure that the overseas recipient does not breach the applicable privacy laws in relation to the data. 

You can obtain more details of the protection given to your Personal Information by contacting us as described in section 14 below.

9. How we protect your Personal Information

At Hines, we take your security seriously. We've put in place strong measures to keep your information safe and secure. This includes special protection for client files, tailored to the sensitivity of the information they contain. We also have controls in our computer systems to restrict access appropriately.

Only authorized Hines employees have physical access to areas where Personal Information is stored or processed. We make sure our team members are trained to follow all laws and regulations, especially when it comes to data protection. Access to sensitive information is limited to employees who really need it for their jobs and who are authorized to see it.

If you want more details about how we protect your Personal Information, just reach out to us as described in Section 14 below. When you contact us about your file, we may ask for some Personal Information to make sure that only you or someone you've authorized can access your information.

10. How long we keep your Personal Information

We will retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected or to comply with applicable legal, regulatory, or internal policy requirements.

11. Modification of your choices and preferences

If you don't want to get marketing messages from us, no problem! You can opt out anytime by unsubscribing, sending us an email, or writing to us at the contact details listed in Section 14 below. If you receive an email from us about marketing stuff, just reply to that email and ask us not to send you any more marketing messages.

12.  Your rights

Where applicable and under the conditions set forth under applicable data protection laws, you may request the following rights concerning the processing of your personal information:

• access of the Personal Information we hold in relation to you and be informed about how we process it;
• corrections to your Personal Information where inaccurate or incomplete;

These rights are not absolute but subject to limits in applicable law.

If you have questions about how we process your Personal Information, please contact us in the first instance as described in Section 14 below and we will endeavor to deal with your request as soon as possible.

13. Changes in the Privacy Notice.

We reserve the right to revise this Privacy Notice at any time. In the event of any changes, we will update this posting. If we decide to use or disclose Personal Information differently from how it was originally collected, we will promptly inform you. If you object to these changes, please reach out to us using the contact methods detailed in the section below titled “Contact Information.”

14. Contact information.

If you have any questions about our Privacy Notice or wish to exercise your rights, please contact us at 888.928.6029 and corporate.counsel@hines.com. 1111 4th Street SW Calgary, AB T2S 1X2