PRIVACY POLICY

By accessing or using the cadillacfairview.com website, you agree to the terms of Cadillac Fairview's Privacy Policy, as outlined below. If you do not agree to these terms, please do not access or use this site. Cadillac Fairview reserves the right to change its Privacy Policy from time to time at its sole discretion. Your use of this site will be subject to the most current version of the Privacy Policy at the time of such use.

Our Commitment to the Protection of Personal Information

We, at Cadillac Fairview, are committed to protecting the privacy of our customers and others with whom we do business. Personal information shall be dealt with in accordance with applicable privacy legislation in the jurisdictions in which we carry on business. For these purposes, “personal information” is any piece of information, either factual or subjective, about an identifiable individual. Personal information does not include the name, title, business address or telephone number of an employee of an organization.

Cadillac Fairview’s Privacy Policy

Cadillac Fairview’s Privacy Policy encompasses the ten basic principles of current federal privacy legislation. Cadillac Fairview will, from time to time, amend this policy as it considers it appropriate, or in accordance with applicable privacy laws.

Principle 1 • Accountability
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An organization is responsible for Personal Information under its control and shall designate an individual or individuals who are accountable for the Company’s compliance with privacy legislation.
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Cadillac Fairview has appointed a Chief Privacy Officer who is responsible for the Company’s compliance with privacy legislation. A privacy committee has also been appointed to assist the Chief Privacy Officer with the implementation of its Privacy Policy.

Cadillac Fairview employees are informed about the importance of privacy and are committed to upholding the Company’s privacy practices.

Principle 2 • Identifying purposes
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The purposes for which Personal Information is collected shall be identified at or before the time the information is collected.
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Cadillac Fairview collects personal information primarily for the purpose of providing a variety of services to its customers.

Whenever Cadillac Fairview collects personal information, it will identify how the information is to be used, at or prior to the time of collection. Cadillac Fairview will obtain an individual’s consent prior to using personal information for any other purpose than that identified.

Principle 3 • Consent
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The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.
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Cadillac Fairview will obtain an individual’s consent to the collection, use or disclosure of personal information at or prior to the time of collection. Cadillac Fairview will strive to ensure that individuals understand how their personal information will be used or disclosed.

Cadillac Fairview may collect, use or disclose personal information without an individual’s knowledge or consent in circumstances when such use or disclosure is required by court order, is in connection with enforcement of laws or contractual rights, or is in connection with an emergency involving a person’s life, health or security.

Consent may be expressed in writing or implied, and in some cases, it may be provided verbally, electronically, or through an authorized representative, provided such representative has the appropriate written authorization to do so.

An individual may withdraw his or her consent to the further use of his or her personal information at any time, subject to any legal or contractual restrictions, and upon reasonable notice to Cadillac Fairview. Upon request, Cadillac Fairview will explain to the individual any implications of withdrawing consent.

Principle 4 • Limiting collection
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The collection of Personal Information shall be limited to that which is necessary for the purposes identified. Information shall be collected by fair and lawful means.
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Cadillac Fairview will only collect information that is reasonably necessary for the purposes identified. Cadillac Fairview may request additional personal information, if appropriate in the circumstances, provided consent is first obtained. Cadillac Fairview will only collect personal information by fair and lawful means.

Principle 5 • Limiting use, disclosure and retention
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Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information shall be retained only as long as necessary for the fulfilment of those purposes.
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Cadillac Fairview will not sell personal information to third parties, neither will Cadillac Fairview use or disclose personal information for purposes other than those for which it was collected, without the express consent of the individual concerned, or as required by law. Cadillac Fairview may employ third parties to process some aspects of personal information on its behalf. In such circumstances, appropriate assurances will be sought to ensure the personal information is similarly protected by such third parties.

Cadillac Fairview has established guidelines and put procedures in place for the appropriate retention and destruction of personal information.

Principle 6 • Accuracy
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Personal Information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
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Cadillac Fairview will strive to ensure that personal information that is used on an ongoing basis, including information that is disclosed to third parties, and information that is used to make a decision about an individual is accurate, complete and up-to-date.

Principle 7 • Safeguards
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Personal Information shall be protected through security safeguards appropriate to the sensitivity of the information.
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Cadillac Fairview uses appropriate safeguards and security measures to protect personal information. Paper records are physically secured and access is limited to authorized personnel who are trained and aware of the requirements of the Company’s privacy practices.

Electronic files are similarly safeguarded by the limitation of access to authorized personnel and the use of appropriate electronic security devices.

Principle 8 • Openness
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Cadillac Fairview shall make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.
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Cadillac Fairview’s Privacy Policy is available to anyone upon request. Individuals are invited to contact the Chief Privacy Officer directly if they have any questions, concerns or complaints about privacy. Such requests should be sent in writing to the following address:

Chief Privacy Officer
The Cadillac Fairview Corporation Limited
20 Queen Street West
Suite 500
Toronto, ON M5H 3R4

Fax. No. (416) 598-8222

Principle 9 • Individual access
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Upon request, an individual shall be informed of the existence, use, and disclosure of his or her Personal Information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
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An individual may request access to his or her personal information. Requests for access should be made in writing to the Chief Privacy Officer at the address provided above and should include satisfactory identification and proof of entitlement. Cadillac Fairview will respond to such requests within the time period prescribed by law.

If an individual’s personal information is inaccurate or incomplete, Cadillac Fairview will make the appropriate amendments, based on the receipt of satisfactory evidence.

In certain circumstances, Cadillac Fairview may be unable to provide access to personal information. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege. The individual may then choose to challenge the decision.

Principle 10 • Challenging compliance
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An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for Cadillac Fairview’s compliance.
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Cadillac Fairview will investigate all complaints and respond within the time period prescribed by law. If a complaint is found to be justified, Cadillac Fairview will take prompt and appropriate measures including, if necessary, amending its Privacy Policy or practices relating to the handling of personal information. In the unlikely event that a complaint cannot be resolved satisfactorily, the complainant will be advised of further complaint procedures that may be available to them.