Privacy Policy

BROADVIEW WEBSITE PRIVACY POLICY

CASL

By providing your contact details, you consent to Bosa Properties Inc.and their respective current and future affiliates and subsidiaries contacting you regarding their current and future products and services, event invitations, newsletters, announcements, promotions, incentives, and other publications. Rest assured that none of this information is sold or distributed to any other parties. You may withdraw consent at any time.

Please read the following carefully before using our website, portal or application.

Bosa Properties Inc., and its parents, subsidiaries, related companies and affiliates (collectively, “BPI”, “we”, “our” or “us”) have published this privacy notice (this “Notice”) to tell you about how we collect, use, disclose and store personal information when you apply for a job with BPI or access our on-line services, including our websites, online customer portal and rental services (collectively, our “Services”). This Notice is also supplemental to our residential tenancy agreement and Services includes BPI’s activities in relation to the tenancy including administration, operation, enforcement and management of the tenancy and BPI’s properties. Please refer to our website and portal Terms of Use, which incorporates this Notice and describes the BPI entities and our websites.

We think transparency is important, but providing that transparency requires us to make this Notice longer than we would like. That is why we have set out the highlights of this Notice in brief summary form here, with the details following below.

Summary Highlights of this Notice

Realtors: Most information we collect about you is business information, not personal information. We use this to support and better understand our realtors and their clientele, so we can provide and improve our Services.
Clients of Realtors – Prospective Purchasers: We may obtain your personal information from realtors that use our Services to help you find and purchase or rent a property, and use that information for the purpose it was provided, including contacting you about properties of interest. We recommend you contact them with any complaints, questions or requests about their provision of your personal information to us. In some cases, you may provide your personal information directly in relation to an offer or opportunity.
Tenants / Rental Applicants: We collect personal information you provide to us directly, such as your contact information, employment information and any supporting financial information, and information collected automatically through cookies and similar tools. We may collect information from third parties in respect of your application with your consent. We will also collect information about you during the course of your tenancy. We use this to evaluate your rental application, manage our relationship with you as a tenant, security and provide and improve our Services.
Website / Online Customer Portal Users: We collect personal information you provide to us directly, such as your email address, and information collected automatically through the portal, via cookies and similar tools. We use this to manage your account in the portal, support and better understand our users and provide and improve our Services.
Employees / Contractors / Job Applicants: If you apply for a job with BPI, we collect and use your personal information to consider hiring you. If we hire you, we will use your personal information in connection with your employment. A separate privacy notice may apply to employees.

Application of This Notice

This Notice applies to all personal information that we collect, use, disclose in relation to our Services and when you apply for a job with BPI.

What Does this Notice Not Cover?

Information Controlled by Realtors: As mentioned above, we sometimes obtain personal information from third parties, including realtors, on the basis that they have authority to share the information and use that information for the purpose it was provided, including contacting you about properties of interest. We are not responsible for how your agent may handle your personal information. We recommend you direct any complaints, questions or requests about how they handle your personal information to them. If you have questions about the information they have provided to us, you may Contact Us directly.
Non-Personal Information: Information about your business, including your business contact information, is not typically personal information. Anonymized and de-identified information is also not considered personal information for the purposes of this Notice. We may anonymize any personal information in our custody, in which case it will cease to be personal information.

In some situations, we may rely on exemptions or other permitted conduct under applicable laws, including to collect, use, disclose or store personal information for purposes not described in this Notice. We provide our Services to realtors and users in many jurisdictions and privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions. If you are unsure if or how this Notice applies to you, Contact Us.

Changes to this Notice

We may update this Notice from time to time by posting a new version of the Notice on our websites. Our collection, use, disclosure, and retention of your personal information will be governed by the version of the Notice in effect at that time. Please review this Notice periodically to see whether it has been updated. Any use of our services by you after we provide notice constitutes your acceptance of those changes.

Collecting Your Personal Information

What Personal Information Do We Collect Directly?

We collect personal information through our Services when you voluntarily provide it. Examples include when you complete the “Contact Us” form, or other similar forms, on our websites for general inquiries or newsletters, when you email us for information about our projects, when you chat with us, when you create an account and interact with our portal, when you purchase a property or when you submit a rental application. We collect the personal information to provide you with the information or service that you have requested.

When you access our Services, we may ask you to provide personal information such as your name, e-mail address, mailing address, telephone number and other information necessary to provide you with our Services. Additionally, we may ask you for your real estate preferences such as the type of home you may be interested in and your reason for buying or renting (e.g. first-time home buyers, downsizers). We may also ask you if you want to complete a survey asking about your budget range, reason for buying or renting, type of home interested in, etc. Our surveys will explain how we intend to use the information you provide us in response. At the time we ask you to provide personal information, you may choose not to provide certain details, but this may affect your ability to access related Services.

What Personal Information Do We Collect Automatically?

When you access our Services, we may automatically collect non-personally identifiable information. For example, we use the following technologies:

Cookies: Our Services use “cookies” to track user activity on our websites. Cookies enable our Services to save and retrieve information that you enter. A cookie is a commonly used piece of software that tracks your visits and preferences, and is capable of enhancing your use of our Services. It may remain on your computer after you exit the Services (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser, however, disabling cookies may affect your ability to access certain Services. You can read about cookies at allaboutcookies.org.
IP Address Tracking: Our Services obtain your IP address, web browser and operating system you are using, the date and time of the visit, the sections of our Services you access, as well as the pages read and the images viewed, and certain content that you download from our Services. We may collect visit information related to data such as IP address, device information, and browser information for activity across our websites, including timestamps of pages visited, and click-through as an anonymous user. We do not link any of the above information with other information about you, such as account or rental information. We collect this data for a number of reasons, including to understand the traffic on our Services, how our Services are used, and how we can improve them. For example, the information about our visitors’ browsers tells us what kind of browsers we need to support. Other information lets us know how many visitors visit our Services and what sections are the most popular. We do not share this aggregate data with third parties except for the possible use of web analytics companies as described below.
Web Analytics: We use third party analytics companies and remarketing tools, such as Google Analytics and Google Ads remarketing, to track and analyse your use of our Services and to improve your online experience. This data is used for aggregate reporting purposes. None of this data is used by us or our service providers to identify you. These third party analytics companies may use cookies and other tracking technologies to perform their Services. To learn more about Google’s privacy practices, including how you can view and edit your preferences regarding Google Ads, please see the Google Privacy Policy at policies.google.com/privacy. You can find the instructions for opting-out of Ads Personalization at policies.google.com/technologies/ads.
Web Beacons: We use web beacons such as Facebook Pixel to track how you interact with our Services, such as the pages read and the images viewed.
“Do Not Track” (DNT) Signals: Although we would like to honor browsers set with DNT signals, at this time, our Services do not respond to DNT signals or other mechanisms that might enable users to opt out of IP address tracking. For more information about DNT signals, please visit allaboutdnt.com.

Social Interactions

When you choose to share information or content through our Services, we may also collect this information. Anything you share or link through social media accounts or through interactive or social aspects of our Services, including “favorites” or other content, will not be private. We may use and disclose the social information you provide for purposes as described in this notice.

Using Your Personal Information

How Do We Use Your Personal Information?

Much of the personal information we use is necessary to fulfil the purpose for which it was originally collected (or for a use consistent with that purpose) or to meet our legal or contractual obligations. We will often rely on express, deemed or implied consent, such as when you provide us with your information for an obvious purpose (e.g. an application form) or when use would be reasonable in the circumstances and you have an opportunity to opt-out of such use (e.g. to prevent fraud or other purposes set out in this Notice). In the latter case, we rely on you to review this Notice and contact us if you have any questions or concerns. We also may rely on a legal exception to the consent requirement.

We may use personal information for a variety of purposes, including the following:

To contact and correspond with you regarding your use of our Services;
To send you information about our Services and products, including project updates and announcements, event invitations, promotions, incentives and other information that we think may interest you, and for other marketing purposes;
To respond to specific requests and inquiries from you, including to provide you with our Services and products that you request such as our newsletters, project information and publications;
To facilitate, monitor, and gauge engagement in our Services such as the social interaction and user generated content aspects of our portal;
To consider a job or rental application;
To administer and manage your accounts with us, including your account for the portal;
To respond to service requests and to schedule service calls and fulfill service requests;
To manage our business, including managing our properties, managing rentals and for purposes related to property sales;
To process suggestions and comments provided by you;
To improve our Services;
To measure interest and engagement in our Services and potential offerings;
To administer our Services and protect the security of our Services when necessary;
To facilitate such other Services and activities as we may identify at the time;
To investigate a breach of the law, any terms of use of our Services, including the websites and portal; and
To meet legal and regulatory requirements.

We may request express consent for purposes at the time of collection. These purposes may or may not be included in this Notice in some circumstances.

In addition to the uses described in this Notice, BPI may provide supplementary notices, such as to residents and visitors regarding collection, use and disclosure relevant to a particular property. Those notices may be posted or distributed by various means to tenants or in the property and will be applicable in conjunction with this Notice. BPI may rely on your implied consent on the basis that you have a reasonable opportunity to opt-out of such collection or use.

We will sometimes de-identify or de-personalize information, such as through anonymization or aggregation. We may use and disclose such information for any purpose, as it will no longer identify you or any other person.

Sharing Your Personal Information

With Whom Do We Share Your Personal Information?

We share your personal information with our employees, contractors, consultants and other parties such as affiliates and third party companies that assist us in providing our Services, including marketers, customer support and hosting services. We will also share information between BPI affiliate companies and entities for the purposes of managing our business, providing you with Services and as described in this Notice.

Below is a non-exhaustive list of the service providers with which we may share personal information.

Service Providers	Purpose
Marketers and Advertisers	Provide you with news and marketing, including customizing our advertisement and creating lookalike audiences for BPI using tools such as Google Ads’ audience targeting tools and Facebook’s Lookalike Audiences.
Tenant Services and Building Amenities Partners	Affiliates and partners who may provide and inform the Tenant and applicable occupants of products and services that may be related to or a benefit to or of the tenancy. For example, such services may include but are not limited to special concierge, transportation, communications, health, fitness and tenant insurance. The partners may vary for each building.
Customer Support and Customer Relationship Management	Track your service issues, review and consider job or rental applications, improve our Services, provide answers and solutions to your queries and concerns and manage our relationship with you. For example, Freshdesk is our helpdesk platform provider, Yardi and Salesforce help us organize and analyze customer relationship information, and Pardot automates our marketing system and webforms. Certn assists us with checks related to our tenancy applications.
Hosting and Similar Service Providers	Help us provide our Services, manage digital content and store data. AWS hosts our data back-ups in Canada.
Platform Service Providers	Help us provide our Services and manage our online customer portal and rental applications and services. For example, Avesdo, provides the online customer portal, Sitecore is the content management system for our websites, Building Stack helps us with our residential properties listings, and Findspace helps us list commercial properties.

The service providers with which we may share personal information are only provided the limited amount of information required to perform their services. When we use service providers, we will require the service providers to protect your personal information in accordance with applicable law and with the same or more stringent security and privacy standards than us. Any such sharing of your personal information to a service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.

To Whom Do We Disclose Your Personal Information?

We may disclose your personal information to certain third party recipients. When we disclose your personal information, the third party recipient’s policies and procedures will apply. Where required by law, we will obtain your consent before disclosure. Below is a non-exhaustive list of the third party recipients to which we may disclose personal information.

Recipient	Purpose
Third Parties Acquiring or Proposing to Acquire one or more BPI entity	To assist third parties acquiring or proposing to acquire all or a substantial part of our operations or any of our affiliates or subsidiaries, including by merger or acquisition, amalgamation, corporate reorganization or restructuring or a sale of assets, including as part of due diligence.
Law Enforcement / Legal Proceedings	To comply with applicable laws or regulations, enforce our policies, or protect our or others’ rights, property or for safety, where we believe disclosure is appropriate. For example, we may disclose your personal information to enforce our rights, comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel or auditors.
Regulatory and Taxation authorities	To comply with our obligations to provide information to governmental authorities, regulators, and tax authorities.
FINTRAC	To comply with our requirements to collect and disclose information for the purposes of detection, prevention and deterrence of money laundering and the financing of terrorist activities.

International Transfers of Personal Information

The organizations affiliated with BPI are primarily based in Canada. Some BPI entities are located in the United States of America. As described above, we may share personal information among BPI entities in the course of managing our business or in providing Services to you. We may also share your personal information with service providers both in and outside of your country as described above. As a result, your personal information may be collected, used, disclosed or stored outside of your home country, including in Canada and in the United States of America. Laws relating to privacy vary between countries, and your personal information may be processed in a country with laws less stringent than the laws in your country. Your personal information may be accessible to governments, courts, or law enforcement, national security authorities and regulatory agencies of these countries in accordance with applicable laws. If you have any questions about BPI’s policies and practices with respect to service providers outside of Canada, you can contact our Privacy Officer at the contact information listed at the end of this Notice.

Exercising Your Rights in Respect of Your Personal Information

Depending on where you are located and subject to applicable laws, you may have the right to request to access, correct or erase your personal information, object to our processing of your personal information, request restrictions on the use of your personal information or withdraw or change your consent to how we process your personal information. Depending on the circumstances, your rights may be restricted or exercise of them may mean we are not able to provide a Service to you. You may inquire about your rights and exercise them by contacting our Privacy Office: Contact Us.

As a security measure, our Privacy Office may request specific information from you in order to verify your identity prior to granting any requests. If we cannot respond to your request promptly or have to refuse the request, we will advise you of the reasons, subject to any legal restrictions. If you disagree with our determination, you may complain to us and we will reconsider. If you are not satisfied with our ultimate determination, you may contact your local data protection authority or privacy commissioner. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

If you want to designate someone to exercise your rights on your behalf, please send your designation request using the email associated with your account, if you have one, or that you have otherwise provided to BPI. We may not otherwise be able to verify your identity or authorization.

Where permitted by law, we may refuse repeat, abusive or inappropriate requests. In some circumstances, we may also charge a reasonable fee for access to your personal information.

Retaining Your Personal Information

We store personal information as long as reasonably necessary to fulfill the purposes for which it was collected, to conduct our business operations and maintain an appropriate historical record of our relationship with you, as permitted by law, or in order to comply with applicable laws, whichever is longer. We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with, or tracked back to, you.

Securing Your Personal Information

We take reasonable steps to protect your personal information. We use safeguards to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information. These safeguards are intended to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. However, the internet is not a secure environment and no computer system is perfectly secure. As such, we cannot guarantee the security of personal information provided to us through electronic means: there is always a risk that your personal information may be accessed or used without authorization.

You may be required to create an account with BPI in order to access certain of our Services, such as the online customer portal. You are responsible for maintaining the confidentiality of your account login information and will not use the account login information of any third party or disclose your account login information to any third party. You are responsible for all activities, charges and liabilities made on or through your accounts with BPI, whether authorized or unauthorized by you and should take steps to protect against unauthorized use of your account by, for example, choosing a robust password. If you suspect any unauthorized use with any account or any use of account login information, you must Contact Us immediately.

It is your responsibility to provide any updates to your personal information to us in writing.

Contact Us

If you wish to make a complaint about how we have handled your personal information, or have any other questions or any other privacy-related concerns, such as requests to withdraw consent, access our records of personal information or to change or erase personal information, please contact our Privacy Office here or by using the details below.

Privacy Office
Address: 1201 – 838 West Hastings Street,
Vancouver, BC V6C 0A6
Telephone: 604-416-0097
Email: info@bosaproperties.com

Last Revised: December 2023