Last revised: August 7, 2019
Hullmark is committed to the proper use of personal information collected from our service providers, clients, tenants, and other business partners. The following document provides answers to questions you may have about the types of personal information we collect, how and why it is collected, used and disclosed, how it is protected, and how to contact us for more information.
From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
i) What is personal information?
Personal information means any information about an identifiable individual. This includes information in any form, such as age, name, contact information, identification numbers, credit/banking information, etc.
ii) What personal information do we collect and how is it used and disclosed?
We typically collect personal information directly from you when we interact with you. However, we may also collect personal information from third parties where we have obtained your consent to do so or as otherwise required or permitted by law.
Please see Schedule A which lists examples of the types of personal information we typically collect during our regular business activities and how it may be used and disclosed.
We may also transfer your personal information to third party service providers, where such third parties are assisting us with our activities - such as data storage or processing, whether in the United States or in Canada. However, you should note that to the extent that any personal information is out of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Officer as indicated below.
We may also make disclosures of personal information to a potential acquiror in connection with a transaction involving the sale of some or all of the business of Hullmark (in which case the use of your personal information by the new entity would continue to be limited by applicable law), or as otherwise permitted or required by law.
iii) How do we obtain consent?
We ask for your consent to collect, use or disclose personal information, except where our collection, use or disclosure of information is authorized or required by law. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask for consent in writing (by e-mail or by signing a consent form)
Consent to the use and disclosure of personal information may be withdrawn at any time on reasonable notice, unless the personal information is necessary for us to fulfill our legal or contractual obligations.
iv) Is my personal information accurate?
We take steps to help ensure that personal information we collect is accurate. We rely on our vendors, tenants, and other business partners to notify us if there is a change to personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for correction.
v) Is my personal information secure?
We have implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification and to help ensure that the only employees, who are granted access to your personal information, are those with a business ‘need-to-know’ or whose duties reasonably require such information.
We have implemented appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records. We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes or as required or permitted by law.
We take steps to help ensure that all affiliates and other third parties that are engaged to perform services on our behalf and are provided with personal information are contractually required to observe the intent of this Privacy Policy and our privacy practices.
vi) How can I access my personal information?
If you make a written request to our Privacy Officer below to review any Personal Information about you that we have collected, utilized or disclosed, we will take steps to provide you with any such Personal Information to the extent required by law. We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests or advise you in writing if we cannot meet your requests within this time limit.
At any time, you can challenge the accuracy or completeness of your personal information in our records by contacting our Privacy Officer. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will take steps to amend the personal information as required. Where appropriate, we will take steps to transmit the amended information to third parties having access to your personal information.
vii) Where do you keep my information?
We keep personal information that we collect either at our offices in Canada or at the offices of a service provider in the United States of America or in Canada. We may keep a record of your personal information, correspondence or comments, in a file specific to you.
viii) Have a question, request or complaint?
All comments, questions, concerns or complaints regarding your personal information, this Privacy Policy or our privacy practices, and all written requests for access to personal information or for the correction of information, be forwarded to our Privacy Officer as follows. Please direct all inquiries to:
Hullmark Asset Management
Attn: Privacy Officer
474 Wellington St W, Suite 200
Toronto, ON M5V 1E3
Phone: 416-510-1700
Email: privacyofficer@hullmark.ca