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Privacy Policy

Last Updated: September 23, 2024

1. Introduction

BGO is a leading, global real estate investment management advisor and a globally recognized provider of real estate services. BGO includes BentallGreenOak (Canada) Limited Partnership, BentallGreenOak (U.S.) Limited Partnership, their worldwide subsidiaries, and the real estate and commercial mortgage investment groups of certain of their affiliates, all of which comprise a team of real estate professionals spanning multiple legal entities. This Online Privacy Policy ("Policy") applies to the BGO group of companies. This Policy explains how we comply with local laws and regulatory requirements in the jurisdiction we operate in.

BGO is committed to protecting the privacy of all personal information or data entrusted to it.  This Policy describes how BGO collects, uses, retains, discloses, and protects personal information, including any data you may provide to us through your use of this website or other BGO websites or mobile or web applications. This Policy supplements any other privacy policy or fair processing notice that BGO may have provided to you on specific occasions and is not intended to override them. It is important that you read this Policy together with any other privacy policy or fair processing notice, so that you are fully aware of how and why BGO uses your personal information.

If you are a California consumer, you may have additional rights under the California Consumer Protection Act (“CCPA”), as detailed in the California Consumers section. If you are in the European Union, you may have additional rights under the General Data Protection Regulation (“GDPR”), as detailed in General Data Protection Regulation section. 

2. What is personal information

Personal information or personal data (“personal information”) means information about an identifiable individual. This includes factual or subjective information, recorded or not, that can be used, either alone or in combination with other information, to identify an individual. It also includes data points that when combined with other information could identify an individual. It doesn’t include information about an individual that is publicly available. It also does not include aggregate or anonymous data that cannot identify an individual. 

3. What personal information we collect

BGO collects personal information from individuals, for example, from customers, clients, tenants, suppliers, service providers, employees, or other individuals. BGO collects personal information that’s necessary to deliver products and services, enhance your experience and interactions with us, manage our business operations and fulfil our legal, regulatory and security obligations.

Depending on your products, the services you use, or your interactions with us, the personal information we need may includes:

  • contact information - such as your name, mailing address, email address, phone number
  • demographic information - such as your age, employment details, marital status, beneficiary information, nationality
  • health information - such as your lifestyle information, health, and medical history
  • financial information - such as contributions, investment funds and accounts, retirement goals, source of income, intended use of account, risk tolerance, credit score and credit report from credit rating agencies
  • identifiers - such as bank account numbers, government issued IDs or other personal identifiers
  • supporting documents - such as tax slips, bank statements, identity verification documentation, proof of relationship, power of attorney
  • information about your interactions with us - such as your consents, survey responses, call centre interactions, complaints
  • employment and job application information or lease application information - this may include some of the information described above, as well as background checks, letters of reference and any additional information provided by you in a job or lease application form
  • Information collected automatically using automated means, further described below
  • Information collected from third parties and other sources, further described below

Children’s personal information

BGO does not knowingly solicit or collect any personal information from or market products and services directly to children under the age of majority. BGO’s products, service and website(s) are for those who are over the age of majority. We would only collect information about children from parents or legal guardians when they are covered under their agreements, leases, policies, or assigned as beneficiaries, for example.

If you are under the age of majority, please do not submit any personal information to us. If BGO is notified or discovers that a child under the age of majority has submitted personal information to us, we will take reasonable steps to delete the information.

4. How we collect personal information

BGO may collect personal information directly from an individual, through automated means, or from third parties or other sources.

Directly from an individual

BGO collects personal information you provide directly to us when you communicate with us in person, by mail, through email, over the telephone, through our websites or in any other direct manner, for instance when you sign an agreement, apply for a lease, participate in a survey, consent to receiving marketing or commercial-related communications, submit a job application, or upload content to our websites.

Through automated means

BGO or our service providers may collect automatically information using automated means when you contact us over the phone, interact with our websites, or visit our managed properties or office locations. This may include the following types of personal information:

  • Technical information when you visit or use a BGO website. We may automatically collect, for example, your phone number, internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites to manage and improve our operations.
  • Video surveillance and recordings to protect you, our tenants, employees and other individuals who visit our managed properties or office locations, and to maintain the security of these locations.
  • Audio equipment and recordings when you contact us by phone or through other electronic means we may use audio recordings for quality assurance and training purposes. We will inform you before any call is recorded.
  • Cookies, pixels and similar technologies when you visit or use a BGO website. We use this information to understand how our users interact with our websites to improve the display and content of our websites. We may also use this information for advertising purposes. To learn more about our use of these technologies and how to manage your preferences, please see the “Cookies and Similar Technologies” section below.
  • Electronic access card or key fob information if used when you access our managed properties or office locations.
  • Information generally transmitted by mobile devices, such as, for example, an international mobile equipment identifier (“IMEI”) or media access control (“MAC”) addresses. 

From third parties or other sources

BGO may receive personal information about you from third parties or other sources. This may include, for example, from your former and present employers and landlords, personal references, financial institutions, services providers or other professional advisers. In these cases, we collect your personal information from third parties or other sources only if we have obtained your consent to do so, if you provided your consent to the third party, or if the law requires or permits us to do so.

Also, BGO may collect information from publicly available sources, such as LinkedIn or any similar professional or recruiters’ websites or online platforms.  

5. How we use personal information

Here are some examples of how we may use your personal information in connection with you or your business:  

Delivering products and services

  • manage accounts and provide administrative support
  • understand needs and suitability of our products
  • process applications and transactions
  • manage investments and payments
  • provide updates on accounts, products and services
  • investigate complaints and respond to inquiries

Enhancing experience and interactions

  • personalize and improve the experience while using our websites or online platforms
  • better understand interest in our products and services
  • enable the use of online tools
  • deliver targeted and personalized marketing
  • display customized preferences (language, time zone, etc.) on our websites or online platforms 

Managing our business operations

  • analyze and improve internal business processes
  • develop products and services
  • determine the effectiveness of marketing and advertising
  • evaluate and improve the functionality of our websites or online platforms
  • measure engagement and gain a better understanding of behaviours on our websites or online platforms

Fulfilling security and legal obligations

  • confirm identity to make sure no one else is accessing information without authorization
  • enhance digital security including preventing and detecting security threats and unauthorized activities
  • implement risk management programs and procedures to protect against fraud, errors or misrepresentations
  • meet regulatory or contractual requirements, such as financial and regulatory reporting
  • enable financial institutions and service providers to meet their regulatory obligations

We may need to use your personal information in other ways, as required by law. If we need to use your personal information for any other purposes, we will do so only with your consent where it is required.

We may analyze data collected through automated means to evaluate and improve your digital experience. We may collect this personal information directly or indirectly through third parties. We may also share aggregated, anonymous data with third parties. This data cannot directly identify you. We may combine some of the data we collect through automated means with other data we have about you for analytics. 

6. How we retain personal information

BGO maintains policies and practices governing the retention and destruction of personal information in its possession or custody. We retain your personal information for as long as it is necessary to fulfill the purposes for which it was collected or used and to comply with applicable laws. After the personal information is no longer necessary either for the purpose for which it was collected or to comply with any laws, it will be destroyed or made anonymous in accordance with applicable legal requirements.

7. How we share personal information and with whom

We are responsible for protecting the confidentiality of all personal information in our possession. That includes information transferred to third parties performing services on our behalf such as our agents, service providers or our affiliates. Unless prohibited by legal or contractual requirements, we and some of these third parties may store or process your information outside the jurisdiction where it was collected. In those cases, we follow all local laws, and the processing of your personal information may be subject to the laws of those other jurisdictions. We always require that these third parties protect your personal information consistent with our privacy policies and practices and comply with relevant laws.

In respect of personal information disclosed to third parties, BGO takes appropriate steps, where permitted by law, to ensure that such third parties use the personal information only in connection with the purposes for which the information was collected and safeguard the personal information against unauthorized use or disclosure.

In some cases, laws require us to share information with regulators or government agencies.

BGO Affiliates

BGO affiliates in Canada, the United States and internationally may share personal information with each other and use it for the purposes described in this Policy. This allows BGO and each entity within the group to comply with applicable laws, regulations and requirements and ensures that your information is consistent, accurate and up to date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with BGO through easier access to your information within the group.

Service Providers

In the course of providing our services we may share your personal information with third party service providers who perform services on our behalf. These service providers help us operate our business and improve the services we offer to you. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and require that those third parties adhere to confidentiality as well as security procedures and protections.

Examples of third party service providers with whom BGO may share your personal information include:

  • Cloud hosted digital solutions and advanced technologies;
  • IT support, security and consulting services;
  • Employee workforce management systems and services;
  • Lawyers; regulators or government agencies;
  • Credit reporting agencies;
  • Tenant service response systems;
  • Financial institutions, in connection with employee, fund, property, tenant, client or investor financing arrangements;
  • Data processing, fund or investor administration, facilities management, call centre operations, mail-out and building maintenance providers;

Other Permitted Reasons

In certain circumstances we may share personal information without your consent and when authorized by law to do so, such as to comply with a warrant or other order from a court or a governing regulatory authority; to investigate the breach of an agreement or applicable law (for example, investigating potential theft); and when required in the context of a prospective or completed business transaction, such as a transfer of assets or shares or merger.

In these circumstances, we will not share more personal information than is reasonably required to fulfill that particular purpose.

With your consent

We may also share or disclose your personal information when we have your implied or express consent.

8. How we manage consent

The collection, use or disclosure of your personal information by BGO requires your knowledge and consent. At certain times, your consent for the collection, use and disclosure of your personal information may be implied from the manner in which it is collected. For example, when you provide BGO with your personal information in connection with a lease, you have implicitly consented to BGO collecting, using and disclosing your personal information in a manner necessary to determine your suitability for, and administer, your lease.

You may also expressly provide your consent. If BGO collects, uses or discloses personal information for purposes other than those described above, prior to the collection, use and/or disclosure of such personal information, unless required to be disclosed by law, you will be informed of and your consent obtained prior to BGO's collection, use and/or disclosure of that personal information. If BGO intends to use and/or disclose personal information that BGO previously collected for a new purpose which is not authorized under applicable laws, your consent will be obtained before BGO uses and/or disclose it for that new purpose.  

You may always choose not to supply BGO with your personal information. Furthermore, previously granted consent may be withdrawn at any time (subject to certain legal or contractual restrictions) by notifying the Privacy Officer in writing. Keep in mind that by withdrawing your consent (in whole or in part) to our collection, use or disclosure of your personal information, we may no longer be able to provide you with the services you requested.  

9. How we protect your personal information

BGO will protect your personal information in a manner that is consistent with and appropriate to the sensitivity of that personal information. For example, we employ physical safeguards (such as the use of locked cabinets and storage facilities), technical safeguards (such as the use of passwords and encryption), and organizational safeguards (such as installing access controls and limiting access to need to know employees) to ensure your personal information is protected while it is under our care. We also use contractual measures to protect any personal information disclosed to third parties outside the jurisdiction where you reside.

Data Governance and Security Measures

BGO maintains policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information, including:

  • Internal policies and procedures that define the roles and responsibilities of our employees throughout the information life cycle and limits their access to such information on a “need-to-know” basis;
  • If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures;
  • A designated Privacy Officer to monitor BGO’s compliance with applicable data protection laws;
  • Privacy impact assessments (“PIAs”) for new business initiatives and significant changes to processes that pose a high risk to the privacy of individuals.
  • Employee privacy and data security training;
  • Procedures for receiving, investigating and responding to complaints or inquiries regarding BGO’s information handling practices, including any security incidents involving personal information;
  • Framework governing the retention and destruction of personal information;
  • Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate privacy protections and standards. For example, we generally require our service providers to notify us in case of any actual or suspected security incident. We also try to monitor and audit their compliance with these requirements in various ways.

BGO undertakes to use reasonable efforts to maintain the accuracy, completeness and currency of your personal information that is held by BGO as is necessary to fulfill the purpose for which it was collected and is to be used. BGO may, from time to time, ask you to confirm the accuracy of your personal information for such purpose.

Transfers of Personal Information to Other Jurisdictions

We may store your personal information in a jurisdiction outside your jurisdiction of residence (for example, outside your province or state or outside Canada or the United States). Some of our service providers may also access, process or store your personal information outside the province, territory, state or country where you reside. Where Personal Information is located outside of your province or state of residence, it is subject to the laws of that jurisdiction which may differ from those in your jurisdiction and any personal information transferred to another jurisdiction will be subject to law enforcement, regulatory, and national security authorities in that jurisdiction.

In these circumstances, we use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored. We use our best efforts to ensure our service providers only use your personal information for authorized purposes we have made known to you or which are otherwise permitted by applicable law.

For European citizens, we will rely on adequacy decisions where possible, and will otherwise rely on standard contractual clauses of the EU Commission to protect your personal information.

10. How can you exercise your privacy rights?

Depending on your jurisdiction you may have certain privacy rights. You will not have to pay a fee to exercise your privacy rights, however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances or as permitted by applicable law.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.

Changing your Communication Preferences

You can always choose not to receive marketing or promotional messages from BGO by email by clicking on “unsubscribe” or letting us know your preference.

Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law, for example, to send you important product information, service notification or recall. In addition, it may take up to ten (10) business days to register a change of preference across all our records.

Accessing and Correcting Personal Information

Under certain circumstances, you have rights under data protection laws in relation to your personal data. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below.

An individual may, upon written request to BGO's Privacy Officer, access the personal information about the individual that is in the custody of BGO. Within 30 days of such request (or such longer time as permitted by law), BGO will inform the individual of the existence, use, and disclosure of such information.

An individual may, upon written request to BGO, request a correction to an error or omission in any personal information that is under BGO's control. BGO will, as appropriate, amend the information as requested and use its best efforts to send the corrected personal information to each third party to which it has disclosed the information during the preceding year.

The written request must provide sufficient detail to enable BGO, with a reasonable effort, to identify the individual and the personal information or correction being sought.

An individual's rights to access his or her personal information are not absolute. BGO may deny access when denial of access is required or permitted by law, including but not limited to if granting an individual access would reveal:

  • Personal information about a third party, or information which could reasonably be expected to threaten the life or security of an individual;
  • Confidential commercial information;
  • Personal information which is protected by solicitor/attorney-client privilege; or
  • Personal information collected relating to an investigation.

If we deny an individual's request for access to, or refuse a request to correct personal information, we will explain why, to the extent permitted by law.

An individual may also have the right to request the portability of his or her personal information. This means that an individual will have the right to receive the personal information that he or she made available to BGO in a structured, commonly used and technological format, to be able to transmit them to another entity directly without impediments on BGO’s part.

To submit a request, please contact BGO’s Privacy Officer as described below.

Additional Rights for California Residents

California law entitles California residents to certain additional protections regarding personal information.  California residents have the right to request:

  • Information regarding your personal information BGO has collected (including the categories of personal information collected, the categories of sources of such information, and the purposes for which BGO has collected such information)
  • Notice of whether BGO has disclosed your personal information to third parties (and if so, what categories of information has been disclosed, and what categories of third parties have disclosed it to)
  • A copy of your personal information collected by BGO in the previous 12 months
  • That your personal information be deleted

BGO will not discriminate against you if choose to exercise any of these rights.  To do so, please contact our Privacy Office as described below.

Additional Rights for European Economic Area (EEA) / Swiss Residents

Under the GDPR, BGO processes your data under a number of legal bases:

  • Consent: We will process your personal data when you have provided us with your consent to do so;
  • Contract: We will process your personal data when necessary to do so under a contractual obligation;
  • Legal obligation: We will process your personal data when required by law to do so;
  • Legitimate interests: We will process your personal data when necessary to the legitimate interests of BGO, including for marketing, fraud prevention, and security purposes; and
  • To protect the vital interests of individuals.

Depending on the processing activity, individuals may be entitled to the following protection rights:

  • Right to erasure: In certain circumstances, you may have a broader right to erasure of personal information that BGO holds about you. Please note that BGO may need to retain certain information for record-keeping purposes, to complete transactions, or to comply with our legal obligations
  • Right to object to processing: You may have the right to request that BGO stop processing your personal information when the processing is based on our legitimate interest.
  • Right to restrict processing: You may have the right to request that BGO restricts processing of your personal information in certain circumstances (for example, where you believe that the personal information BGO holds about you is inaccurate or unlawfully held).
  • Right to data portability: You may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that BGO transfer the personal information to another data controller without hindrance.
  • To exercise such rights, please contact BGO as set forth at the end of this Policy.
  • You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Cookies and Similar Technologies

When you visit the BGO website(s), we may collect and use your internet protocol address to help diagnose problems with our server and to administer the website(s), to understand how users interact with the BGO website(s), and to gather broad demographic information. BGO may also collect web page choices, browser type, operating system, and time you spend on the site to help BGO improve your experience.

BGO uses "cookies", a technology that installs a small amount of information on a website user's computer, to permit our website to recognize future visits using that computer and to avoid having to register your contact information at each visit. Cookies enhance the convenience and use of our website(s). For example, the information provided through cookies is used to recognize you as a previous user of our website(s), to track your activity on our website(s), to respond to your needs, and to otherwise facilitate your experience on our website(s).

You may choose to decline cookies if your browser permits, but doing so may affect your use of our website(s) and your ability to access certain features of our website(s) or engage in transactions through our website(s).

We may use the following types of cookies on our website(s):

  • Strictly necessary cookies: these cookies are essential to allow you to fully use our website and its full features. These cookies do not gather information about you that could be used for marketing.
  • Performance cookies: these cookies collect information about how our visitors use our website, to help us understand what sections of our site are popular and help us fix errors on any of our web pages.
  • Marketing and targeting cookies: these collect information about your browsing habits and are placed by third party providers and ourselves. The information in these cookies is anonymized but they contain a unique key that can distinguish individual browsing habits, or if an individual user has clicked on an advert we have placed. We use these cookies to understand if our marketing is effective, and if our recommendations for you are a good fit.

Within our applications, BGO may also use analytic tools and automated tracking technology or methods. BGO may use these tools to analyze and enhance the user experience. BGO may use third-party advertising networks to display advertising on our websites or other websites. These advertising networks may use cookies or similar technologies to track your navigation habits on our websites and third-party websites to serve you advertising that is customized to your inferred interests and preferences. For example, a cookie may be placed on your computer when you visit a BGO website, which is recognized and used by third-party advertising networks to serve you with a BGO ad when you visit other websites within their advertising network.

As described above, you may be able to set your browser to decline cookies. If you decline cookies, you may still receive online advertising; however, it may be less personalized. Some advertising networks participate in industry programs that include web pages to visit to opt-out. For example: http://youradchoices.ca/choices. You can find out more about turning off cookies at the independent website allaboutcookies.org.

Third Party Websites

BGO may provide links to other websites that are not operated or controlled by BGO. These websites are not governed by this Policy. You should review the privacy policy associated with any linked website prior to visiting the site or providing any information.

11. Changes to our Privacy Policy

We may make changes to this Policy from time to time. Any changes we make will become effective when we post a modified version on our websites. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws.

By continuing to use our products and services after the modified version of the Policy has been posted or after you have been informed of such update, you are accepting the changes to the Policy. If you do not agree to the changes in our Policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand, and agree to the latest version of the Policy as posted. The “Last Updated” at the top of this Policy indicates when it was last updated.

12. How to contact us

BGO’s Privacy Officer and Data Protection Officer (“Privacy Officer”) is responsible for overseeing BGO's compliance with this Policy.

Please address any questions or concerns about this Policy or our privacy practices generally, including requests for access to your personal information, to the Privacy Officer.

Privacy Officer
BGO (Controller)
1 York Street, Suite 1100, Toronto, Ontario Canada M5J0B6
Phone: 416-681-3400
Email: PrivacyOfficer@BGO.com