Avison Young Online Privacy & Cookie Notice
Effective Date: May 23, 2018
Avison Young is committed to protecting and respecting the personal data that we hold. This Privacy Notice (“Notice”) applies to all Personal Information (defined below) that is collected by Avison Young (“we,” “us,” or “our”) through our online properties (“Sites”). This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.
The purpose of this Notice is to inform website users (“you” or “your”) what information may be collected from you when you visit the Sites, how the information will be used, with whom the information will be shared, your choices regarding the information, your ability to edit, update, correct or delete the information and the security procedures that we have implemented to protect your privacy.
Personal Information. In general, you do not need to provide us with any Personal Information in order to browse the Sites. However, you may consent to provide Personal Information such as your name, address, email address, telephone number, or business contact information, in order to use certain portions of the Sites. If you are applying for a job through the Sites, you may also choose to provide us with additional information such as your employment status, employment history, and academic background. If you do not want to share your Personal Information with us, please do not submit it. Unfortunately, this means that we may not be able to provide you with the services you have requested.
Log Files, Research and Data Analytics. We may also gather certain information automatically, such as Internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating systems, date/time stamps, and/or clickstream data. We gather this information to better understand our clients and Site user-base and to improve our services to you. In addition, we may conduct research on your demographics, interests, and behavior based on non-Personal Information usage data. This data may be compiled and analyzed on an aggregate basis and we may share the data with our service providers. However, the data is stored separately from any Personal Information you may have provided, and will not be connected to you.
Use of Information & Choice
If you choose to provide us with your information, we may use it for the following purposes:
(a) to provide you with real estate related services if you are a client, or become a client, of Avison Young;
(b) to send you “Research Reports” or other newsletters you have subscribed to on the Sites;
(c) to answer your questions submitted through the “Contact Us” feature of the Sites;
(d) to evaluate the quality of our services and to perform internal studies regarding our services;
(e) to recruit prospective employees who have applied for a job on the Sites;
(f) to enhance the operation of the Sites; and
(g) to serve you with content, advertisements and promotional materials through the Sites.
We do not collect, use, or disclose your Personal Information for any other purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will always obtain your consent first, and offer you the choice to opt-out of such collection, use, or disclosure.
We do not share your Personal Information with third parties except as described below and we will never sell, rent, or share your Personal Information for direct marketing purposes.
Avison Young Affiliates. We may share your Personal Information with our subsidiary, affiliate, and parent entities for the purposes described in this Notice.
Service Providers. We may share your Personal Information with contracted service providers as may be necessary for us to achieve the purposes described in this Notice. These service providers are under a contractual obligation to use Personal Information only for the purposes for which they were hired and in accordance with applicable law
Business Partners. We may share your Personal Information as part of joint marketing efforts with affiliates and third party business partners, consistent with the purposes described in this Notice.
Business Transitions. In the event we go through a business transition, such as being acquired by another company, or selling all or part of our assets, Personal Information will, in most instances, be part of the assets transferred. However, it will be subject to the promises made in any pre-existing privacy notice unless the acquiring entity obtains your consent to additional uses.
Legally Required Law Enforcement, Judicial and Administrative Agency Disclosures. We will disclose Personal Information and related confidential information as necessary to comply with judicial orders, subpoenas, civil or criminal investigative demands, administrative and regulatory demands, and other legal obligations, if we believe in good faith that disclosure is necessary to comply with the law, to protect our rights, to protect your safety or the safety of others, or to investigate violations of applicable law.
Research Reports & Newsletters. Site visitors may subscribe to “Research Reports,” or other newsletters that provide you with information about our services, by providing us with a valid email address. You may stop receiving these kinds of emails by clicking “unsubscribe” or by following the instructions in the footer of the email, or by submitting a written request to the Privacy Office at the contact information below.
Sales & Customer Service. We communicate with customers and interested individuals via email, regular mail, and telephone to provide requested services. You may ask to be removed from a mailing or calling list at any time by submitting a written request to the Privacy Office at the contact information below.
Cookies and Tracking Technologies
Session Cookies. - temporary cookies that remain in the cookie file of your browser until you leave the site. Session cookies are used to carry information across pages of the Sites so you don’t have to re-enter information.
Persistent Cookies. – cookies that remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). Persistent cookies are used to help us recognize you as a unique visitor when you return to our website. They also allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly. We also use persistent cookies to compile anonymous, aggregated statistics that allow us to understand how the Sites are used and to help us improve the structure of the Sites.
Web Beacons. Web beacons are images inserted in a webpage or email, which may be used to count the number of visitors to the Sites, monitor the behavior of the Site user, store the IP address of the user, store the duration of the interaction, and store the type of web browser that was used, among other information. We may use web beacons to improve user experiences on the Sites and learn more about our customers and visitors to the Sites. Web Beacons collect only limited information which includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. Web becons do not contain any Personal Information.
Disabling and Enabling Cookies. You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of the Sites if cookies are disabled. Should you wish to be alerted before a cookie is accepted on your hard disk, guideline instructions follow below:
Deleting cookies. You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you are using Microsoft Windows Explorer:
- Open 'Windows Explorer'
- Click on the 'Search' button on the tool bar
- Type "cookie" into the search box for 'Folders and Files'
- Select 'My Computer' in the 'Look In' box
- Click 'Search Now'
- Double click on the folders that are found
- 'Select' any cookie file
- Hit the 'Delete' button on your keyboard
If you are not using Microsoft Windows Explorer, then you should select "cookies" in the "Help" function for information on where to find your cookie folder.
Do Not Track Browser Requests. Web browsers often also allow you to send a “Do Not Track” request with your browsing traffic, which would enable anonymous browsing. Our service provider does not honor Do Not Track requests from web browsers.
Data Quality, Access & Rectification
We will make reasonable efforts to ensure your Personal Information is accurate and complete and we will update or correct your information as needed when notified by you. If you would like to request access to your Personal Information, request to verify your Personal Information, identify any inaccuracy in your Personal Information, or change your Personal Information in any way, please contact our Privacy Office at the address below. We will use commercially reasonable efforts to accommodate all such requests.
We retain the Personal Information processed by us for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
We take reasonable administrative, technical and physical steps to ensure that your Personal Information in our custody and control remains accurate, timely, and secure. Unfortunately, no data transmission over the Internet can be guaranteed as secure and we cannot be responsible for harm that you or any other person may suffer as a result of a breach of confidentiality in respect to your use of the Sites or any information you transmit through the Sites.
The Sites are hosted in the United States. Accordingly, by providing your Personal Information through the Sites, you consent to the transfer of your Personal Information from your country of residence (i) to the United States for purposes of Site administration, (ii) to other Avison Young offices in other countries if you have requested a service from them, and (iii) to service providers or business partners located in other countries, all in accordance with applicable law. Those countries may offer less privacy protection than your country of residence, and in certain instances your Personal Information may be accessible by foreign courts, law enforcement authorities and national security authorities in those countries.
Third Party Links
The Sites may contain links to or from other websites over which we have no control. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage users to be aware when they leave our Sites and to read the privacy notices of each and every website that collects Personal Information. This Privacy Notice applies solely to information collected by our Sites.
Questions and Complaints
We take your privacy concerns seriously. If you believe we have not complied with this Privacy Notice, or you have any other questions, you may write to our Privacy Office at One South Wacker, Suite 3000, Chicago, IL 60606, firstname.lastname@example.org.
The Sites are general audience websites and not intended for minors. We do not knowingly collect Personal Information from anyone under 13 years of age. If you believe we may have collected information from your child on the Sites, please contact the Privacy Office and we will make reasonable efforts to delete the information from our records.
We do not use the Sites to knowingly collect “sensitive data” such as that relating to racial or ethnic origin, current or future medical status, genetic information, religious, philosophical or moral beliefs, labor union affiliation, political opinions or sexual preference. If you believe you have mistakenly provided us with any sensitive data, please contact the Privacy Office.
Geographic Location-Specific Provisions
Individuals may request access to their personal data held by us as a data controller.
Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
Individuals may request that we erase their personal data
Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
The full GDPR Privacy Statement can be found here GDPR Supplementary Privacy Statement
If you wish to exercise any of these rights, please send an email to email@example.com.
You have the additional rights (i) to cancel your Personal Information when you deem it is not required for the purposes established in this Notice or that it is being used for unauthorized purposes, (ii) to oppose the processing of your Personal Information for certain specific purposes, and (iii) to file a complaint with the Federal Public Information Access Institute at www.ifai.org.mx. You may exercise rights (i) and (ii) through a written petition to the Privacy Office at the address above, accompanied by your email address and telephone number, and if applicable, specific details of the reasons for which a rectification, opposition or revocation of consent is requested. We will respond to your petition within a reasonable amount of time and inform you of its outcome through the phone number and/or email address provided by you.