Privacy Policy

Privacy and Cookies Policy

This Privacy Policy (“Policy”) describes the personal information that Hansbraun Investments Ltd. (“Hansbraun”, “our”, “we” or “us”) collects from or about you when you use the www.hansbraun.ca website (the “Site”), or otherwise interact with us.  It also describes how we use that information, and to whom we disclose it. As used in this Policy, “personal information” means information about an identifiable individual, except for any information exempted under the applicable privacy laws of British Columbia, Canada, or other relevant jurisdictions. This Policy does not apply to any anonymized information, nor does it apply to business contact information processed solely to communicate with a person about that person’s employment or profession.

Please read this Policy carefully and contact us if you have any questions. By using our Site, other than to review this Policy and the Site’s Terms of Use, or otherwise providing us with personal information, you will be deemed to have agreed to this Policy.  If you do not agree with our collection, use or disclosure of personal information in accordance with this Policy, you should not access or use the Site or otherwise provide any personal information to us. 

This Policy was last updated on July 31, 2023. Hansbraun reserves the right to revise this Policy from time to time and, as such, you should review its terms each time that you visit our Site.  We will notify you about any significant changes in the way we handle personal information by placing a prominent notice on the Site and/or by updating the privacy information on this page. Any changes to this Policy will not go into effect until at least five (5) days after they are posted or otherwise communicated to you.  Your continued use of this Site or our services signifies your acceptance of any changes to this Policy.

Accountability and Openness / Privacy Compliance Officer

Hansbraun is responsible for personal information under our control, and we are accountable to you for our collection, use and disclosure of all personal information that you provide to us. We have established policies and procedures to safeguard any personal information that we have on file or that we collect, and to deal with complaints and inquiries. We will only collect personal information as described in this Policy.

Hansbraun has designated an individual (the “Privacy Compliance Officer”) who is accountable for the protection of data containing personal information, and for our compliance with this Policy.

If you have questions or concerns regarding this Policy, our compliance with it, as well as any of our processes and procedures relating to the collection, use and disclosure of your personal information, you may direct them in writing to the Privacy Compliance Officer at info@hansbraun.com or c/o Hansbraun Investments Ltd., Unit 401b -3989 Quadra St., Victoria, BC V8X 1J8.

Collection of Personal Information

What Information is Collected and How?

We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). In most cases, we will collect personal information directly from you when you visit the Site, or otherwise interact with us with regards to the properties that we own or manage and the services that we offer. We encourage you not to provide us with any personal information beyond what is required or requested by us for the purposes we have described below.  Personal information will always be collected using means that are transparent, fair and lawful.

1. Direct Collection
   Examples of personal information that we may collect, use and disclose include your name, company name, email address, physical location, address and telephone number. We may also request birth dates for the purpose of performing credit checks on prospective individual tenants. This information will only be collected when you voluntarily provide it to us.

   If you provide comments or other feedback to us regarding our properties or services, such comments or other feedback become the property of Hansbraun and we may use, disclose and share them for any purpose provided that we do not associate them with your personal information without your express consent.

2. Collection from Third Parties
   We will not collect your personal information from a third party unless we receive assurance that you have consented, or unless we are required or permitted to do so by applicable law.  Any personal information collected from a third party will be used only for the purposes for which it was collected.
3. Information Collected Through Automated Means
   Users may visit the Site without telling us who they are or revealing any information about themselves. However, like many organizations’ websites, our web server automatically logs certain information related to a user’s visit to the Site, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed the Site, the Internet address of the website from which the user linked directly to the Site, the operating system that the user is using, and the pages of the Site that the user has visited. Unless required or permitted by law, we will not attempt to link this information with the identity of individuals visiting our Site unless we have consent to do so. We may, however, review server logs and traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving our website and programs, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.

Cookies: We use “cookies” in order to improve your user experience, and to analyze how the Site is used.  Cookies are files with a small amount of data that are placed on your computer by websites that you visit, and are stored on your device.  Cookies are used to identify you to the web server, and will tell the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system. There are different types of cookies: Session cookies, which are used to operate our Site and that expire when you close your browser; preference cookies that are used to remember your preferences and various settings, and remain on your device until they are deleted or expire; and security cookies, which are used for Site security purposes, such as detecting malicious activity and violations of our Site’s Terms of Use.

We use cookies:

• to personalize your online experience by delivering personalized content to you;
• to save you time and facilitate browsing, by recalling your specific information and preferences on subsequent visits to the Site;
• to determine and authenticate your access privileges on our Site;
• to complete and support a current activity;
• to track website usage;
• to implement security features;
• for advertising purposes, to offer you relevant opportunities and other targeted content that may be of interest to you; and
• to generally improve your online user experience.

When you first visit the Site, a pop-up banner informs you of the use of cookies, seeks your express consent to their use, and provides a direct link to this information page. Although the banner will not normally appear on subsequent visits to the Site, you may withdraw your consent to the use of cookies at any time by following the instructions below.

Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. The management of cookies varies for each browser, and you should consult your browser’s user documentation for instructions on how to modify your cookie preferences.    If you decline cookies, you may still be able to use the Site but your ability to access certain pages, features and functions may be affected.

Your browser or device may include “Do Not Track” functionality. “Do Not Track” is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a standard for “Do Not Track” technology.  No standard has been adopted to date.  At this time, Hansbraun does not generally respond to browser “Do Not Track” signals.

Analytics: Our Sites may use analytics services, such as Google Analytics.  These services use cookies to analyse how users use the Sites.  The analytics service provider will use this information to evaluate the use of the Site, compile reports, and provide us with other information regarding Site activity and internet usage.  For more information about Google Analytics, or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available here. You can also obtain additional information on Google Analytics’ data privacy and security at the following links: https://policies.google.com/technologies/partner-sites

Consent

Consent for the collection, use or disclosure of personal information may be express or implied. Typically, where we rely on consent to process personal information that you have provided to us, we will seek your consent at the time of collection, and efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed.

In certain circumstances, we might seek your consent regarding use or disclosure after the information has been collected, but before use, such as when Hansbraun wishes to use personal information already in its possession for a purpose that was not previously identified.

Hansbraun assumes the implicit consent of individuals in photographs taken at Hansbraun events to use the photographs in Hansbraun communications. However, your photograph will not be distributed to outside organizations without your express consent.

Part of providing meaningful consent is understanding the risk of harm and other consequences of the disclosure of personal information. While we endeavour to continually use best practices to minimize the risk of harm (See: Safeguards – How Personal Information is Protected, below), technology is constantly evolving and no safeguards can be guaranteed to be failsafe or to provide absolute protection against malfeasors.

Withdrawal of consent

You may always choose not to disclose personal information. Also, when we are already using personal information on the basis of your consent, you may withdraw or change your consent at any time. To withdraw or change your consent to our use of your personal information, please send your request in writing, along with details of the use of your information that you wish to change or withdraw your consent for, to the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer).

In some circumstances, particularly where our use of any personal information that you have provided to us is integral to the provision of our services or your participation in our programs, your refusal or inability to provide consent, or a change or withdrawal of consent, may adversely affect your interactions with us and/or our ability to provide you with information, programs or services.

Purpose – Why We Collect, Use and Disclose Information

We will not collect personal information that is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected, without first obtaining your consent. The information that we collect is used and disclosed only for business purposes related to Hansbraun’s operations.  These include:

• to create a user account for you, and to verify and authenticate your identity;
• to operate and maintain the Site, and to respond to your requests, questions and concerns;
• to process payments;
• to transact business with you, and generally to perform our obligations and exercise our rights arising from any contract between you and us;
• to run credit checks, and otherwise verify your financial stability;
• to support our advertising and marketing activities;
• to design events and services that may be appealing to our clients and other users of the Site;
• to provide you with personalized content, and to maximize our ability to provide you with services, information and other resources that are useful and relevant to you;
• to manage your employment with Hansbraun Investments Ltd.;
• to obtain feedback regarding our properties and services, which may include inviting you by email to write a review of our properties. This allows us to continually improve the services that we offer;
• to offer and manage contests, conferences and other promotional activities;
• to verify that any information submitted by you is accurate and complete;
• to generally communicate with you for reasons related to our business, such as to provide you with announcements, updates, alerts, confirmations, corrections and surveys;
• to create a record of your involvement with us;
• for legal purposes, which may include the processing of real estate transactions, handling and resolution of claims and legal disputes, or for regulatory investigations and compliance;
• to detect and prevent error, fraud, theft and other illegal or unwanted activities;
• internal business purposes, including data analysis, to administer or improve our properties and services, market research, to enhance the client experience, and to improve the functionality and quality of our Site and online resources;
• to comply with any legal, accounting and regulatory requirements, including reporting requirements; and
• any other reasonable purpose for which you provide consent, or for which consent may be implied in accordance with this Policy and applicable law.

Where personal information that has been collected is to be used for a purpose not previously identified, we will notify you of the new purpose and, where necessary, obtain your consent, prior to the use of that information for the new purpose unless otherwise permitted by law.

Disclosure to Third Parties

Hansbraun may share your personal information with its employees and contractors for the purposes contemplated by this Policy, provided that such persons agree to use the information only in accordance with this Policy.  Except as specifically provided in this Policy or as permitted by law, personal information will not be shared with unrelated third parties unless we provide you with both prior notice and choice.  Hansbraun does not share, sell, rent or lease user information to third parties.

From time to time, Hansbraun may disclose personal information to third party subcontractors and service providers (“Subcontractors”) in connection the operation of our business.  Third party Subcontractors to which we may disclose personal information may include payment processors, analytical support services, web hosts, maintenance contractors, and parties that we engage to send out marketing materials.  Given the nature of cloud services, personal information may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored.

Hansbraun has contracts in place with our Subcontractors to ensure that any personal information that you disclose to us and which is shared with them is kept safe, secure, confidential, and in line with this Policy and applicable laws. In all cases, we will provide the Subcontractors only with the information needed to perform the subcontracted service. We may change or add Subcontractors at any time, at our discretion. Details regarding the personal information that we make available to our third party Subcontractors, and how it is used, is available by contacting the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer). Any request made by you to correct, change or erase personal information will be promptly communicated to any third party Subcontractor in possession of that information (see: Individual Access / Accuracy / Erasure).

We may collect, use or disclose personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based upon our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to enforce our rights or to protect our assets, the users of the Site, or the public.

Retention of Personal Information

Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected.   Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media. In certain circumstances, you may request the erasure of your personal information, which we will endeavor to do without undue delay as required by applicable law. Written requests should be sent to the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer). We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information.

Safeguards – How Personal Information is Protected  

We have implemented physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive information. Our data systems use user IDs, passwords and encryption technology. Paper files containing personal information are centralized, and rooms where filing cabinets are located are locked outside of business hours. Paper files are shredded when no longer required.  We store data on remote servers hosted by reputable companies in Canada. Staff and contractors who have access to personal information are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner.  Personal information that is transmitted to other sites is protected through the use of encryption, such as Secure Sockets Layer (SSL) protocol.  When destroying personal information, we delete electronically stored personal information and shred any physical materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media, but will not be used unless permitted by law.

We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal information may involve the transmission of data on an international basis and across networks not owned and/or controlled by Hansbraun. Accordingly, we cannot guarantee that personal information will not be lost, or that it will not be altered, intercepted or stored by an unauthorized third party.

In the event of a security breach concerning personal information, we will endeavour to notify affected individuals promptly upon discovering the breach, as required by applicable law.  In any event, if a breach is likely to affect the rights and freedoms of the affected individual, we will ensure that the notification is made without undue delay.

Individual Access / Accuracy / Destruction

We will endeavour to ensure that personal information contained in our records or which is disclosed to third parties for the purposes described above will be as accurate, complete and up-to-date as is necessary for the purposes for which it is used. You may request access to the personal information that we hold about you by submitting a written request to the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer). Including “Request personal information” in the subject line of your email or letter will facilitate compliance with your request. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom we have disclosed the information. In some instances, you may also be entitled to receive a copy of your personal information in a structured, commonly-used, machine-readable format (or request that this be transferred to a third party where technically possible). In certain circumstances, Hansbraun may not be able to provide you with access to all or some of your personal information, in which case you will be advised in writing of the reasons for our inability to provide you with the information.

You also have the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect.  If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data or if your personal information changes. All notices and requests regarding inaccuracies or changes should be in writing and sent to the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer).

In certain circumstances, you have the right to require that we erase, limit and/or cease processing your personal information. All notices and requests asking us to erase, limit or stop processing your personal information should be in writing and sent to the Privacy Compliance Officer at the address set out above (see: Accountability and Openness / Privacy Compliance Officer).

Links to other Websites 

To the extent the Site contains links to other websites, the owners of those websites are responsible for the privacy practices and content for their sites. If you click on those links, you will leave the Hansbraun website, and third parties may collect personal information from you or your electronic devices. The accessing and use of any third party websites is at your own risk.  Hansbraun does not provide or endorse any information, goods or services available through third party websites, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to the Hansbraun Investments Ltd. website, and we encourage you to review the privacy policies contained on each Internet site that you access

International Transfer and Storage of Information

Hansbraun is based in Canada, and will endeavor to continue to use data hosting facilities based in Canada. However, given the nature of the Internet and cloud services, personal information may be transmitted, transferred, processed, backed-up and/or stored outside of Canada, including in the United States. In particular, certain of the Subcontractors to which we disclose your personal information (see: Disclosure to Third Parties) may use and store that information at their facilities outside of Canada. We will use reasonable means to ensure that your information is protected, including written agreements with our third party Subcontractors, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada, or that your personal information will not be accessible to foreign courts, law enforcement or national security authorities in the jurisdiction(s) where it is transferred or stored.

Minors

The Site and our services are intended solely for users who are 19 years of age or older. Hansbraun will never knowingly collect personal information from minors.  If we are advised or otherwise discover that personal information has been collected from a minor without the express consent of a parent or guardian, we will take all commercially reasonable steps to delete that information.

Compliance and Governing Law

Inquiries, requests and complaints regarding our compliance with this Policy should be directed to the Privacy Compliance Officer (see: Accountability and Openness / Privacy Compliance Officer).

Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual.

The Site is hosted and operated from Victoria, British Columbia, Canada.  Except as required by applicable privacy laws, your use of the Site, this Policy and the protection of your personal information will be governed exclusively by the applicable laws of the Province of British Columbia and of Canada.  Additional rights may apply to users in other jurisdictions as required by applicable law.