Privacy Policy

Introduction

Gilad Parking, a division of Gilad Properties Ltd. (“Gilad”) is committed to protecting the privacy of personal information.  This Privacy Policy (the “Policy”) has been developed to explain how Gilad treats the personal information about you that it collects in connection with its various parking lot operations and to detail its responsibilities under the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

 

What is PIPEDA?

 

PIPEDA is federal legislation that governs the collection use and disclosure of personal information in a manner that respects your right of privacy concerning your personal information.  PIPEDA balances these rights against an organization’s need to collect, use and disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.

 

What is personal information?

 

Personal information is information about an identifiable individual.  Examples of personal information collected by Gilad include: home and e-mail addresses, phone numbers, credit card information and vehicle information.

Accountability

 

The responsibility for the personal information under Gilad’s control rests with its Privacy Officer.  The individual designated as Privacy Officer may change from time to time, however, his or her identity will be made known upon request and it is currently Robert Moses, whose contact information is set out at the end of this Policy.

 

Consent

 

This Policy identifies the purposes for which Gilad collects, uses and discloses your personal information. Due to the reasonableness and appropriateness of the purposes described in this Policy, consent will be implied by your purchase of parking (or request to be placed on a waiting list for parking), in all circumstances and generally may not be withdrawn. In cases where your personal information was collected prior to the issuance of this Policy, it is only used and disclosed for the purposes described in this Policy.

 

Identifying Purposes

 

Parking Operations.  Personal information is collected in order for Gilad to operate its business as a parking lot manager.  This may include the collection of all or any of, your name, credit card number, license plate, telephone number and e-mail or residential address. This information is collected for the purpose of:

  • processing parking transactions (either for daily or other periodic passes), including collecting payments and invoicing for periodic payments,
  • ensuring that only authorized users are using the parking lots,
  • contacting you to advise you about parking lot closures, scheduled cleaning or maintenance, or incidents that occurred at or near the parking lot in connection with safety or security; and
  • contacting you to advise you that a parking spot has become available.

 

Information may also be collected concerning missed or late payments for periodic passes.  Consent may not be withdrawn for these purposes during any period while you are a parking pass holder, while you on a waiting list to get a parking pass or while you owe any amounts to Gilad.

 

Due Diligence Disclosure.  If Gilad sells a parking lot, your personal information may be disclosed to the buyer so that it may continue to use such information for the purposes described in this policy.  Consent may not be withdrawn for this purpose during any period while you are a parking pass holder or on a waiting list to get a parking pass.

 

Identification. Personal information is collected for the purposes of identification.  Consent may not be withdrawn for this purpose during any period while you are a parking pass holder or on a waiting list to get a parking pass.

 

Limiting Collection

 

Gilad does not collect personal information indiscriminately.  Gilad limits the collection of personal information to that which is necessary for purposes it identifies.

 

Gilad primarily collects personal information directly from you; however, personal information may also be collected from other sources including Gilad’s own observations about missed or late payments.

 

The personal information that Gilad collects directly from you may be collected in a variety of ways, including, by being disclosed directly by you to Gilad verbally or in an application, generated by your transactions with Gilad at a parking lot machine, or observed by Gilad.

 

Limiting Use and Disclosure

 

Gilad only uses and discloses information for the purposes for which it was collected, or otherwise in accordance with PIPEDA.  Any new purpose for which the information is to be used or disclosed will be documented, and consent will be obtained for it.

 

Personal information collected at point of sale machines at parking lots is not collected or retained by Gilad.  Credit or bank card information revealed at such machines is communicated directly to the processing bank.

 

 

Accuracy

 

Personal information will be kept as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.  You are responsible for informing Gilad about changes to your personal information.

 

Safeguards

 

Gilad protects personal information against loss or theft; as well as unauthorized access, disclosure, copying use or modification; with security safeguards appropriate to the sensitivity of the personal information.  Any paper applications with credit card information on them have all but the last 4 digits of the credit card number redacted and such applications are kept inside a locked cabinet in Gilad’s vault. All other personal information that is collected is either collected electronically or input manually into Gilad’s electronic system. Gilad uses firewalls and passwords to protect electronic personal information.

 

Electronic Passes

 

In some of the parking lots managed by Gilad, electronic passes may be used.  The passes work by permitting entry and exit to the parking lot when the pass is waved in front of a pass reader at the particular entry/exit. Each pass, when read electronically, may be distinguishable from every other pass and Gilad may keep a record of which pass is issued to whom and when each pass is used to enter or exit a parking lot.

The purpose for the collection of personal information in connection with the pass is two-fold.  Firstly, because of the fact that a pass is personal to its holder, it allows Gilad to deactivate a pass if it is lost, stolen, not returned at the end of a period of parking, or otherwise unaccounted for. Thus once reported, a pass that is stolen (for example) will be deactivated and cannot permit entry to the parking lot.

 

The second purpose for the collection of personal information in connection with the passes is to assist in identifying a person seen on the video camera recordings using a pass, if an incident is under investigation, including any misuse of the pass.

 

Please note that the personal information collected in connection with the passes may be disclosed to and used by law enforcement officials if the situation (in Gilad’s opinion) requires it. The above personal information may also be used in legal proceedings, if a law has been broken or some other offence has occurred.

Openness

 

The Privacy Officer may be contacted concerning inquiries about how to gain access to personal information held by Gilad or, complain about Gilad’s treatment of personal information or about the accuracy of your personal information on file.

 

 

Individual Access

 

Upon written request, Gilad will divulge the existence, use and any disclosure made of personal information and will give you access to your information, in accordance with its obligations under PIPEDA.  Written requests must be delivered to the Privacy Officer at the address at the end of this Policy.  If assistance is needed with the request, please contact the Privacy Officer.

 

Gilad will respond to an access request within 30 days, unless an extension of time is required, in which case the response may take up to an additional 30 days.  A fee for reasonable costs incurred pursuant to the request may be charged by Gilad, provided that you are informed of the fee in advance and do not withdraw your request.

 

If Gilad does not comply with an access request, it will inform you of the reasons for such refusal.

 

Challenging Compliance

 

Any concerns respecting Gilad’s compliance with PIPEDA must be addressed to the Privacy Officer.  Gilad will investigate and respond to written complaints within 90 business days of receiving a complaint.  If a complaint is found to be justified then Gilad will take appropriate measures, including, if necessary, amending its policies and procedures.

 

 

PRIVACY OFFICER

Robert Moses

Arnon Development Corporation Limited

1801 Woodward Drive

Ottawa, Ontario

K2C 0R3

(Telephone): 613-727-4026

E-mail: rmoses@arnon.ca