Privacy Policy

Privacy Notice Two Park Central

Effective as of 13 July 2026

Thanks for visiting our website. This Privacy Notice describes how Personal Information is collected through this website in connection with your current lease or rental relationship with the property, or your interest in becoming a resident.

The Property Owner HNC 500 Block II HT ULC (“Data Controller”) is the entity who is responsible for the collection and processing of your Personal Information. Hines Living (“Hines”) serves as the property manager and acts as a “Data Processor” under applicable Data Protection Laws. Hines processes Personal Information solely on behalf of the Property Owner and only in accordance with their instructions.

Throughout this Privacy Notice, “we,” “us,” or “our” refer to the Property Owner and to Hines, who acts as the Data Processor on behalf of the Property Owner and under its direction.

Our Privacy Notice extends to all Personal Information you provide to us, or that we obtain from you, or about you (“Personal Information”). This Policy applies to the collection, use, disclosure and/or processing of Personal Information by Hines on behalf of Data Controller to which Data Protection Laws apply. We are committed to maintaining the confidentiality, integrity, and security of your Personal Information. It is our policy to respect your privacy and to safeguard your Personal Information entrusted to us.

This document (“Privacy Notice”) describes the standards we follow for handling your Personal Information on behalf of Data Controller and how we use the Personal Information collected about you in accordance with the provisions of applicable Data Protection Laws and Data Controller’ instructions. 

Depending on your place of residence, additional information in compliance with the specific regional regulations applicable to your situation is provided in the annexes to this Policy. 

Terms capitalized in this Privacy Notice are intended to be interpreted in alignment with the relevant Data Protection Laws applicable to your circumstances.

The information below explains how we protect your Personal Information, to what extent we transfer it to other countries, how long we keep your Personal Information and what rights you have regarding our processing operations. 

For further information please click on the notice that is relevant to your relationship with Hines.

  1. HOW WE PROTECT YOUR PERSONAL INFORMATION

We take your privacy seriously. We've put in place strong measures to keep your Personal Information safe and secure. This includes special protections for client files, tailored to the sensitivity of the information they contain. We also have controls in our computer systems to restrict access appropriately.

Only authorized employees have physical access to areas where personal data is stored or processed. We make sure our team members are trained to follow all laws and regulations, especially when it comes to data protection. Access to sensitive information is limited to employees who really need it for their jobs and who are authorized to see it.

If you want more details about how we protect your Personal Information, just reach out to us as described in Section 9 below. And when you contact us about your file, we may ask for some Personal Information to make sure that only you or someone you've authorized can access your information.

  1. WHAT PERSONAL INFORMATION DO WE PROCESS?

For the purposes of this Privacy Policy, “personal information” is information about an identifiable individual and that directly or indirectly allows that person to be identified. For the purposes of this Privacy Policy, personal information does not include information normally used to contact an individual at their place of business, except as required by applicable privacy laws. 

Personal Information Collected Directly from You. While the personal information we collect about you varies depending upon your use of our Services and our interactions with you, in general, we may collect the following personal information directly from you: 

When You Use the Site: 

  1. Identifiers and contact information. When contacting us through the Site, we collect your name and e-mail address, and any further personal information that you may choose to share with us.

When You Apply to be a Resident or are a Resident at a Property that we Manage: 

  1. Information that is reasonably required to process and manage your rental application or tenancy. This may include, but is not limited to: name, contact information (e.g. phone number(s), e-mail address(es), current and previous address(es)), preferred means of communication, employer and job title, income information, credit check information, date of birth, marital status, gender, government identification numbers (e.g. driver’s license number and/or social insurance number), vehicle license and registration numbers, pet information, and information about household members. 
  2. Communication and Interactions. When you email, call, chat, text, or otherwise communicate or interact with us, including if you complete forms on our Services, sign up for our mailing lists, or otherwise enter information into public-facing comment fields or forums sponsored by or affiliated with Hines, we may collect, process, and maintain records of your contact details, communications and interactions with us and others, including your posts or submissions, texts, information about the nature of your inquiry and our responses and any other information that you choose to provide.
  3. Property Use Details. We may also collect personal information related to your use of property and use of our Services, as well as other requests that you submit to us related to our Services. For example, if you register a guest or visitor(s) at a property, register your presence at our office(s), book the use of a desk or room at a property, request catering or other services, report facilities related issues or request maintenance services, etc. 
  4. Transactions and Billing Information. We also collect personal information about you in connection with a purchase or payment you submit to us. This may include collection of your name, address, payment method, payment history and other transaction details. 
  5. Promotional Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your profile, including the Services, Site and features you use in order to provide you with marketing communications about products and services we think you may like. If ‎you participate in special activities, offers, programs, promotions, or sweepstakes we ‎offer, we may also collect certain contact details, your age, and any other information ‎that may be required by law. If you win a contest, promotion, or sweepstakes, we may ‎also collect certain tax information and/or waivers and releases, depending on the prize ‎and as required by applicable law.‎
  6. Preferences and Other Requests. We may also collect information about your preferences, including communication preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us. 

Personal Information Collected and Processed Automatically. We may collect and process personal information about how you use our Services and your interactions with us and others, including information we collect automatically (e.g. using cookies), as well as information we derive about you and your use of the Services. Such information includes: 

  • Device and browser information: Like most websites and other internet services, we may use cookies, local shared objects, log files and other technologies to automatically collect certain technical and device information, including personal information, about you when you interact with our Services, including but not limited to, device ID, internet browser, language, computer operating system used, IP address, general location, domain name of your internet service provider, access times, referring and exiting URLs, and other and similar device and usage information.  
  • Activity and usage information: When you visit our Site, engage with the App and when you communicate with us, we may collect information, including personal information, about how you interact with us, such as domain name, pages you accessed and when, date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the Site, including content viewed or downloaded, features used, links clicked, etc. 

Children’s Information

Our services are not directed to children under the age of 18, or the age of majority in your jurisdiction, and we do not knowingly collect Personal Information from children under the age of majority without the consent of their parent or legal guardian. If such information is identified, we will delete it. To the extent we are collecting Personal Information of children with the consent of their parent or legal guardian, we are using such Personal Information consent with this Privacy Notice.

  1. SOURCES OF PERSONAL INFORMATION

We may collect Personal information from the following sources.

  • Direct information from you, e.g. by submitting a form;
  • Information captured through our website, e.g. by the use of cookies.

  1. PURPOSES FOR PROCESSING PERSONAL INFORMATION

a) Our (or relevant third parties) legitimate interests:

The processing of Personal Information is deemed necessary for our or relevant third parties’ legitimate interests, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subjects. This includes: 

  • Communication and support: To communicate with you regarding your rental application, tenancy, property management matters, and to respond to your inquiries and customer support requests.
  • Application and tenancy administration: To process and administer rental applications and tenancies, including conducting credit and reference checks, processing rent and other payments, and maintaining financial records.
  • Event and property management: To organize and manage events and property-related activities, including registration, attendance, facilitating connections with attendees and service providers, and providing information about relevant services.
  • Property management services: To deliver property management services, including handling maintenance requests, responding to complaints, and maintaining the safety and security of properties and residents.
  • Identity verification: To verify your identity where necessary.
  • Compliance with agreements: To monitor and enforce your compliance with tenancy agreements and other applicable terms.
  • Service improvement and operations: To operate, maintain, customize, and improve our services, including websites, applications, and related offerings.
  • Personalization and marketing: To better understand your preferences, tailor content and advertisements, and send you relevant information about our services or third-party offerings, where permitted by law.
  • Business operations and audits: To conduct financial, tax, and accounting audits, and to assess and improve our internal controls, security, and compliance processes.
  • Record keeping and governance: To maintain appropriate business records and enforce our policies and procedures.
  • Fraud prevention and security: To detect, prevent, and protect against fraud, errors, and security risks, including safeguarding our systems and conducting threat analysis.
  • Debt collection: To collect outstanding amounts owed to us.
  • Professional advice: To obtain legal, accounting, or other professional advice as needed.

b) Compliance with legal obligations:

We process Personal Information where such processing is necessary to comply with applicable laws, regulations, lawful requests, and regulatory obligations, including record-keeping, reporting, and cooperation with authorities.

c) Your consent: 

The processing of Personal Information is carried our based on the consent of the Data Subject for one or more specific purposes, such as sending out newsletters, promotional materials, and other electronic commercial communications you sign up for and any other purposes to which you have consented. 

  1. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will hold your Personal Information for as long as is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory or internal policy requirements.

  1. THE USE OF ARTIFICIAL INTELLIGENCE

We may use artificial intelligence (AI) and automated tools to support and enhance our services, including for data analysis, content generation, and process optimisation. All AI-based processing is carried out in accordance with applicable Data Protection Laws. Where AI systems involve automated decision-making that produces legal or similarly significant effects, we will inform individuals about this, including providing information on the logic involved, the significance of the processing and its potential consequences. Such processing is subject to appropriate safeguards, including human oversight, data minimisation, and regular accuracy and fairness assessments. We do not rely solely on automated decision-making without meaningful human involvement unless legally permitted and appropriately disclosed.

  1. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES 

In connection with one or more of the purposes outlined in the “How we use your personal data” section above, we could disclose Personal Data to:

  • Other members of the Hines Group. We will take steps to ensure that access to personal data is restricted to authorized employees who have a lawful basis to access your personal data and only for the purposes described in this Privacy Notice.
  • Professional advisors and third parties that provide services to us (such as IT systems providers, platform providers, financial advisors, consultants (including lawyers and accountants), providers of marketing services where we are permitted to disclose your personal data to them, and in all cases such transfers will be under a legal basis as set out in Section 2 of this Privacy Notice and subject to appropriate safeguards including data processing agreements where required; 
  • Competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request); and 
  • Any central or local government department and other statutory or public bodies where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request).

The Recipients may, under contractual obligations, legal or professional duty consistent with their relationship with us and this Privacy Notice, disclose the Personal Information to their agents and/or delegates (the “Sub-Recipients”), which shall process the Personal Information for their sole purposes of assisting the Recipients in providing their services to the Data Controller and/or assisting the Recipients in fulfilling their own legal obligations.

  1. INTERNATIONAL DATA TRANSFERS

As a global company we may need to transfer your Personal Information out of the country or jurisdiction in which it was originally collected. You should be aware that these countries may not have similar data protection laws to the country in which your personal data was originally collected. In such cases, Hines will ensure that there are adequate safeguards in place to protect your Personal Information with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Notice.

For transfer of Personal Information outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements, and Hines will take reasonable steps (for example through a contract with the overseas recipient) to ensure that the overseas recipient does not breach the applicable Data Protection Laws in relation to the Personal Information. 

You can obtain more details of the protection given to your Personal Information by contacting us as described below.

If you object to your Personal Information being transferred or used in this manner, please do not register with or use the Website.

  1. YOUR RIGHTS

You may have a right to access your personal information, to be informed how we process your personal information, or request correction of your personal information held by us: 

  • If you request a correction to your personal information and Hines is satisfied on reasonable grounds that there is an error or omission in your personal information, Hines will correct the personal information as soon as reasonably possible and send the corrected personal information to each third party to whom the personal information was disclosed, all in accordance with applicable law. If we do not correct the information, we will annotate it to show that a correction request was made. 
  • If you request to access your personal information and that request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you. 
  • You can opt of marketing communications at any time by unsubscribing, sending us an email, or writing to us at the contact details listed below. If you opt-out of marketing communications, we may still send you transactional communications to manage your tenancy or relationship with us.

These rights are not absolute, but subject to limits in applicable law. 

You also have the right to refer complaints to the Office of the Privacy Commissioner of Canada.

You can exercise these rights by contacting us by emailing us at

Canada.DPO@hines.com

.

  1. COOKIES AND SIMILAR TECHNOLOGIES

Our website uses cookies and similar technologies to enhance user experience, improve website functionality, and ensure security and compliance. Below, we provide a transparent explanation of the types of cookies we use, their purposes, and how you can manage your preferences.

Cookies are small data files stored on your device that help websites function effectively. Some cookies are session-based, meaning they are automatically deleted when you close your browser, while others are persistent, remaining on your device for a set period.

Additionally, we use similar technologies, such as local shared objects, which enhance your browsing experience by storing preferences and optimizing website functionality.

Third parties, including Google, Meta and X, may use cookies, web beacons, and other storage technologies (e.g. Facebook Pixel, X pixel, GA4) to collect or receive information from this website and elsewhere on the Internet and use that information to provide measurement services, target and deliver ads. You can opt-out of the collection and use of information for ad targeting and access a mechanism for exercising such choice through: 

http://www.aboutads.info/choices

or  

http://www.youronlinechoices.eu/

.

We transparently inform you about our use of cookies and similar technologies in the sections below. In case you would like to further understand more about these technologies, you can as well set your browser settings to inform you about the cookies or similar technologies downloaded to your device.

  1. Strictly Necessary Cookies:

These cookies are essential for website security, network management, and overall functionality. They enable key features such as page navigation and access to secure areas of the site.

  • Purpose: Ensure website operation and security.
  • Your Control: While you can disable these cookies in your browser settings, doing so may impair website functionality.

  1. Analytics Cookies: 

These cookies are used to collect aggregated information about how visitors use our website, helping us to understand website performance and improve functionality. Analytics cookies are implemented in a manner designed to minimize the collection of Personal Information, where possible. 

  • Purpose: 
    • Analyze website performance and usage patterns.
    • Improve website functionality and user experience.
  • Your control:
    • Analytics cookies will only be placed where permitted under applicable law.
    • You can manage your preferences and withdraw your consent at any time through our cookie settings.

  1. Optional Cookies:

All other cookies, including those for preferences, analytics, marketing, tracking, profiling, and chat functionality, will only be activated if you explicitly consent.

  • Purpose:
    • Store user preferences for a personalized experience.
    • Analyze website performance and user engagement.
    • Deliver targeted advertisements and measure marketing effectiveness.
    • Enable chatbot and interactive functionalities.
  • Your Control:
    • These cookies will not be placed on your device unless you opt-in.
    • You can manage your preferences and withdraw consent at any time through our cookie settings.

Regarding your cookie preferences, please note that when you click "dismiss" on the cookie banner, only Analytics and Strictly Necessary cookies are placed on your device. These cookies don't gather personal information. 

For more information on the specific cookies used, their purposes, and their retention periods, please refer to the cookie banner accessible via ‘Manage Cookie Preferences’. Additional details are available by expanding the banner

  1. SOCIAL MEDIA PLUG-INS

We place various social media buttons on our website in the form of a plug-in. The following are the social media buttons used:

  • Facebook
  • Instagram

Please be aware that when you visit a website that integrates social media plug-ins AND  you click on a social media button or link, certain data (such as your IP address, visited sites, and the date and time of access) may be forwarded to these social media platforms—even if you are not registered or logged in to those services.

If you are already logged into a social media service, the platform may link this data to your user profile, identifying your username and potentially even your real name.

We do not control the extent, nature, or purpose of such data processing by social media platforms. These services may create pseudonymized or individualized user profiles based on this data.

If you prefer not to share your data with these platforms, we recommend avoiding interaction with these links or plug-ins.

For more information on how these social media platforms handle your data, please refer to their individual privacy policies.

  1. THIRD -PARTY LINKED SITES 

Our website contains links to third-party websites, including social media sites, which may have privacy policies that differ from our own.

We are not responsible for the collection, use, or disclosure of information collected through third-party websites and expressly disclaim any liability related to such data processing. Additionally, we are not responsible for the accuracy, content, or privacy practices of these third-party sites.

Links to external websites are provided for convenience only, and your browsing, use, and interactions with these sites—including those that link to or from our website—are subject to their rules and policies. We strongly encourage you to review the Privacy Notice of any website you access through our platform.

Please note that if you provide Personal Information to us through a social media site or interact with social media content linked to our website, you consent to our use of that information in accordance with this Privacy Notice, as if the information had been submitted to us directly via our website.

  1. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update or modify this Privacy Notice from time to time. Any material changes will be reflected in an updated version of the Privacy Notice posted on our website. If you are subscribed to our marketing communications, we may also notify you of such changes through those channels, where appropriate.