Privacy Policy

University District Trust

Privacy Policy

1. Introduction

The University District Trust, by its trustee University of Calgary Properties Group Ltd. (the “Trust”, “we”, “us”, or “our”), respect the privacy of our website users (“you”) and are committed to protecting it through our compliance with this Policy.

This Policy describes the types of information we may collect from you or that you may provide to us when you visit the websites located at ucpg.ca and myuniversitydistrict.ca (together, our “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy describes how we collect, use, retain, and disclose your personal information in connection with your visit to and use of the Website, including our blog and other Website-related social media. It describes the types of information we may collect from you or that you may be asked to provide when you access or use the Website, and our practices for collecting, using, retaining, and disclosing that information.

Please read this Policy carefully to understand our policies and practices for collecting, using, retaining, and disclosing your information. If you do not agree with this Policy, do not access, use, or provide any information on the Website. By accessing or using the Website, or continuing to do so, you acknowledge and agree that you understand, accept, and consent to this Policy.

This Policy and our privacy practices are developed with regard to applicable privacy laws. This Policy will be reviewed and may be updated periodically to reflect any changes in the way we handle your personal information and/or changes to applicable privacy laws. It is our policy to post any updates we make to this Policy on the Website. The date the Policy was last revised is at the bottom of the Policy. Any and all such updates are effective immediately upon posting and apply to all access to, use of, and continued access to and use of the Website. You are responsible for periodically visiting the Website and this Policy to check for any updates. Your continued use of the Website after we make updates indicates that you understand, accept and consent to those updates.

We will only use your personal information in accordance with this Policy unless otherwise in accordance with or required by applicable laws. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes, as set out further below.

For the purposes of this Policy, “personal information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Examples include your legal name, address, phone number and email address. Personal information does not include business contact information.

2. What does this Policy cover?

This Policy applies to personal information we collect, use, retain or disclose:

to, from or on the Website;
to, from or in emails, texts, posts, and other electronic messages and communications between you and the Trust to or through the Website; and
when you interact with our advertising and applications to the extent those applications or advertising include links to the Website and/or this Policy.

This Policy does not apply to personal information collected by:

the Trust offline or through any other means, including on any other website operated by the Trust, its trustee, or their affiliates; or
any third party, through any application or content (including advertising or applications) that may link to, be linked from, or be accessible from or on the Website.

The Website may include advertising or links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you, including your personal information. If you follow a link to a third-party website or engage a third-party plugin, please note that this Policy does not apply and we do not accept any responsibility or liability for any personal information collected, used, retained or disclosed by such third parties. We do not monitor, verify or control these third-party websites, and we encourage you to review any applicable policies or procedures of such third parties with respect to your privacy and your access or use of such websites.

This Policy is intended to apply to Website visitors residing in or accessing the Website from Canada. Non-Canadian visitors may access or use the Website, but they may be governed by privacy policies applicable to the countries in which they reside or from which they access the Website.

3. Minors

The Website is not intended for persons under 18 years of age. No person under the age of 18 years may provide any personal information to, from, or on the Website, unless otherwise with the authorization of their parent or legal guardian.

We do not knowingly collect personal information from minors under the age of 18 years, without the prior, verifiable consent of a parent or legal guardian. If you are under the age of 18 years, do not access, use or provide any information on the Website.

If we learn we have collected or received personal information from a minor under the age of 18 years without verification of parental consent, we will promptly delete that information. Parents or legal guardians may have the right, upon request, to view the information provided by the minor, and where appropriate, require that it be deleted. If you believe we might have any information from or about a minor under the age of 18 years, please contact us at privacy.officer@ucpg.ca.

4. Collection and use of personal information

We use different methods to collect your personal information. Some of your personal information is collected automatically, while other personal information may be provided to us directly, such as through filling-in forms, completing survey questions, subscribing to our newsletters or mailing lists, or registering for an event.

We collect personal information that can help us improve the Website, as described further below under the headings “Automatically collected information”, “Information that you provide to us”, and “Use of cookies and other technologies”. We may collect certain personal information that does not directly identify you by name, but could be used to identify that a specific computer or device has accessed the Website. This information collected automatically is stored in an aggregate form and cannot be used to identify you.

We may collect personal information that can reasonably be used to directly or indirectly identify you, being your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the internet, and user name or other similar identifier. We may use this information to contact you online or offline.

We will only use your personal information for the purposes and reasons specified in this Policy or during the collection process, to which you consent, or as otherwise permitted or required by applicable laws, being the following purposes:

to present the Website and its contents to you;
to provide you with information, products, or services that you request from us;
to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts we may have with you (or that we are in the process of entering into with you), including for billing and collection purposes or to comply with legal requirements;
to notify you about changes to the Website or any information, products or services we offer or provide though the Website;
to improve the Website, information, products or services, marketing, or customer relationships and experiences;
to allow you to participate in interactive features, social media, or similar features on the Website, including our blog;
in any other way we may describe when collecting the information and when you provide the information; and
for any other purpose with your consent.

We may use the personal information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement or application, the advertiser may assume that you meet its target demographic or criteria.

a. Automatically collected information

The Website logs inquiries and accesses by visitors and automatically stores this information as server log files. Server log files are used to analyze how you interact with the Website and for statistical purposes. We may maintain this automatically collected information separately or associate it with personal or non-personal information we collect in other ways or receive from third parties.

The following types of information are logged in this way:

your IP address;
your location;
technical information, including: your login information; the internet browser type and version you are using; time zone setting; browser plug-in types and versions; operating system and platform; information about your internet connection; the equipment you use to access or use the Website, and usage details; and
information about how you interact with the Website, including: the date and time you spend on the Website’s webpages; the source and terms used to request or find the Website; information, products, services or offerings that you viewed or searched for; clickstream to, through and from the Website including the preceding and subsequent pages that you have viewed; the full Uniform Resource Locators (URLs); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.

This type of information helps us to improve the Website and to deliver a better and more personalized service, including by enabling us to:

estimate our audience size, demographic and usage patterns;
customize the Website according to your individual interests and preferences;
facilitate more efficient and quicker searches; and
recognize you when you return to the Website.

b. Information that you provide to us

In connection with your use of the Website, we may collect information directly from you or through the Website if you provide us with personal information, including through direct interactions with us, for example, by filling-in forms, subscribing to newsletters or mailing lists, signing-up for or requesting more information about programs or services, signing-up for promotions or contests, registering for an event, or when you utilize the contact form on the Website or correspond with us by phone or email, or when you report a problem with the Website. This collected information includes:

personal information that can reasonably be used to directly or indirectly identify you, being your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the internet, and user name or other similar identifier. We may use this information to contact you online or offline; and
non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, demographic information, information such as search terms used on the Website, or statistical or aggregated information. This statistical or aggregated data does not directly identify you, but we may derive non-personal statistical or aggregated data from this information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to or using the Website at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee the authenticity of anyone who may view or interact with your User Contributions or the security of your User Contributions.

c. Use of cookies and other technologies

In connection with your access to and use of the Website, we use browser cookies, flash cookies and web beacons. Each of these is described further below:

Browser Cookies: We use browser cookies, which are small text files that are temporarily or permanently placed on the hard drive of your computer or mobile device. Each cookie is uniquely assigned to your web browser and can only be read by that browser. Each cookie contains some anonymous information and allows the Website to recognize you and to remember your preferences. You may refuse to accept all or some browser cookies, or to alert you when cookies are being sent, by activating the appropriate settings on your browser. However, if you select these settings, you may be unable to access or use certain parts of the Website or the Website may not function properly. Unless you have adjusted your browser settings so that it will disable or refuse cookies, our system will issue cookies when you direct your browser to the Website.

Flash Cookies: Certain features of the Website may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings that are used for browser cookies (discussed above). To learn how you can manage your flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, you may be unable to access or use certain parts of the Website or the Website may not function properly.

Web Beacons: Certain pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages of the Website or and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

As you navigate through and interact with the Website, we may use the cookies and automatic data collection technologies described above to collect certain information about your equipment, browsing actions, and patterns. This information includes:

details of your visits to the Website, including traffic data, logs and other communication data and the resources that you access and use on the Website; and
information about your computer and internet connection, including your IP address, operating system, and browser type.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies or beacons on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver advertisements tailored to your preferences and usage patterns.

d. Use of third parties or publicly available sources

We may also collect your personal information from third parties or publicly-available sources, for example, business partners and service providers who provide us with data storage solutions.

5. Data security

The security of your personal information is very important to us. We use physical, electronic, organizational and administrative measures designed to secure your personal information from accidental loss, theft or unauthorized access, retrieval, disclosure, use or alteration.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information or User Contributions posted on or transmitted to or using the Website. Any posting or transmission of personal information, including User Contributions, is at your own risk. We are not responsible for unlawful interception or access, or circumvention of any privacy settings or security measures contained on the Website.

6. Retention of personal information

Except as otherwise permitted or required by applicable laws, we will only retain your personal information for as long as necessary to fulfill the purposes described in this Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once it is determined that your personal information is no longer needed, it will be securely deleted.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

7. Disclosure of personal information

Subject to applicable laws, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Subject to applicable laws, we may disclose your personal information in the following circumstances to the following persons or entities:

to our affiliates;
in accordance with applicable laws, to a successor of the Trust in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other transfer or consolidation of some or all of the Trust’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Trust about the Website users is among the assets transferred;
to our contractors, service providers, and other third parties we use to support our business and the purpose of the Website (such as analytics and search engine providers that assist us with Website improvement and optimization or providers of communication tools, such as our newsletter provider) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards as set out in this Policy;
to fulfill the purpose(s) for which you provide it;
with your consent;
to comply with any court order, law, or legal process. In such cases, we may collect, use, retain and disclose your personal information without notice or consent, as may be required;
to respond to any government or regulatory request, in connection with reporting or other regulatory obligations;
to enforce or apply our Terms and Conditions of Use;
in certain circumstances where we may be permitted by applicable laws to disclose personal information without your consent, such as if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of you, the Trust, Website users, our customers, or others.

8. Transferring your personal information

We may transfer personal information that we collect or that you provide to us as described in this Policy to contractors, service providers, and other third parties we use to support our business and the purpose of the Website (such as analytics and search engine providers that assist us with Website improvement and optimization or providers of communication tools, such as our newsletter provider) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards as set out in this Policy.

We may process, store, and transfer your personal information in and to the cloud, or our third-party service providers in Canada, the United States, or elsewhere outside of Canada. Accordingly, your personal information may be transferred outside of Canada to a country that has different privacy laws that may or may not be as comprehensive as the privacy and data protection laws of Canada. In these circumstances, such personal information will be subject to the legal requirements of the applicable foreign jurisdiction(s) and may be accessible to governments, courts, law enforcement, or regulatory agencies in each jurisdiction where it is accessed or stored. Whenever we engage a third-party service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy laws.

Please note that we may change or add third-party service providers at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to refer to our Policy, as it may be updated from time-to-time, to obtain updated information about our service providers.

We will never transfer or sell personal information of the Website visitors to a third party unless such transfer is in compliance with applicable privacy laws.

By accessing and using the Website, submitting your personal information, posting a User Contribution, or engaging with the Website, you consent to this transfer, storage, and/or processing.

To obtain further information about our policies and practices relating to our service providers (inside and outside of Canada), please contact us at privacy.officer@ucpg.ca.

9. Accessing and correcting your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct or update the personal information that we hold about you.

If you would like to review, verify, correct, update or delete any personal information that we hold about you, you may send us an email at privacy.officer@ucpg.ca. We may not accommodate a request to change information if we believe the change would violate any applicable laws or cause the information to be incorrect. We may charge you a fee for any reasonable costs incurred in connection with accessing or printing your personal information, however, we will notify you of any such fee in advance.

We may request specific information from you to help us confirm your identity and your right to review, verify, correct or delete your personal information. Applicable laws may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with applicable laws or our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy laws. Examples of such exceptions include:

information protected by solicitor-client privilege;
information that is part of a formal dispute resolution process;
information that is about another individual that would reveal their personal information;
confidential commercial information; or
information that is prohibitively expensive to provide.

10. Consent

By accessing or using the Website or clicking on our targeted links, or subscribing to our marketing or other communications, you consent to the collection, use, retention and disclosure of your personal information for the purposes set out above.

You may withdraw your consent at any time, subject to legal and actual circumstances. To withdraw your consent, if applicable, contact us at privacy.officer@ucpg.ca. Please note that if you withdraw your consent, it may affect our ability to communicate with you or provide you with particular information, products or services. We will explain the impact to you at the time to help you with your decision.

We will seek your consent before using your personal information for any purposes beyond the scope of the original consent, except where required or permitted by applicable laws.

11. Disclaimer

University of Calgary Properties Group Ltd. is the trustee of the Trust, and has prepared this Policy solely in its capacity as trustee on behalf of the Trust. Any obligations of the Trust hereunder shall not be binding upon University of Calgary Properties Group Ltd. other than in its capacity as such, nor shall the obligations hereunder be binding upon any beneficiary of the Trust such that any recourse against the Trust, University of Calgary Properties Group Ltd. or any beneficiary of the Trust in any manner in respect of any obligation or liability arising hereunder or arising in connection herewith or from the matters to which this Policy relates, including without limitation, statutory claims related to privacy or claims made in negligence or otherwise tortious behaviour, shall be limited to, and satisfied only out of the assets of the Trust.

12. Contact information

We welcome your questions, comments, and requests regarding this Policy and our privacy practices at any time. This includes requests to access, correct or update your personal information; questions about collection, use, protection, retention and disclosure practices and procedures; questions about the handling of personal information by our service providers; and withdrawing your consent.

Please contact UCPG’s Privacy Officer with all such requests at:

403.910.1101
privacy.officer@ucpg.ca

University of Calgary Properties Group Corporate Office
405, 3917 University Avenue NW
Calgary, AB T3B 6K3

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact us using the contact information listed above.

This Policy was last updated June 2024.