Facial Detection Cameras in Digital Ads Near Toronto's Union Station Scanned Commuters Without Consent for Three Years
Undisclosed facial detection technology operated for approximately three years in one of Canada's busiest transit corridors — scanning an estimated 250,000–300,000 daily commuters — before a Reddit user noticed a small camera and disclaimer. The technology and corporate claims are similar to the Cadillac Fairview case, where the same type of AVA technology and similar assurances of "no data stored" were found by the OPC to be misleading. The case involves the question of whether meaningful consent is possible in a transit environment where people cannot practically avoid the technology.
Narrative
Beginning in approximately late 2022, Cineplex Digital Media installed digital advertising screens equipped with small cameras in the entryway to Toronto’s Union Station Bus Terminal — Canada’s busiest multi-modal transit hub, serving an estimated 250,000–300,000 people daily. The cameras used Quividi’s AVA audience measurement software to detect faces in real time, estimate each viewer’s age range and gender using neural networks, and dynamically select which advertisement to display based on the inferred demographics.
The screens operated for approximately three years with no public awareness. A small disclaimer embedded in the displays stated that “anonymous software” generated “statistics about audience counts, gender and approximate age only” and that “no images and no data unique to an individual person is recorded.” On November 2, 2025, a Reddit user posted a photo on r/Toronto showing the camera and disclaimer, sparking immediate public concern and media coverage.
Five days after the Reddit post went viral, on November 7, 2025, Cineplex Inc. completed the sale of its digital media division to Creative Realities Inc. (CRI), a US-based digital signage company, for C$70 million — a deal that had been announced earlier. CRI did not respond to media inquiries about the facial detection controversy.
Grassroots advocacy organization Technologists for Democracy, co-signed by OpenMedia and transit advocacy groups, filed a formal complaint with the Office of the Privacy Commissioner. On December 8, 2025, Privacy Commissioner Philippe Dufresne opened an investigation into whether the technology complies with PIPEDA.
The case has notable parallels to the 2020 Cadillac Fairview case. Cadillac Fairview used the same type of AVA technology in mall kiosks, made similar claims that “no personal information” was collected and images were “deleted immediately,” and the OPC investigation found these claims to be misleading — over five million facial representations had in fact been captured and retained. Privacy experts have noted that corporate self-attestation about data deletion was found to be misleading in the Cadillac Fairview case, and have questioned whether meaningful consent is achievable in a transit corridor where commuters cannot practically avoid the technology.
As of March 2026, the OPC investigation remains active, no screens have been reported removed, and Creative Realities has not made a public statement addressing the controversy.
Harms
Digital advertising screens equipped with cameras captured and analyzed the faces of an estimated 250,000–300,000 daily commuters passing through the Union Station Bus Terminal entryway to estimate their age and gender and dynamically target advertisements, without meaningful informed consent. The screens operated for approximately three years before public discovery.
A small disclaimer on the screens was the only notice provided. No opt-in consent mechanism existed, and commuters had no practical way to avoid the cameras while using the transit corridor — an environment where meaningful consent may not be achievable.
Affected Populations
- commuters using Toronto's Union Station Bus Terminal
- transit users in the Greater Toronto Area
- Canadian public
Entities Involved
Installed and operated the facial detection advertising screens near Union Station Bus Terminal as part of its DOOH network; sold to Creative Realities Inc. in November 2025
US-based digital signage company that acquired Cineplex Digital Media for C$70 million in November 2025, inheriting the facial detection advertising network
French company providing the AVA audience measurement software that uses computer vision and neural networks for real-time facial detection and demographic estimation
Opened investigation in December 2025 into PIPEDA compliance of the facial detection advertising technology following a formal complaint
AI Systems Involved
The facial detection and audience measurement software embedded in digital advertising screens, using cameras to capture faces and estimate demographics in real time to select targeted advertisements
Responses & Outcomes
Opened formal investigation into privacy concerns related to digital signs near Union Station that use facial detection software, examining PIPEDA compliance
AI System Context
Quividi's AVA audience measurement platform, a computer vision system embedded in digital advertising screens operated by Cineplex Digital Media (later Creative Realities). Small cameras capture images of passersby, neural networks detect faces and estimate age range and gender in real time, and the system dynamically selects advertisements based on the inferred demographics. The operator claims images are processed in milliseconds and immediately deleted.
Preventive Measures
- Require express opt-in consent before deploying any biometric or facial analysis technology in spaces accessible to the public, consistent with OPC guidance on biometrics
- Mandate prominent, clearly visible signage disclosing the use of facial detection or analysis technology, going beyond small disclaimers embedded in the advertising displays
- Require privacy impact assessments before deploying facial detection systems in transit corridors and other spaces where people cannot reasonably avoid the technology
- Establish enforcement mechanisms with meaningful financial penalties for undisclosed or inadequately disclosed biometric data collection
- Require independent third-party audits of corporate claims about data deletion and non-retention in facial analysis systems
Materialized From
Related Records
Taxonomy
Sources
- Privacy commissioner launches investigation after facial detection ads pop up in Toronto
- 'I didn't sign up for this': Facial detecting ads near Toronto's Union Station raise concerns
- Canada's privacy commissioner probing facial detection ads near Union Station
- What to know about the ads that could be recording you on the way to Union Station Bus Terminal
- Privacy watchdog investigating controversial facial recognition ad at Toronto's Union Station
- These ads near Union Station and other places around Toronto could be recording you
- Canada Opens Privacy Probe Into DooH Screens Near Toronto's Union Station
- Advocates demand answers about billboards with facial detection tech near Union Station
- Joint investigation of Cadillac Fairview — PIPEDA Findings #2020-004
Changelog
| Version | Date | Change |
|---|---|---|
| v1 | Mar 8, 2026 | Initial publication |