Effective: January 29, 2021

We take seriously our obligation to protect the private and confidential information of our users. This Privacy Policy describes how we use and protect your personal data. It applies to Tenancy Ltd.’s website having the domain name www.tenancy.ca and mobile application (collectively, the “Software”). 

The terms “users” or “you” as used in this Privacy Policy, refer to landlords, tenants, property managers, and other users, who use the Software to search for properties to lease, landlords and property managers who list properties for lease on the Software and other users who use software or other tools or services we provide on a Software, including, but not limited to, property management tools. 

We use information collected about you as explained in this Privacy Policy. The Software may contain links to third party websites. We're not responsible for the privacy practices or the content of those websites. The Software may also contain links to terms of service and privacy policies of third party providers who provide tools or services on the Software. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those tools, services or websites. 

By providing information to us when listing a property, searching for a property, using any tool or service on a Software or otherwise using the Software, you expressly agree to this Privacy Policy and our Terms of Service. This Privacy Policy was last updated on the date set forth above and applies from that date. We may occasionally amend this Privacy Policy to reflect regulatory requirements, advances in technology, Software updates and changes in our information collection and disclosure practices, and other internal protocols. Any new policy will automatically be effective when it is published on the Software. You should therefore return here regularly to view our most up to date Privacy Policy. You should also print a copy for your records.

Your personal data (also referred to as personal information) - that is, data that identifies you, or from which you are identifiable - will be collected, processed, stored and used by us, and passed to and processed by Tenancy Ltd. and third parties acting on our behalf. We do not knowingly collect or process data from anyone under the age of eighteen (18) years old. 

Tenancy Ltd. may use various third party analytics softwares to gather statistics on Software usage. This may involve the use of cookies. You acknowledge and accept that Tenancy Ltd. does not have full control over the data collection of such third party analytics softwares. 

1. WHAT POSITIVE STEPS IS TENANCY LTD. TAKING TO PROTECT USERS PRIVACY?

• Simple user privacy settings to revoke individual or all applications to listings

2. WHAT KIND OF INFORMATION DO WE GATHER?  

At various times while using the Software you may give your personal data to us. For example, in order to send a residential tenancy application, we may need to know all or some of the following: your full name, address, telephone number, and e-mail address. You may also give personal data to us at other times, such as when registering on the Software or when submitting a listing for a residential tenancy. We also receive your personal information when you set up financial account information for payment processing. We may also gather information from cookies or web beacons. You can find out more about how they operate in the relevant section of this policy below. We also collect IP addresses, mobile device identifier details, your location, navigation and click-stream data, the time of accessing the Software, homes you viewed, what you searched for, the duration of your visit, and other details of your activity on the Software. If you ask us to connect with other websites (for example if you ask us to connect with your social media account) we may get information about you that way too. In connection with electronic communications we facilitate through the Software, we use electronic or manual checks to monitor such communications for trust and security purposes. For further details on how we collect personal data, see Surveys and Communications below. We obtain data from you either by you inputting your personal details, by the automatic collection of information about you as you use the Software, when we speak to you, or from third parties. Third party information may include financial information from our payment processor partners that we use to update our records and to prevent and detect fraud, information from your mobile provider if you are accessing the Software over a mobile device or information from a third party such as a social media or travel opinions software where you have asked us to share your data with them.

3. HOW IS YOUR PERSONAL DATA USED?  

Our primary purpose in collecting your personal data is to provide you with the services you request and those which we believe will optimize your use of the Software. You agree that we may use your personal data for the following purposes: 

• For the services provided on the Software or to support your request; 

• To contact you from time to time with user or service updates; 

• To send other messages that help us provide our services on the Software; 

• To assist people you have done (or have agreed to do) business with. For example, if you have submitted a residential tenancy application, processing the details of such application to the landlord or property manager;

• To customize, measure, report on and improve our services, content and advertising;

• To promote services related to the Software or those of Tenancy Ltd.;  

• To compare information for accuracy, update our records, and verify it with third parties;

• To prevent, investigate or prosecute activity we think may be potentially illegal, unlawful or harmful; and

• To enforce our Privacy Policy and/or our Terms of Service or any other purpose referenced herein or therein.

We collate statistics about Software traffic, sales and other commercial information which we pass onto third parties to assist us with improving the services we provide to you. We also use demographic information to tailor the Software and we share that information with third parties so that they can build up a better picture of our customer base and general consumer trends. If you are a landlord or manager, we may also display your phone number on the listing itself so that potential tenants may contact you and to restrict fraudulent behavior. We may also contact you about your account and your use of our services.

4. HOW WE MAY DISCLOSE YOUR PERSONAL DATA?  

We may disclose your personal data to enforce our policies, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, or in connection with actual or proposed litigation, or to protect our property, people and other rights or interests. 

We may also share your personal data with:

• One of our partners if you've requested their services or if you’ve requested to be provided with information by them;

• Another member if you have done business with them;

• A third party performing services on our behalf, such as to process payments;

• Subsidiaries or affiliates of Tenancy Ltd; 

• Other companies or business entities, for example if we are considering a merger with or sale to that company or business entity;

• Other companies we work with to feature all or part of the property listings or otherwise provide promotional or other services related to Tenancy Ltd.’s business. This might include featuring your listings and photographs on other websites; 

• Any third party you have asked us to share your personal data with – such as social media account if you have asked us to connect with your social media account; or

• Any legal or governmental entity pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments.

You may have accessed our Software through a hyperlink from the website of one of our partners. If so, you consent to your personal details and purchase information, including behavioral patterns, being shared with that trading partner in accordance with our contractual relationship with them.

In the event that Tenancy Ltd. is sold, or some of its assets are transferred to a third party, your personal information, as a valuable asset, may also be transferred. Potential purchasers and their advisors may have access to data as part of the sale process. We will request the acquiring party to follow the practices described in this Privacy Policy with respect to previously collected information. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy. Similarly, your personal information may be passed on to a successor in interest in the event of a liquidation, bankruptcy, or administration. Our customer database could be sold separately from the rest of the business, in whole or in a number of parts. 

Communications

We may offer different communications from time to time intended to enhance the services we offer. Users may cancel their subscription to these communications at any time, although there may be a delay for the changes in your preferences to become effective.

Surveys

We also use surveys to collect information about our users. From time to time, we request users' input in order to evaluate potential features and services. The decision to answer a survey is completely yours. We use information gathered from surveys to improve our services.

Mobile Applications

When you download or use apps relating to our Software, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to turn off location services. If you have questions about how to disable your device's location services, we recommend you consult your device’s manual, or contact your mobile service carrier or your device manufacturer.

Telephone Calls

As well as collecting data online and from correspondence we may also speak with you face to face or by telephone. We may record telephone conversations for quality assurance and training purposes. This Privacy Policy also governs those recordings and we keep this data in the same way that we keep other data. Recordings of calls may also be transferred to locations or processed worldwide.

Inquiries and other Electronic Communications

Potential tenants may send inquiries to landlords or property managers via clickable links on the property listings on the Software. Further, tenants, landlords and property managers may communicate with each other via tools on the Software. If you choose to send an inquiry or booking request through these links, your personal information, including your email address and any other information you supply (unless the Software specifies otherwise), will be visible to the tenants, landlords, and property managers in question so that they might reply directly to you. Your details may also be sent to us and we have access to those communications even if you contact the tenant, landlord, or property manager directly. If tenants, landlords, and property managers further engage in communications through the Software, we also have access to those communications, which we monitor for compliance and security purposes. Additionally, those inquiries and messages may be hosted on, be processed by or transmit through our servers. If you engage in such communications and call the other party, you may be asked to leave a return telephone number. Do not share information in the e-mail or phone call that you are not prepared to allow such person and Tenancy Ltd. to have, including, but not limited to, credit card and bank account information. In addition, inquiries and messages can be sent to the individual member you selected and to our system. Our customer service team may share such communications with landlords and property managers. We may also from time to time, use third party e-mail servers to send and track receipt of such communications, and analyze the pattern of such communications for trust and security purposes as well as to gather data, such as inquiry and booking data (on an anonymous basis), to assist us in better understanding our business.

5. WHAT IS YOUR ROLE IN PROTECTING YOUR PRIVATE DATA?  

Further to paragraph 1 above, we take technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Software reduce our vulnerability to security problems to a level appropriate to the type of data involved. We have security measures in place to protect our user database and access to this database is restricted internally. However, it remains your responsibility:

• To protect against unauthorized access to your use of the Software;

• To ensure no one else uses the Software while your machine is logged on to the Software (including by logging onto your machine through a mobile, Wi-Fi or shared access connection you are using);

• To log off or exit from the Software when not using it;

• Where relevant, to keep your password or other access information secret. Your password and login details are personal to you and should not be given to anyone else or used to provide shared access for example over a network; and

• To maintain good internet security. For example, if your email account or social media account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us.

You should keep all of your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can, so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.

If you have asked us to share data with third party websites (such as a social media account), their servers may not be secure. Payment card and bank account information is generally stored by our payment processing partners and we contractually require them to keep that data secure. We also use third parties to help us optimize our Software flow, content and advertising (see below). 

Note that, despite the measures taken by us and the third parties we engage, the Internet is not fully secure. As a result, others may nevertheless unlawfully intercept or access private transmissions or data.

6. WHAT ARE COOKIES, WEB BEACONS AND CLEAR GIFS AND WHAT IS THEIR USE? 

A "cookie" is a small file placed on your hard drive by some of our web pages. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major websites in much the same way we use them with our Software. You may delete and block all cookies from this Software, but parts of the Software will not work. 

Even if you are only browsing the Software, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Software) is automatically collected about you. This information will be collected every time you access the Software and it will be used for the purposes outlined in this Privacy Policy.

You can reduce the information cookies collected from your device. An easy way of doing this is often to change the settings in your browser. If you do that you should know that (a) your use of the Software may be adversely affected;

(b) your experience of this and other websites that use cookies to enhance or personalize your experience may be adversely affected; and 

(c) you may not be presented with advertising that reflects the way that you use our and other websites. 

Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as you visit our Software. By using the Software you consent to this, unless you change your browser settings. 

We gather and share information concerning the use of the Software by tenants, landlords, and property managers with one or more third-party tracking companies for the purpose of reporting statistics. To do this, some of the pages you visit on our Software use electronic images placed in the web page code, called pixel tags (also called "clear GIFs" or "web beacons") that can serve many of the same purposes as cookies.

Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Software and to help determine how you found the Software. 

Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

7. PHISHING OR FALSE EMAILS

If you receive an unsolicited email that appears to be from us or another user that requests personal information (such as your credit card, login, or password), or that asks you to verify or confirm your account or other personal information by clicking on a link, that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a "phisher “or "spoofer." We do not ask for this type of information in an email. Do not provide the information or click on the link. Please contact us at Customer Support if you get an email like this. 

8. HOW DO I CORRECT OR UPDATE MY INFORMATION?

If you are a tenant, landlord, property manager, or other user the best way of seeing any personal information processed by uses to log on to your account by using the ‘Account’ tab at the top of the screen. You can see your basic details and correct or update them there at any time to suit you. We also want to give you the opportunity to identify any inaccuracies in any other information we hold about you. Where possible, if we’re told about the inaccuracy of any personal information, we will make appropriate corrections. You can ask to see, update or amend any information we hold on you by contacting us using the information below. We may not be able to delete your personal information without also deleting your user account. You will not be permitted to examine the personal information of any other person or entity. In order to verify your identity, you may be required to provide us with personal information prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

9. HOW DO I OPT-OUT OF RECEIVING MARKETING COMMUNICATIONS FROM YOU?

We will contact you from time to time for marketing purposes. Unless you have opted out, this could include contacting you by phone or email.

You may opt-out of receiving marketing communications from us by the following means:

1. Contact us at Customer Support;

2. Follow the instructions included in each communication or newsletter;

3. Use the Unsubscribe function;

4. Mail the request to us at support@tenancy.ca.

Please remember that if you change your preferences it may take a short time for those preferences to become effective.

10. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will retain your personal data only as long as is necessary for the purposes to which you consent under the Terms of Service and this Privacy Policy, or as is required by applicable law, and then we will delete it.

Reach out to us and we'll do our best to help:

legalteam@tenancy.ca