The "PROPRIOLOCATION" Platform's privacy regulations aims to inform users about the manner in which their personal data (the "Personal Data") is processed by PROPRIOLOCATION" in the context of their use of the Platform and its Services.
PROPRIOLOCATION attaches great importance to the protection of Personal Data in the way the Platform has been created, organised and implemented. As data controller, PROPRIOLOCATION mc complies with the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA) of the Office of the Privacy Commissioner of Canada - updated June 4, 2020.
All Users are therefore invited to carefully read this Personal Data protection charter, which is an integral part of the general conditions of use of the "PROPRIOLOCATIONmc" Platform.
2. CATEGORIES OF DATA PROCESSED?
The data processed by PROPRIOLOCATION are:
To create a User's account:
- its identification data, such as, for example, first and last name, address, date of birth,
- its contact data, such as, for example, contact details, telephone number or e-mail address,
- his transaction data, such as, for example, his payment information
For the use of the Platform :
- its connection data, such as, for example, its IP address, its logs,
- any other data that the user himself provides in the context of the use of the Services or that PROPRIOLOCATION collects with his consent to provide him with the Services or for specific processing,
- any other data provided to the user by a third party necessary in connection with the use of the Services,
- the obligatory or optional nature of the data that the user provides is also indicated at the time of collection by an asterisk.
3. USE OF PERSONAL DATA
PROPRIOLOCATION collects and processes Users' Personal Data for :
- creating and administering their accounts and ensuring contact between Users when creating Rental and Lease applications,
- ensure the proper functioning of the Platform and the PROPRIOLOCATION services and preserve their security and integrity,
- respond to requests for technical support or support relating to the use of the Platform,
- improve the user experience and offer new functionalities.
- Collect statistical information on non-nominative data in order to provide value-added information to the user
4. LEGAL BASIS
The processing of Users' Personal Data is justified on the following grounds:
- either because it is necessary for the execution of the contractual relationship with PROPRIOLOCATION to provide the Services such as completing and having signed a rental application, completing and having signed a lease, providing customer support, allowing Users to carry out transactions, providing hosting and computer maintenance;
- or because it is necessary for the pursuit of the legitimate interests of PROPRIOLOCATION mc, such as, for example, to ensure a better functioning of the Services, improve the user experience or establish audience metrics;
- or because it requires the user's consent, for example, to send him/her personalised advertising or to allow him/her to share on social networks or to deposit cookies;
- or because it is necessary to comply with legal and regulatory obligations of PROPRIOLOCATION.
5. RESPONSIBILITY FOR THE PROCESSING OF PERSONAL DATA
The person who collects and processes Personal Data may have, depending on the processing carried out, the quality of data controller, joint data controller or processor.
The controller is defined as the natural or legal person who alone or jointly with others determines the purposes and means of the processing. The processor is defined as the natural or legal person who processes personal data on behalf of the controller. The processor thus acts under the authority of and on the instructions of the controller.
PROPRIOLOCATION acts as the controller of the processing of Users' Personal Data collected during their registration to the Platform, their use of the Services, their requests for technical or customer assistance from PROPRIOLOCATION's teams or when sending promotional messages presenting the Platform's new functionalities.
6. PERSONAL DATA OF CHILDREN COLLECTED?
PROPRIOLOCATION's services are not intended for children and PROPRIOLOCATION does not collect or solicit Personal Data from children under the age of sixteen for whom parental consent to the collection of Personal Data must be obtained.
7. USER RIGHTS
If the user wishes to correct, delete or object to the processing of his/her Personal Data because he/she contests its accuracy, he/she may send a request by e-mail to the following address: firstname.lastname@example.org
The User must indicate his/her identity, contact details, the purpose of the request (access, correction, deletion, opposition, limitation, etc.), the Personal Data concerned and accompany it with a copy of his/her identity document.
The request will be processed by the PROPRIOLOCATION teams within thirty (30) days of receipt.
Subject to its legal obligations of conservation and within the limit of the user's rights, PROPRIOLOCATION may, if necessary, correct, update, delete the Personal Data, stop or limit their processing. PROPRIOLOCATION may, in fact, keep the Personal Data in its archives in order to resolve disputes, to enforce its rights or because of its legal obligations or compelling legitimate interests.
8. STORAGE OF PERSONAL DATA AND RETENTION PERIOD?
PROPRIOLOCATION keeps the Personal Data for a period not exceeding that which is necessary for the purposes for which they are collected and processed and, in any case, in accordance with the required legal requirements.
Personal Data is subsequently deleted or irreversibly anonymized by PROPRIOLOCATION or archived in an intermediate database if necessary, to reserve the possibility of proving one's rights or to comply with one's legal or regulatory obligations and for the duration prescribed by law (i.e. the period prescribed by law for each legal obligation).
A rental application has:
- A lifespan of 14 days from the date the application is created, after which all personal data disappears from the system.
- A 48-hour delay is triggered when a request is sent by email or SMS for the prospective tenant to complete and sign it. After this delay, the link no longer works, and the request appears in the EXPIRED column where the landlord can send it again with the icon provided for this purpose (paper aeroplane). This action triggers a new 48 hour delay and returns the request to the IN PROGRESS tab.
- After 14 days, all requests are listed in the HISTORY tab and no longer contain personal information.
- The action of trashing or deleting a request (regardless of the tab where the request to be deleted is located) permanently deletes the request and makes it disappear from the platform.
An electronic lease has:
- Unlimited lifetime from the date of creation of the application.
- The action of trashing or deleting a lease (regardless of the status of the lease) permanently erases the lease and removes it from the platform.
9. SHARING OF PERSONAL DATA
The Users' Personal Data is shared with the external service providers of PROPRIOLOCATION such as, for example, the pre-hire survey, payment and emailing service providers who use them for the aforementioned purposes, as well as with the internal teams of PROPRIOLOCATION.
When Personal Data is transferred to these third-party service providers, PROPRIOLOCATION ensures that they offer guarantees equivalent to its own and requires that they adhere to its personal data protection charter, that they comply with its procedures and that they preserve the confidential nature of the Personal Data to which they have access in the context of their services on behalf of PROPRIOLOCATION. Its partners are prohibited from using its Personal Data for other purposes or for other purposes without the user's consent.
The user is informed of the obligations incumbent upon him/her as data controller, and in particular the respect of rights and in particular, the right to access, oppose and rectify information concerning them.
The user engages his responsibility in case of non-respect of the present obligations and guarantees and will indemnify PROPRIOLOCATION and its service providers against any action, claim or demand introduced by an authority or a third party following any failure on his part under the terms of the present article.
Finally, PROPRIOLOCATION may be obliged to communicate the Personal Data to other competent authorities in order to enforce its rights conferred by law or to comply with the law or a decision of a court issued by a governmental entity or any other competent authority. Unless required by law or a court order, PROPRIOLOCATION is not obliged to give notice of such disclosures of Personal Data.
10. SECURITY OF PERSONAL DATA
PROPRIOLOCATION implements appropriate organisational and technical measures in order to guarantee a level of security adapted to the Personal Data processed, in particular through data back-up measures, control of persons having access to the data, the introduction of an identifier and passwords to access the data and the data carrier, data segregation and protection against attacks.
Cookies are tracers deposited and read during the consultation of a site, the reading of an e-mail, the installation or use of a mobile application, whatever the type of terminal used such as a computer, a tablet or a telephone.
The User has the possibility of refusing the deposit of a cookie on his hard disk. However, he is informed that the Services may not function correctly.
The User also has the possibility of deactivating cookies, after accepting their deposit on his hard disk, by configuring the parameters of his browser so that it blocks them in whole or in part.
For more information on cookies, Users may refer to the following website: http://www.allaboutcookies.org
The User acknowledges that the creation of new services or the obligation to comply with any legal, regulatory, jurisprudential and technical evolution may imply the modification and updating of the Charter which, in this case, will be updated and will indicate the day on which the modifications were made.
In any event, the user's Personal Data will always be processed in accordance with the Charter in force at the time of their collection, unless a mandatory legal prescription stipulates otherwise and is applicable retroactively.