October 13th 2021
Administrateur immobilier numérique Wazo Inc. (“Wazo”, “we”, “us” or “our”) is committed to respecting your privacy and protecting your personal information.
To provide you with quality services, we need to have access to certain personal information about you. We make sure that our employees manage this information with all the necessary discretion and diligence in compliance with the legal and regulatory requirements in force.
When using our services, you consent to the hereby Policy.
1. WHAT IS PERSONAL INFORMATION?
We define “personal information” as any information about an identifiable individual, or that taken alone or combined with other data, allows an individual to be identified.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
During our interactions with you, whether it be while providing our services or during our business activities, we must collect certain personal information about you. The personal information we collect is necessary to provide you with the requested services. This includes, but is not limited to:
- Contact information such as name, address, email, or phone number;
- Billing information;
- Information related to the use of our email campaigns including technical information about the opening of emails or other information collected through pixels or similar tools;
- Marketing information and communication preferences such as comments, survey responses;
- Recruitment-related information such as resumes, information about your professional or academic background, or any other information relevant to potential recruitment;
- Any other personal information provided.
3. YOUR CONSENT
Generally, Wazo will obtain the necessary personal information directly from you, with your consent, subject to the exceptions provided by law.
By providing us with personal information, whether by telephone, e-mail, in person, through our website or application or by any other means, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS PROVIDED IN THIS POLICY.
We may also collect personal information from third parties or from publicly available records as permitted by law or where we have obtained consent.
Wazo will not collect, use, or disclose personal information without your consent unless it is authorized or required to do so by applicable laws. For example, Wazo may need to do so without your consent for the following reasons:
- When, for security, medical or legal reasons, it is impossible for us to obtain your consent;
- When, for fraud detection, prevention, or law enforcement purposes, seeking consent would defeat the purpose of the procedure.
Please note that you have the right to refuse to provide us with personal information. You also have the right, subject to reasonable notice and applicable legal or contractual restrictions, to withdraw your consent regarding the use of your personal information already collected by contacting our Wazo Team. The refusal to disclose information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our services.
Wazo may also seek your consent for secondary purposes. As mentioned above, we will ask for your consent in this regard. In addition, your consent for secondary purposes may be withdrawn at any time, without affecting the rendering of our services to you.
4. WHY AND HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Wazo collects, uses, and discloses personal information for the purposes identified at the time of collection or as permitted or required by regulations. This includes, but is not limited to, the following purposes:
- To provide you the service;
- To answer your request of information;
- To obtain more details about your operations so we can properly identity your needs;
- To process your payment;
- To send occasional communications regarding your account or our products/services via e-mail;
- To facilitate the use of our products/services and ensure their applicability, to monitor the use of our products/services, to answer questions submitted through our products/services;
- To conduct development and research to ensure that we maintain the highest standard of security, to understand our clients’ requirements and to improve our service offer;
- As permitted or required by any applicable legal or regulatory obligations or provisions;
- Any other purpose to which you have consented.
a) Use of web beacon
A web beacon is a tiny image placed on a website or in an email. It can be used to anonymously track the number of times a user visits a page or if an email is opened. Web beacons are invisible and can be found on our emails. Web beacons are not stored on your computer.
We use web beacons to customize and optimize our advertising campaigns. This technology does not use any identifying personal or financial information, but it may contain a unique identifier for retargeting purposes.
A cookie is a small data file created by your browser and placed on your computer when you visit a website, a page or a web application. Cookies allow web applications to store certain information about you to facilitate your access and browsing of the Internet within our sites. Cookies can only be read by the web application that sends them to your computer.
We use certain cookies on our website, specifically to:
- Store your settings and preferences. Cookies tell us your preferences for example, your country, province or language,
Wazo uses 1 type of cookies:
- Performance and functionality connection cookies: These cookies are not essential to the provision of our services. They facilitate the personalization and enhancement of the user experience. For example, they may remember your preferences and avoid having to re-enter information more than once or remember your credentials, so they don’t have to enter them each time you use them.
c) Google Analytics
Wazo uses Google Analytics to analyze the browsing behaviour of visitors to its website. It is a tool for analyzing web application traffic and websites use, which is provided by Google Inc. (Google). By using this tool, Wazo can obtain, among other things, the following information:
- the number of visitors to the site;
- the type of browser, language, and operating system they are using;
- screen resolution;
- the name of the service provider;
- date, time, and duration of visits;
- the country/province from which the site is being accessed;
- pages visited;
- the source (origin) of the traffic, either organic/direct/reference/social media;
- centres of interest;
- search terms within the website (search fields).
The information collected by Google Analytics is used to analyze the use of Wazo’s website and to produce statistical reports on visitor activity. More information about Google Analytics can be found here.
d) Deactivation of Cookies
It is possible to prevent the personalization functions of our site by disabling cookies on your browser. You can do this by changing the settings in your browser or mobile device.
However, if you choose to decline cookies, certain pages or sections of our web application and products may not display properly or certain features may not be available.
5. LIMIT TO COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
Wazo strives to limit the collection of personal information to what is strictly required to fulfill the purposes for which it is collected. Rest assured that we will not disclose or use your personal information for any other purpose unless you consent to such or as required by law.
In addition, as you will see in the Privacy section, we limit access to your personal information only to those individuals who have the authority and need to access it for a specific purpose.
Please note that we do not voluntarily collect information from persons under the age of 16. If we learn that we have accidentally collected personal information from a person under age 16 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a person under 16, please notify us by using the contact information provided below.
6. WHY AND HOW DO WE SHARE YOUR PERSONAL INFORMATION?
To provide you with our services, we may share the personal information we collect with certain third parties.
During its activities, Wazo may disclose your information to third parties, which includes but is not limited to:
- Third-party service providers, including but not limited to services related to our products (hosting, security, etc.). The personal information provided is then limited to only the information required to enable them to carry out their services and these suppliers are obliged to maintain the confidentiality of this information,
- Governmental public authorities and law enforcement agencies when required by applicable laws or when necessary for the rendering of our service.
a) Transfer of personal information abroad
Wazo occasionally calls upon service providers located outside of Canada to carry out specific mandates in the normal course of business. Although most of our service providers are located in Canada, it is possible that some of your personal information may be transferred to another country and be subject to the laws of that country.
We do, however, ensure that we protect the personal information in our hands, including personal information entrusted to a supplier whether located in Canada or abroad. Our privacy policies and practices require that a written commitment be signed by that service provider to comply with its obligation to maintain the confidentiality and security of personal information entrusted to it. This includes implementing solid and effective security measures, as well as prohibiting the disclosure of your information to others.
If you have any additional questions regarding the above, you may contact us using the contact information provided below.
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
Personal information is retained for as long as necessary for the purposes set out in this Policy and to ensure that we comply with our legal and regulatory obligations.
In addition, and as mentioned in the previous section, your personal information may be kept in Canada or abroad. Of course, we ensure that we have the necessary security measures in place, as well as the relevant contractual agreements, to protect your personal information.
If you wish to learn more about how long we keep your personal information, we invite you to contact our Privacy Officer, whose contact information is provided below.
8. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Wazo strives to apply the necessary and appropriate security measures to ensure the confidentiality of the personal information in its possession. In doing so, we follow generally accepted industry standards [and all of our connections are encrypted in accordance with the security protocol Transport Layer Security («TLS»)]. The personal information we hold is therefore accessible only to persons who are qualified to have access to it and who consult it only when necessary in the performance of their duties.
Appropriate physical, technical, and/or administrative safeguards and security measures have been put in place and are maintained to prevent:
- Any accidental or unlawful destruction,
- Accidental loss,
- Unauthorized disclosure,
- Unauthorized modification,
- Unauthorized access,
- Any illegal treatment.
In order to do so, we ensure, among other things, that access to our offices and computer equipment is restricted, that our staff is trained and that our agents and suppliers of goods and services with access to personal information are required to sign confidentiality agreements and implement security measures deemed equivalent.
It should be noted, however, that no method of transmission over the Internet, nor any means of electronic storage is completely secure. Therefore, we cannot guarantee the security of any personal information transmitted to us or that you provide to us, and that you do so at your own risk.
We also cannot guarantee that such personal information will not be obtained, accessed, disclosed, modified, or destroyed as a result of a breach of our protection and security measures.
If you believe that your personal information has been compromised, we invite you to contact us.
9. HOW TO ACCESS AND RECTIFY YOUR PERSONAL INFORMATION?
You may request access to your personal information or inquire about the existence of such information or about the way we collect, use, maintain and/or disclose your personal information. You may also request that information held by Wazo be corrected if it is found to be inaccurate, equivocal, or incomplete. You may submit a written request to this effect by using the contact information provided below.
If you wish to obtain copies of your personal information, we may be required to charge a nominal fee, which will be disclosed to you in advance, simply to cover the cost of transcription, reproduction or transmission.
10. EUROPEAN UNION DATA
This Section only applies to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection.
a) Right to erasure
With some restrictions applicable, in accordance with the international application of the General Data Protection Regulation, you will be entitled to obtain from Wazo the prompt deletion of your Personal Information and Wazo is required to delete such Personal Information as soon as possible, where any of the following reasons apply:
- the Personal Information is no longer necessary for the purposes for which it was collected or otherwise processed;
- you withdraw the consent on which the processing is based and there is no other legal basis for the processing;
- you object to the Processing and there is no compelling legitimate reason for the Processing;
- the Personal Information has been unlawfully processed;
- the Personal Information must be deleted to comply with a legal obligation to which Wazo is subject; and
- the Personal Information was collected as part of an offer of services normally provided for remuneration, remotely, electronically and at the individual request of a recipient of services.
Where Wazo has made the Personal Information public and is required to delete it, Wazo, taking into account the available technologies and the costs of implementation, will take reasonable steps, including technical measures, to inform the data controller who process such Personal Information that you have requested that such data controller delete any link to or copy or reproduce such Personal Information.
b) Right to restrict processing
You will be entitled to obtain from Wazo a restriction to process when any of the following applies:
- for a period of time that allows Wazo to verify the accuracy of the personal data while you dispute the accuracy of the Personal Information;
- the processing is unlawful and you object to the deletion of Personal Information and instead require a restriction to process by limiting the Personal Information use;
- Wazo no longer requires the Personal Information for the purposes of the processing, but it is still necessary for you to establish, exercise or defend legal rights;
- you object to the processing during a verification as to whether the legitimate grounds pursued by Wazo prevail over your own.
c) Right to Data Portability
You will be entitled to receive the Personal Information you have provided to Wazo, in a structured, commonly used and machine-readable format, and you will be entitled to transmit such Personal Information to a third party without Wazo impeding it where the processing is based on your consent and the processing is carried out using automated processes.
d) Right to Object
You may object, at any time, for reasons relating to your particular situation, to the processing of your Personal Information which is necessary for the legitimate interests pursued by Wazo or by a third party or for the performance of a task carried out in the public interest or in the exercise of a public authority vested in Wazo, including profiling. Wazo will no longer process Personal Information unless we demonstrate that there are compelling legitimate reasons for the processing that prevail over your interests, rights and freedoms or for the establishment, exercise or defence of legal rights.
e) Automated Individual Decision-Making, Including Profiling
You may not be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner, unless the decision is:
- necessary for the conclusion or performance of a contract between you and Wazo;
- authorized by the law to which Wazo is subject and which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests; or
- based on your explicit consent.
To learn more about your rights or the steps to follow to make such request, please communicate with us to the following address: firstname.lastname@example.org. Note that we will not discriminate against you for the exercise of these rights.
11. LINKS TO SITES
It is important to understand that this Policy does not apply to other third-party websites that may be accessed through links on our products. We are not responsible for those third-party sites, their content or access. Therefore, any personal information you transmit through these sites is subject to the privacy policies of those sites. It is your responsibility to review their privacy policies to ensure the protection of your personal information.
12. QUESTIONS, COMMENTS, COMPLAINTS
To contact us, ask questions about this Policy, provide us with your comments, submit a request for access or correction, exercise any applicable rights, file a complaint or obtain information about our practices or policies, we invite you to contact us at email@example.com.
13. UPDATING THIS POLICY
The content of our products can be changed at any time. Accordingly, this Policy may be subject to change from time to time in the future. We recommend that you review it whenever you visit our web application and our website to stay informed about how we handle personal information.
This Policy was last updated on October 13th 2021.