Last Updated: October 12, 2021

OVERVIEW

FrontLobby Financial Inc. and our affiliates (“FL”, “we” or “us”) respect your privacy and are committed to protecting it by complying with this policy and applicable legislation.

This policy describes:

• how we collect, use, disclose and protect the personal information of customers and website users (“you”);
• the types of information we may collect from you or that you may provide when you visit the website www.Frontlobby.com (our “Website”) or use the services made available through the Website (the “Services”); and
• our practices for collecting, using, maintaining, protecting and disclosing that information.

Privacy laws in Canada generally define “personal information” as 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.

Please read this policy carefully to understand our policies and practices for collecting, processing and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website or the Services. By accessing or using this Website or the Services, you indicate that you understand, accept and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website or the Services after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

SCOPE OF THIS PRIVACY POLICY

This policy applies to information we collect, use or disclose about you in connection with our business in Canada, including:

• on this Website or through the Services;
• in email, text and other electronic messages between you and this Website or the Services;
• through mobile and desktop applications you download from this Website or the Services, which provide dedicated non-browser-based interaction between you and this Website or the Services.

This policy does not apply to our international affiliates, who maintain their own privacy policies. Please carefully read their privacy policies to understand their collection, use or disclosure of your personal information, even if you link to them through our Website or the Services.

This Website or the Services may include links to third-party websites, plug-ins, services, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your full name, any previous name(s), mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, billing and account information, social insurance number, date of birth, credit card number, credit and rental histories, salary, gender, demographic data, marital status and any other identifier we may use to contact you (“personal information”).
• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your interest connection, the equipment you use to access our Website or the Services, and usage details.
• Non-personal details about your Website and Services interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms, creating an account through our Website or the Services, or corresponding with us by phone, email or otherwise.
• Automated technologies or interactions, as you navigate through our Website or the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners and landlords and property managers that have obtained your consent to provide the information or do not require consent under relevant law. We also collect information from reports about you that are provided to us by credit grantors or other institutions that are responsible for obtaining your consent to provide the information to us.

INFORMATION YOU PROVIDE TO US

The information we collect directly from you on or through our Website or the Services may include:

• Information that you provide by filling in forms on our Website or the Services. This includes information provided at the time of registering to use our Website or the Services or when requesting further services. We may also ask you for information when you report a problem with our Website or the Services.
• Records and copies of your correspondence (including email addresses), if you contact us or through our customer support interactions with you.

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

A cookie is a small file placed on the hard drive of your computer or smartphone. We and our third-party partners may set and use cookies for site functionality, remembering user’s settings and for authentication. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Website or the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or the Services.

As you navigate through and interact with the Website or the Services, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to the Website or the Services including traffic data, location data, logs and other communication data and the resources that you access and use on the Website or the Services.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

INFORMATION WE COLLECT FROM THIRD PARTIES

We may use third-party service providers to monitor, analyze, improve and protect the use of the Website and the Services.

We also may collect personal information about you from other third parties, including landlords and property managers. We have processes in place to encourage, confirm and educate third parties regarding consent requirements prior to disclosing your personal information to us, including the provision of sample clauses to insert into tenancy applications and leases obtaining your consent for the disclosure of your information. However, the responsibility for obtaining consent, when required, for such information ultimately remains with the landlords and property managers.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• to verify your identity;
• to present our Website and its contents to you;
• to perform the Services and related transactions offered through the Website;
• to provide you with information, products or other 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 provide you with notices about your account;
• to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
• to notify you about changes to our Website, the Services or any products or other services we offer or provide through the Website or the Services;
• to provide customer service;
• to improve the Website or the Services (including upgrading security measures), other services, internal business processes or customer relationships and experiences;
• to evaluate the products and services that we offer and develop new or improved products or services and to better understand our business environment;
• to detect, prevent and address fraud or other illegal activity;
• to fulfill our obligations under consumer reporting and privacy legislation (such as, a request to initiate an investigation);
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails or email us at support@frontlobby.com. For more information, see the Choices About How We Use and Disclose Your Information section below.

DISCLOSURE OF YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this privacy policy:

• to our subsidiaries and affiliates;
• in accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of FL’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding in which personal information held by FL about our customers and users is among the assets transferred.
• to contractors, service providers and other third parties we use to support our business (such as credit and consumer reporting agencies, analytics and search engine providers that assist us with Website and Services improvement and optimization, vendors that help us with payment processing or third parties that provide you with customer support) 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 set out in this policy;
• to fulfill the purpose for which you provide it, including the provision of rent history reporting to credit and consumer reporting agencies and credit reports;
• for any other purpose disclosed by us when you provide the information; or
• with your consent.

We may also disclose your personal information:

• to comply with any court order, law or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
• to enforce or apply our Terms of Use and Terms of Service and other agreements, including for billing and collection purposes; or
• if we believe disclosure is necessary or appropriate to protect the rights, property or safety of FL, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

Our servers are located in Canada and personal information is stored by us in Canada.

We may need to transfer, store and process some personal information to contractors, service providers and other third parties we use to support our business (such as payment processing, or analytics and search engine providers that assist us with Website improvement and optimization) in Canada or across borders, including the United States, 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 in a manner consistent with the standards set out in this policy, subject to the law in the third party jurisdiction.

By submitting your personal information or engaging with the Website or the Services, you consent to this transfer, storage or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

You have the following control over the personal information you provide to us:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website or the Services may not be accessible or may not function properly. For more information about tracking technologies, see the Information We Collect Through Cookies and Other Automatic Data Collection Technologies section above.
• Promotional Offers from FL. If you have opted in to receive certain emails from us but no longer wish to have your email address used by us to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to support@frontlobby.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.

DATA SECURITY

Our servers are located in Canada and personal information is stored by us in Canada.

To protect your personal information from unauthorized access and use, we use physical, electronic and administrative measures. These measures include computer safeguards and secured files and buildings. We also strive to limit personal information access to employees, agents and representatives who need to know the information.

Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Website or the Services. Any such transmission is at your own risk. You are responsible for keeping your password confidential and we ask that you do not share it with anyone. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or the Services.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, including provincial credit reporting legislation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Once your personal information is no longer needed for the purposes we collected it for, it will be deleted or anonymized in accordance with our policies and procedures.

USE OF WEBSITE AND SERVICES BY MINORS

Our Website and the Services are not intended for anyone under the age of 18 and we request that individuals under 18 do not provide personal information through the Website or the Services. We do not knowingly collect personal information from individuals under the age of 18.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

We will make reasonable arrangements to ensure that the personal information we collect, use or disclose is accurate and complete. Please keep us informed if the personal information we have collected from you changes. You have the right to review, correct and obtain a copy of your personal information that is under our control. If you wish to do so, please contact us at support@frontlobby.com.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law 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 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.

HOW TO DISPUTE INFORMATION REPORTED TO THE CREDIT BUREUAS 

Housing providers may use FrontLobby to report rental data to the credit bureaus. Information on when consent is and is not required can be found in the Legal Framework. If you believe that inaccurate information has been reported to the credit bureaus, you may file a dispute with the credit bureaus directly or by following FrontLobby’s Dispute Process.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to us for the collection, use and transfer of your personal information, and we are processing your personal information on the basis of consent, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@frontlobby.com. Please note that if you withdraw your consent we may not be able to provide you with services.

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. In the event of any changes to this privacy policy, we will post the amended privacy policy and effective date thereof on the Website. Your continued use of the Website or the Services following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION

If you have questions, comments or requests regarding this privacy policy and our privacy practices, please contact FL’s Privacy Officer by email at support@frontlobby.com or by mail at:

Attn: FrontLobby Privacy Officer
408 – 55 Water Street
Office #8234
Vancouver, B.C., V6B 1A1
Canada