Last Updated: April 19, 2019
Personal Information We Collect
Your name, email address, and phone number are required to open an account. You must also provide a copy of your government issued identification card to verify your identity. Other details, such as your geographic location; address; profession; salary range; profile photo/avatar; professional/landlord references and roommate details are not required, and are shared only upon your full completion of a Liv Profile in order to permit you to submit leasing applications via our Liv Platform at your discretion. If you wish to use our Credit Check Service and obtain your Liv Score, including your credit score obtained through third party credit reporting agencies and other aggregated details, you will be invited to provide your social insurance number; driver’s license number; bank statements; and paystubs.Click here to read more about the personal information we collect
Information That Is Publicly Viewable
If you are a Renter, your Liv Profiles includes your first name and last name initial, your profile photo/avatar, and your profession. If you are a Landlords, your Liv Profile includes your company name and/or your first and last name, a photo of your building/company logo, and any other relevant company and/or professional details you’ve decided to share. All Users’ Profile Information is displayed on their Liv Profile and can be accessed by other Users via the Site and App. We encourage Users to think carefully about what information about themselves they disclose in their profile pages and their Listings.Click here to read more about the information that is publicly viewable
Personal Information We Share
Other Information That Is Automatically Collected
We automatically collect information when Users access the Platform via their computer and/or mobile device, such the type of browser you’re using; your browser settings; the type of device you’re using; what operating system your device is running; what mobile network you use; and your phone number. We also collect information obtained from cookies, and monitor what activities you perform on our Site, and collect Log Data.Click here to read more about other information that is automatically collected
We do not and will not, at any time, send you a non-secure or unsolicited e-mail, text message or telephone communication requesting your credit card information, sign-in details, identification numbers or other personally identifiable information. If you receive such an email or communication, please contact our Liv support team immediately.Click here to read more about phishing
Your Liv Score
A Liv Score is only mandatory to obtain if you wish to submit an application via the Liv Platform. If you decide to obtain a Liv Score, you also decide whether you want to share your Liv Score with other Users. If you request a Liv Score, you authorize a Credit Report from a third party credit reporting agency Equifax Canada Inc. (“Equifax”) and the resulting Credit Score will be used to generate your Liv Score. Your Credit Report and Credit Score are never stored on Liv’s servers, and none of the details in your Credit Report will be included or stored in your Liv Score, Liv Profile, or elsewhere on Liv’s servers. Any request for your Credit Report may adversely impact your credit score.Click here to read more about your Liv Score
Managing, Reviewing and Updating Your Personal Information
All Users may review, update, correct, or delete the Personal Information in their Liv Profile and Liv Account by contacting us by email at email@example.com or by directly editing the relevant part of their Liv Profile within the Liv Account. If you would like us to deactivate your Liv Account, please send us a deactivation request at firstname.lastname@example.org.Click here to read more about managing your personal information
We have built security into our Services in order to protect your Personal Information, and we use encryption to protect against unauthorized access to your information. However, no method of transmission or information storage is 100% secure, so we cannot guarantee the security thereof. If you have any questions about the security of Personal Information on the Liv Platform, you can contact our Privacy Officer at email@example.com.Click here to read more about security
Liv Strategies Inc. and its affiliates (“Liv”, “we”, “us” and “our”) are committed to protecting the privacy of all individuals and legal entities (each a “User”, collectively, “Users” “Members” and “you”) who use our services (as discussed more below). We understand that this is a big responsibility and we work hard to protect your Personal Information (defined below) and put you in control.
Our services allow users to:
- Use our site, https://liv.rent, and including all subdomains, present and future (“Site”);
- Use our desktop application available on the Site to prepare, review and/or sign a tenancy application (“Contract Portal”);
- Use our mobile application (“Application” or “App”); and
We may collect non-personally identifiable information (“Non-Personal Information”) which is any type of information other than Personal Information, and is excluded from this Policy. For example, Non-Personal Information includes, without limitation, anonymous information; business information; and information that enables an individual to be contacted at a business and which information may be publicly available for such purpose. We collect Non-Personal Information in connection with our business practices in accordance with applicable laws.
Personal Information We Collect
We want you to understand the types of Personal Information that we collect when you use our Services.
We collect Personal Information from our Users in order to provide Services through the Liv Platform, including providing and updating the features and content offered there, administering your use of the Liv Platform, enabling Liv Members (as defined below) to enjoy the Services and easily navigate both the Site and the App. In so doing, we also collect Personal Information and non-identifiable information from Members for our own purposes, such as to provide and administer Services (“Liv Data”). We are the data controller in respect of Liv Data.
The Personal Information that we collect, and how that Personal Information is used, depends on how you use our Services and how you manage your privacy controls.
a. Personal Information
You can choose to provide us with the following types of Personal Information as you use the Liv Platform and enjoy the use of our Services such as:
- Updates about our Services. Even if you are not signed up for a Liv Account, you might choose to provide us with information – such as your email address and first and last name to receive updates about our Services.
- Liv Account Information. When you sign up for a Liv Account, we require certain Personal Information such as your full name, email address and phone number.
- Profile Information. To use certain features within the Liv Platform, we will invite you to complete a personal profile on the Liv Platform via your Liv Account (“Liv Profile”), at your sole discretion, which may include your address, geographical area, profession, salary range and a photograph or personal avatar (which would need to be personally selected and uploaded by you). We may individually assist you to complete your Liv Profile over the phone or in person, which would involve one of our designated employees taking your full name, email address and phone number over the phone to insert directly into your Liv Profile at your express consent. If you choose to complete certain parts of your Liv Profile, including your profile picture, first name, and description, these details will appear to other individual users of the Liv Platform (each a “Member”, together the “Members”). For our tenant Members, the profile picture and first name will not be publicly visible on the Internet to anyone not signed into the Liv Platform; however our Landlord (as defined below) Members’ profile pictures and first names will be publicly visible on the Internet to people who are not signed into the Liv Platform. Strictly for the purposes of marketing and promotional purposes of prospective Landlords, we may disseminate email communications to prospective Landlords with information regarding prospective Tenants looking for Listings. This information will be limited to the first name and occupation of a Tenant and will be attached to an anonymized design of a person’s face. When a prospective Landlord creates a Liv Account, they will gain access to the profile picture and first name of tenant Members.
- Other Authentication-Related Information. To help create and maintain a trusted environment online, Liv has designated management-level employees who are responsible for confirming your identity through a manual review of the screen capture of your government-issued photo identification card or other authentication information that you upload to your Liv Profile. The details from this identification or other information will not be included on your Liv Profile, however by authorizing Liv to confirm your identity through this manual process, this permits us to maintain a trusted environment and protect against identity theft and or related fraudulent occurrences by confirming the identity of Users. The Personal Information reviewed during this identity verification process is not used for any other purpose and is disclosed to such management employee strictly for the purposes of completing this function. Upon manual confirmation of your identity through review of your identification card or other authentication information, or upon our notice to you that we require an alternative form of identification or further authentication information, any copies of your identification or authentication information is securely destroyed by us immediately. Once you provide us with a screen capture of a different identification card or additional authentication information within the Liv Profile, these copies are securely destroyed by us immediately.
- Reference and Additional Information. To apply for tenancy through the Liv Platform (“Tenancy Application”), we may collect additional profile information from you, at your sole discretion, such as your roommate and/or partner’s information (subject to their consent, discussed below), emergency contact’s name and contact details, work references, landlord references, and pet information. These additional details are stored in your Liv Account and disclosable to Landlords strictly on your consent on a case-by-case basis. We provide you with the opportunity to authorize the integration of your LinkedIn account details using its Profile API in order to permit the Liv Platform to access your employment history, geographical details and account status from LinkedIn.
- Roommate Information. When two or more Users of the Liv Platform identify themselves within their respective Liv Accounts as roommates or partners (“Roommates”), the Users consent to the following:
- Being identified as each other’s Roommates on the Site, App and Liv Platform;
- Having their Personal Information (limited to their name, date of birth and employment status) shared with any Landlord(s) that their Roommate(s) matched with; and
- Having their Personal Information shared with Landlords that their Roommate(s) match with on the Liv Platform.
- Credit Information. When you use our Credit Check Service (defined below), we provide you with a form into which you can insert your driver’s license number and/or social insurance number, which form is enabled to directly connect to and be transferred to Equifax, and which Personal Information is not downloaded, stored or copied on our Liv Platform. To confirm, this Personal Information uploaded by you into this form is directly end pointed and transferred to Equifax. Your bank statements and or employer’s pay stubs may be uploaded by you, at your sole discretion, to supplement the generation of your Liv Score. These forms of Personal Information would not be downloaded, stored or copied on our Liv Platform.
- User-generated content. This includes, without limitation, messages, posts, comments, pages, photos, feeds or communications that you exchange and/or post on the Liv Platform. This includes communication with us, other Members and prospective landlords who are Users of the Liv Platform (each a “Landlord” or collectively, “Landlords”). In addition, we may receive Personal Information relating to communications that you choose to send us via the Liv Platform, such as help desk queries or comments concerning our Services and your use of the Liv Platform. Such user-generated content will be reviewable by you in the log of your “Activity” on the Liv Platform.
- Listing Information. When as a Landlord you create a listing for rent by Members on the Liv Platform (“Listing”), we collect your unit address, building name, geographical area, rental amount and term, photos, unit features, building amenities, business license number and any details about the contents of the unit for verification and completion of the Listing. These details are then shared with Members on the Liv Platform in conjunction with your Listing.
- Marketed Rental Units. From time to time we may market certain furnished and unfurnished Rental Units with the details thereof provided on our website including, without limitation, the building name and location, square footage, layout, photos and or generated inside view of the Rental Units, and any details of furnished and unfurnished Rental Units. If we do market such Rental Units, we may offer the ability to schedule or reserve appointments to view such Rental Units and submit an application for such Rental Units to the applicable Landlord(s) within our Liv Platform.
- Other Information. You may otherwise choose to provide us Personal Information when you fill out a registration or other form; conduct a search; create an alert regarding any search; update or add information to your Liv Account; respond to surveys; post to community forums; send messages to Members or Landlords; participate in promotions; engage with third party advertisers; and/or use any other features available at any time on the Liv Platform.
- Information automatically collected from your use of our Services. We also automatically collect and receive certain information from your computer and/or mobile device, including without limitation, the activities that you perform on our Site, the App and generally within the Liv Platform; your browser type and settings; your device type, operating system and settings; your mobile network information including carrier name and phone number; and your application version number. We also collect information obtained from cookies (see "Cookies and Similar Technologies" below). For example, each time you visit the Site or otherwise use the Services, we automatically collect your IP address; browser and device type; access times; real-time location; the web page from which you came; the regions from which you navigate the Site; and the pages of the Site that you access
- Usage information about your interactions with the Liv Platform. When you visit the Site and/or use the App, whether as a Member, a non-registered user or a Landlord, our servers automatically collect and record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (“IP”) address; browser type; the webpage you were visiting before you came to our Site; the pages of our Site and App that you visit; the amount of time you spent on each page; search queries made on our Site and/or App; the date and time you accessed our Services; your real-time location; and other statistics. The types of location data we collect depends on your mobile device and account settings. If you enable push notifications and location services on your mobile device in relation to your use of the Application, you thereby grant us permission to send you updates and access your location information within the parameters you set for such authorization. If you enable location services in relation to the App, you authorize us to enable the Maps feature within the Application. You can turn off push notifications and location services in your device’s settings.
- We use various technologies to collect and store information, including cookies and local storage (such as application data caches, databases and server logs). This Log Data is stored on our secure servers, which are protected using SSL and industry leading encryption technology. This information is kept confidential, and is only used to help us improve our services and our Liv Platform. It is never shared with third party partners.
b. Liv Data
We collect non-identifiable information that we define as “Liv Data”. This information comes from your use of our Services and your general use and engagement with the Liv Platform.
We collect and use the Liv Data in the following ways to build better Services:
- to enable us to deliver our Services to you, such as processing the terms you search for in order to return search results;
- to maintain and improve our Services and the experience of all Users. By analyzing the Liv Platform and using the Liv Data, we can ensure that our Services are working as intended, troubleshoot issues, and to make improvements to our Services;
- to develop new Services;
- to obtain information about our visitors and Users, including research into our user demographics and user behavior in order to continuously improve our Services;
- to understand how our Services are used and optimize product design;
- to communicate with you directly about your Liv Account and to provide customer service support, including responding to your comments, questions and help desk tickets, and to update you about upcoming changes or improvements to our Services. This allows us to keep you informed about our Services, features, newsletters, offers, events, announcements and details about related urban markets that we think that you may find useful or which you have requested from us;
- to share aggregate (non-personally identifiable) statistics about our Users to prospective third party advertisers and partners, which shall also serve to enable us to receive aggregate (non-personally identifiable) statistics from such third-party advertisers and partners about User engagement with such advertisements via the Platform;
- to better understand your needs and the needs of all Users, and to diagnose problems, analyze trends, assess urban leasing markets, improve the features and usability of our Services, and to better understand and serve our Users, both current and prospective;
- to maintain a safe and trusting environment for all Users on the Platform. We use Liv Data to help improve the safety and reliability of the Liv Platform and our Services. This includes detecting, preventing and responding to fraud abuse, security risks and technical issues that could harm our Users, the public or the Liv Platform.
We also use Non-Personal Information for statistical purposes to keep track of Users’ number of visits to our Services in order to introduce improvements and improve the usability of the Platform. We also use this statistical data when considering third party advertisers and service providers in order to ensure we deliver the most useful and relevant integration within the Liv Platform. If we do decide to share any type of non-personally identifiable information with such third parties on a future integration with the Liv Platform, we will advise you in advance of this change.
We use different technologies to process your information. We also analyze the information to detect abuse such as spam, malware and illegal content.
We define “Liv Data” to include “Log Data”, which we use as follows:
- to monitor and analyze Users’ use of and engagement with the Liv Platform and our Services;
- for the ongoing technical maintenance and operation of the Liv Platform;
- to increase the Liv Platform’s functionality for all Users, to ensure the Site and Application are user-friendly for all Users and to better tailor our Site and App to our Users’ needs;
- to verify that Users of the Liv Platform meet the criteria required to process their requests to create a Liv Account and a Liv Profile thereon through the submission of registration forms.
We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such non-personally identifiable information for the same purposes as stated above regarding other non-personally identifiable information.
c. Cookies and Similar Technologies
d. Data Analytics.
Google Analytics. We authorize and transfer Liv Data to Google so we can use Google Analytics to analyze and process Liv Data. This, in turn, helps us optimize and continuously improve our Services and the Liv Platform; assess further market need for additional research and development; and isolate key potential third party advertisers and partners to work with in order to further develop the Liv Platform and our Services offered, among other things.
Identity theft and the practice currently known as “phishing” are of great concern to Liv. Safeguarding information to help protect you from identity theft is a top priority of ours. We do not and will not, at any time, send you a non-secure or unsolicited e-mail, text message or telephone communication requesting your credit card information, sign-in details, identification numbers or other personally identifiable information.
Information Sharing and Disclosure
When you create a Liv Account as a Member and request us to create a Liv Profile for you via a registration form submitted on the Liv Platform, we will do so.
Your public Liv Profile includes your first name and last name initial; your profile photo; and your profession (“Profile Information”). Your Profile Information is displayed on your Liv Profile and can be accessed by other Users via the Site and App. We only disclose your full name, birthdate, and social insurance number (“Personal Information”) in the following circumstances: (1) when you specifically request and provide us with your express consent to submit an application (“Application”) for a Listing (“Listing”) via the Platform; (2) to obtain your Credit Report from a trusted third party credit reporting agency in order to obtain your Liv Score; and/or (3) to create a contract for you and a Landlord in relation to a Listing (“Contract”). As a User, you should be aware that information that choose to provide as part of your Profile Information — your first name; last name initial; profile photo; and profession — will be publicly visible. Therefore, it is important to only share details that you want other Users to know about you. We recommend that you guard your anonymity and sensitive Personal Information and we encourage Users to think carefully about what information about themselves they disclose on their Liv Profile. You can review, revise and delete the Personal Information on your Liv Profile at any time by visiting your Liv Account.
When you create a Liv Account as a Landlord and request us to create a Liv Profile for you via a registration form submitted on the Liv Platform, we will do so. Your Liv Profile includes your company name and/or your first and last name, as applicable; a photo of the building or of your company logo; and any other relevant company and or professional details (“Profile Information”). We also require your business license number, however we will not disclose your business license number to other Users; we only use it to simply identify whether it is verified or pending in relation to your Liv Profile. Your Profile Information is displayed on your Liv Profile to other Users via the Site and App. We only disclose your Profile Information, together with other information, when you specifically request and provide us with your express consent to create a Listing on the Platform and or to enter into a Contract with a Member, and, with your prior permission, on third party sites. For the avoidance of any doubt, if you wish to disclose such information on third party sites, we will enable you to copy your stored details regarding a Listing and paste this script directly into a third-party site such as Craigslist or Kijiji, among others. Any information you choose to provide as part of your Profile Information will be publicly visible to all Users and consequently the information you share in your profile should reflect how much you want other Users to know about you. We encourage Users to think carefully about what information about themselves they disclose in their profile pages and their Listings. You can review and revise your Profile Information at any time.
Our Service enables Members to acquire a “Liv Score” which helps prospective renters engage with Landlords and use our Services to rent a home. A Liv Score contains the weighted average of all scores obtained from credit history reports provided by third party credit reporting agencies (each, a “Credit Report”), background check scores resulting from the aggregate of results from publicly available government records, and verification of certain publicly available details retrievable from LinkedIn (such as employment history, geographical verification, name and account status). In each case that you request that we prepare a Liv Score on your behalf, you will be required to provide your express consent. If you submit a request form to have a Credit Report obtained via our Services, the credit score provided by the third party credit reporting agency will be added to the algorithm preparing the Liv Score calculation via the Liv Platform with no storage thereof on the Liv Platform. No other details in the Credit Report will be included or stored in your Liv Score, Liv Profile or elsewhere on Liv’s servers. You may then share your Liv Score with Landlords who have created Listings for a period of sixty (60) days after you have obtained the Liv Score, on your express consent in each case. Please know that any request for a Credit Report may adversely impact your credit score.
We have systems in place to prevent open access by our staff to Users’ Liv Accounts and any Personal Information that may be stored by Users within their Liv Accounts. Only very small and restricted group of vetted, trained and trusted employees have access to Liv Accounts, and we conduct regular audits of access logs to monitor staff access and ensure compliance with our policies regarding access.
We monitor the Liv Platform on an ongoing and continuous basis to ensure that it remains a trusted environment for all Users, however we do not have legal control or authority over any of the Landlords on the Liv Platform, and therefore encourage all Users to think carefully before sharing your Liv Score with any Landlord. For the avoidance of any doubt, we will never share your Liv Score with any third party other than those Landlords specifically authorized by you in each case.
As a Landlord, if you post a Listing, we may publish that Listing publicly via the Site and Application and may enable you to disclose the details thereof by pasting the details of the Listing on third party websites and or through the use of an HTML “widget”. We may also display the geographical location of your Listing in the form of a map so that current and potential Members can see the general area and neighborhood of your Listing, including your actual street address so interested Members are able to get directions to your Listing. The information that you provide in your Listing will be visible to others, including anonymous, non-registered visitors to the Site.
If you as a Member and prospective renter submit a tenancy application relating to a Listing on the Liv Platform (“Application”), you shall be specifically consenting to and requesting Liv to sharing the information on your Liv Profile to the Landlord of that property. The specified Landlord(s) will then be able to view the information that you have provided in your Liv Profile in order to make decisions on whether to accept your Application to their Listing(s).
Aggregate Information and Non-Personal Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Personal Information and Log Data with third parties for industry, demographic, and geographic analysis, among other purposes. Any aggregated information shared for these purposes will not contain your Personal Information.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your Personal Information that we cannot resolve with you directly.
Compliance with Laws and Law Enforcement
Liv cooperates with government and law enforcement officials to enforce and comply with applicable law. Accordingly, we may disclose to government and/or law enforcement officials relevant or required Personal Information in order to meet any applicable law, regulation, legal process or enforceable governmental request.
Your Privacy Controls: Reviewing, Changing and or Deleting Your Personal Information
You have choices regarding the Personal Information that we collect and how it’s used. This section describes key controls for managing your privacy across our Services and the Liv Platform.
Managing, reviewing and updating your Personal Information
You can request a copy of your Personal Information from us by emailing us at: firstname.lastname@example.org. You can export a copy of the Personal Information in your Liv Account if you want to back it up and/or keep a copy for your records. All Users may review, update, correct or delete the Personal Information in their Liv Profile and Liv Account by contacting us by email at email@example.com or by directly editing the relevant part of their Liv Profile within the Liv Account.
Deleting your Personal Information and deactivating your Liv Account
If you would like us to deactivate your Liv Account, please send us a deactivation request to my email (firstname.lastname@example.org). Once we receive your deactivation request, your Liv Account will be deactivated within three (3) business days. Once an account is deactivated, all of your Personal Information on your Liv Account (except as set out below) — including your name, contact information, profile settings, search history and Liv Score — will be permanently deleted. Some of your Personal Information may remain in back-ups or system cache files for up to five (5) business days. We refresh our system back-ups and cache every five (5) business days. Once a Liv Account has been deleted, all Personal Information (except as identified below) will be deleted, including back-up files and cache, within five (5) business days, subject to any non-personally identifiable information that has been collected as Log Data, etc. during the course of your use of the Liv Account on the Liv Platform and as set out below. Your Personal Information that was previously disclosed in rental applications and Contracts that you completed and authorized to be distributed via the Liv Platform with prospective and actual Landlords will not be permanently deleted due to the consent you provided us to authorize the third party disclosure of your Personal Information in order to complete the rental applications and enter into the contractual relationship between you and the Landlord(s) as parties to any Contracts entered into. Your name will appear in the record of any messages between you and any Landlords had within the Liv Platform since this was authorized by you and cannot be deleted from such other parties’ correspondence history within their own Liv Accounts. You can ask us for a record of all of the applications and Contracts that you entered into by emailing us at email@example.com.
Liv is very concerned with safeguarding your Personal Information and we build security into our Services in order to protect your Personal Information. We work hard to protect you, all of our Users and the Liv Platform from unauthorized access, alteration, disclosure or destruction of information that we hold, including:
- using encryption to keep your data private while in transit;
- encrypting the transfer of sensitive Personal Information (such as credit card numbers and/or your social insurance number) on our registration forms using AES-256-ctr;
- reviewing our physical security measures and information collection, storage and processing practices to prevent unauthorized access to our systems;
- restricting access to Users’ Personal Information to only the Liv employees, contractors and agents who need that information in order to process it. Anyone with this access is subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Additionally, as previously noted, we conduct routine audits of access logs by our Liv employees, contractors and agents who are permitted to have restricted access to certain Personal Information;
- following generally accepted industry standards and best practices to protect all Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission of information or data over the Internet, or method of electronic storage thereof, is 100% secure; therefore, we cannot guarantee the security thereof.
Once your Personal Information is received by us and is in our custody, we do our best to ensure that your Personal Information is secure at every step of the process.
If you have any questions about the security of Personal Information on the Liv Platform, you can contact our Privacy Officer at firstname.lastname@example.org.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email and or by an alert on the Liv Platform in the most expedient way possible and without unreasonable delay, insofar as this is consistent with (i) the legitimate needs of law enforcement in relation to any investigation or other legal process; and/or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the Liv Platform.
We collect, use and/or disclose your Personal Information only with your knowledge and consent, except where permitted or required by applicable laws. By choosing to provide us with your Personal Information, you consent to the use of your Personal Information as identified in this Policy and as may be further identified at the time of collection.
Express Consent. Sometimes we ask for express consent regarding the collection, use and or disclosure of your Personal Information – for example, by checking a box to indicate you consent to receiving marketing communications. When you expressly “opt in” – that is, provide your consent to receive our newsletter and/or marketing emails – you expressly consent to receiving information from Liv or the identified third party. You may choose to stop receiving such communication by e-mail and/or other electronic methods by following the unsubscribe instructions included in these emails or via your Liv Account (when applicable), and you can always contact our Privacy Officer at email@example.com if you need assistance or have concerns about giving or revoking express consent.
Implied Consent. You provide your implied consent to our collection, use and or disclosure of your Personal Information when we reasonably conclude that you have given consent by some action that you have taken or decided not to take. This typically occurs when the purpose for the use of your Personal Information would be reasonably apparent to you – for example, when you provide us with your name and email through a form asking for information, you are providing us with your implied consent to use that particular Personal Information (in this case, your email address) in order to respond to your request (in this case, by sending you the requested email(s)).
Withdrawing your Consent. You may notify us at any time that you would like to withdraw or change your consent to the collection, use and/or disclosure of your Personal Information. We accommodate all requests subject to legal and contractual requirements. The most common means of indicating this withdrawal or change is (i) by changing your privacy preferences in your Liv Account; or (ii) by deleting your Liv Account and ceasing use of the Liv Platform. You may be able to opt out of the use of your Personal Information by, for example, choosing to “opt out” of our mailing list after you have chosen to “opt in”. For example, if you receive an email from us, we will provide a link in the email that you can use to unsubscribe from our mailing list, or you may email our Privacy Officer at firstname.lastname@example.org to request your removal from the mailing list. You may also choose to not provide us with your Personal Information; however, if you choose to do so, we may not be able to provide you with our Services or the information that you have requested.
We comply with the Canadian law known as Canada’s Anti-Spam Legislation (“CASL”). Any email or other electronic communication sent by us to you or other parties is protected by a range of business procedures and policies to ensure that such communication is done so in compliance with CASL at all times. In our electronic communications with third parties, we comply with the rules and regulations established in and pursuant to CASL, which are enforced by various regulatory authorities such as the Canadian Radio-Television and Telecommunications Commission (CRTC). CASL regulates, and our policies generally apply to, each commercial electronic message (“CEM”) that we send, which is an electronic message sent to an electronic address that, among its other purposes, encourages participation in a commercial activity.
We ensure that our CEMs are compliant with CASL in that they will always clearly:
- identify us as the party sending the CEM and whether we are sending it on our own behalf or in conjunction with or on behalf of another party;
- provide our contact information;
- set out a mechanism to unsubscribe from our CEMs that is easy to use, automatic and at no cost to you;
- convey the appropriate information in all parts of the CEM (the banner, header, any links or URLs in the CEM and its content overall), whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you have received a CEM from us, and you believe that it was sent incorrectly or you no longer wish to receive them, please follow the unsubscribe instructions included in each CEM. This unsubscribe should happen automatically or, as required by CASL, within 10 business days at the latest. If you have any questions or concerns, please contact our Privacy Officer by emailing us at email@example.com.
Transferring Personal Information from the European Union to Canada
We are located in Canada. Personal Information that we collect from you will be processed in Canada, with the exception of Google Analytics and Google Fire-based Analytics as well as the services provided by Google Ads and certain of the whitelisting services of Amazon Web Services (“AWS”), which Liv uses to permit the secure access of the services of third party credit reporting agencies when you authorize us to request your Credit Reports for inclusion in the calculation of your Liv Score. In addition, given the availability of the Liv App on the Apple Store and Google Play Store, these platforms require the utilization of iOs and Android analytics in relation to the Liv App. This transfer of Personal Information therefore involves a transfer of your Personal Information to servers and service providers in the United States of America (“USA”), which Personal Information therefore may become subject to the Patriot Act and other legislation of the USA. However, all other information will be processed in Canada. Canada has received a finding of “adequacy” from the European Union (“EU”) in 2001 for the purposes of Article 25 of the General Data Protection Regulation (“GDPR”). Under the GDPR, Canada will have to seek a reassessment by the EU of the adequacy of Canadian privacy protections every four years. We collect and transfer to Canada only the following Personal Information from Users of our Site who are located in the EU when you consent, in order to perform a service for you as contracted or purchased by you, or to fulfill a compelling legitimate interest of Liv in a manner that does not outweigh your rights and freedoms: your name, email address, and phone number in order to open a Liv Account; a copy of your government issued identification card to verify your identity; and other details, such as your geographic location; address; profession; salary range; profile photo/avatar; professional/landlord references; and roommate details upon your full completion of a Liv Profile in order to permit you to submit leasing applications via our Liv Platform at your discretion. We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with and authorization to us and the practices described in this Policy. We also enter into data processing agreements with our third party service providers whenever feasible and appropriate.
Your California Privacy Rights
If you live in California and are a User of the Liv Platform, you can request a list of your Personal Information that we have shared with third parties for marketing purposes. We will also give you a list of the third parties who have received your Personal Information otherwise. You can make a request one time each calendar year.
To exercise these rights, you can email our Privacy Officer at firstname.lastname@example.org and mention that you are making a “California Shine The Light” inquiry. We will respond within 30 days.
Applicable Laws, Disputes
If you are not satisfied with our Privacy Officer’s response to your questions or concerns, you may file a complaint under Applicable Laws and the Privacy Officer can provide you details regarding such complaint processes.