1. GENERAL STATEMENT OF PRIVACY
Potloc takes your privacy and security of Personal Information (as defined below) very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information.
2. SCOPE OF POLICY
Personal Information. This Policy covers the treatment of personally identifiable information (“Personal Information”) and other information gathered by Potloc when you are using the Website and provide insights and opinions when answering our surveys. This Policy also covers Potloc’s treatment of any Personal Information that Potloc may share with its business partners or other third parties under very limited circumstances.
Third Party Services. This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that Potloc does not own or control, including but not limited to any third-party websites or services (“Third-Party Website” or “Third-Party Service”) that you elect to access through the Website or via a link from the Website. While we attempt to facilitate access or link only to those Third-Party Websites or Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites or Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Website you access or Third-Party Service you use.
Communications. This Policy does not cover any Personal Information you send to Potloc via any mode of communications such as email, instant messenger, Facebook, Twitter, Instagram or any other existing or future social media, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to Potloc via these methods.
No Collection of Personal Information as a Matter of Course. Potloc does not, as a matter of course, gather any of your Personal Information while you are using the Website, unless you are asked to provide such information. Personal Information is only gathered with your informed consent. Where you have provided Personal Information, it will only be used for the stated purpose, as detailed more specifically in the next section.
Limited Collection. The following is an exhaustive list of Personal Information collected from you when you use the Website and what we use it for. You acknowledge that you are submitting this Personal Information with your informed consent.
- While visiting the Website, you may be required to provide the following accurate and truthful Personal Information: first name, email address, age, gender, postal code, marital status, primary occupation and household income. These Personal Information are used for survey and statistical purposes. We may also use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you as further described in Section 5 (Mailing List Management).
3. NON-DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
Limited Disclosure. Except as provided in this Section 3, and in Sections 5 (Mailing List Management) and 6 (Security and Encryption of Information) and unless Potloc’s users expressly consent to receive commercial electronic messages from identified third parties, in which case Potloc would only communicate to such third parties the email addresses of consenting users, Potloc does not divulge any Personal Information gathered via the Website to third parties.
Moreover, subject to situations where Potloc’s users expressly consent to receive commercial electronic messages from identified third parties, in which case Potloc may sell, rent, trade or license to such third parties the email addresses of consenting users, Potloc does not sell, rent, trade or license any Personal Information regarding its users to third parties. Only the employees, representatives, subcontractors, officers, agents, or assigns of Potloc (collectively, the “Representatives”) are responsible for the management and development of the Website, and only these individuals have access to the information collected there. These Representatives all have been instructed to comply with the Policy.
We may share any information we have collected about you or that you have submitted (whether Personal Information or not):
- in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands;
- if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the TOU;
- if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Website generally);
- to a parent company, subsidiaries, joint ventures, or other companies under common control with Potloc (in which case we will require such entities to honour this Policy);
4. COLLECTION, USE AND DISCLOSURE OF NON-PERSONAL INFORMATION
Usage Information. We collect information about usage of the Website from within the Website (“Usage Information”), but none of this information identifies you personally. For example, each time you use the Website, we automatically collect the list of most used screens by users. Usage Information can also consist in your testimonials and answers (“Testimonials”) to the questions we ask you within the framework of surveys available on the Website with the purpose of obtaining your views on local retail projects and various consuming habits you may have (“Surveys”). We use Usage Information collected in this manner (i) to better understand your needs and the needs of the Website users in the aggregate; (ii) for statistical purposes to keep track of the usage of the Website with a view to introducing improvements; (iii) for statistical purposes to synthetize your (and other Website users’) views and opinions collected through the Surveys; and (iv) to trace any fraudulent or criminal activity, or any activity in violation of the TOU.
Limited Disclosure. We may share certain Usage Information with third parties so as to optimize our Website, provide statistics on the use of our Website and provide statistics on your views and opinions collected through the Surveys, or provide targeted marketing offers.
5. MAILING LIST MANAGEMENT
Third Party Service Providers. Potloc may use Third-Party Services to manage our mailing list and send out emails. In which case, Personal Information is transferred to such Third-Party Service providers in order for the mailing list to function properly. Your Personal Information is only used for the proper sending out of email. If Potloc uses any such Third-Party Service provider, it will obtain representations from them that they do not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party.
Unsubscribe. You may unsubscribe from Potloc’s mailing list at any time, by following the link at the bottom of all Potloc emails or by contacting us at firstname.lastname@example.org.
6. SECURITY AND ENCRYPTION OF INFORMATION
Security. Potloc uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, Potloc uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Website, and these third parties have been selected for their reliability in terms of security, both electronic and physical. You acknowledge that our third-party vendors and hosting partners may be located in jurisdictions or countries where the privacy laws may not be as protective as those in your home province, state, country or other governmental jurisdiction.
Risks Associated with the Internet or Wireless Data Transmission. Despite Potloc’s best efforts to ensure third parties will not access or obtain your Personal Information through the Website, complete confidentiality and security cannot currently be guaranteed on the Internet and/or where data is transferred via wireless digital technology of any type. Communication in this manner is subject to interception, loss, or alteration. You acknowledge and agree that Potloc cannot be held responsible for any losses or damages whether pecuniary or otherwise resulting from the transmission of your Personal Information in this manner and that such communications are at your own risk.
7. GENERAL INFORMATION TRANSFER FROM THE WEBSITE
Any information (personal or not) the Website collects while you use it may be stored locally on your computer or handheld or tablet device (“Device”) and then transferred to servers controlled by Potloc, and Potloc may obtain this information as a result of the data being sent to our servers from the Website. The information, however, is only used (or not used) by Potloc as described elsewhere in this Policy.
The following is a complete listing and description of what functions on your Device that were developed by third parties are accessed and / or modified by the Website. Unless otherwise specified, these permissions apply both to iOS Devices and Android Devices.
- Localisation services. Allows the Website to determine your location through network services to adapt the content locally.
- Cookies tracking. Allows the Website to track your behaviours on the Website for 180 days after your last connexion to optimize the experience on the platform.
9. ACCESS TO AND DELETION OF PERSONAL INFORMATION
If you wish to inquire about and access what Personal Information Potloc holds about you, or if you wish to delete any Personal Information held about you from our databases, please contact us at email@example.com.
10. COMPLIANCE WITH PRIVACY LAWS AND ANTI-SPAM LAWS
Privacy. This Policy and Potloc’s practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5) and Quebec’s An Act Respecting the Protection Of Personal Information in the Private Sector (R.S.Q. c. P-39.1). If you have any questions regarding this compliance, please contact us at firstname.lastname@example.org.
Anti-Spam. Potloc is committed to ensuring that we respect anti-spam legislation, specifically the U.S. CAN-SPAM Act of 2003 (15 U.S.C. Ch. 103) and the Canadian law informally known as Canada’s Anti-Spam Law (“CASL”, S.C. 2010, c. 23). If you feel you have received emails from us in violation of these laws, please contact us at email@example.com.
11. LIMITATION OF LIABILITY
POTLOC, ITS AFFILIATES, AND THEIR RESPECTIVE SHAREHOLDERS, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, PARTNERS, PRINCIPALS, SUPPLIERS, LICENSORS, REPRESENTATIVES, SUCCESSORS AND ASSIGNS WILL NOT BE HELD LIABLE FOR ANY LOSSES OR DAMAGES (DIRECT OR INDIRECT, PECUNIARY OR OTHERWISE) RESULTING FROM THE MISUSE OF ANY INFORMATION COLLECTED BY ANY THIRD PARTY, OR ANY MISUSE OF ANY INFORMATION COLLECTED THROUGH THE WEBSITE NOT IN VIOLATION OF THE POLICY. IN ADDITION TO THE FOREGOING AND THE OTHER TERMS OF THIS POLICY, YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS ALSO SUBJECT TO THE TOU (INCLUDING THE LIMITATION OF LIABILITY PROVISIONS).