Summary of key changes:
- We improved readability of our Privacy Policy by using plain language and adjusting the layout to make everything even easier to understand.
- We improved the content of our Privacy Policy by providing granular information on our data handling practices and removing outdated information for further transparency.
- We further defined our communication channels with you.
Welcome to the Potloc Website!
Potloc Inc. (“Potloc”, “we”, “us” or “our”) is committed to the privacy and security of your personal information. This Privacy Policy (the “Policy”) explains the privacy practices of Potloc which apply to the processing activities of Potloc as controller in respect of personal information (i) collected by us when you use the website located at http://potloc.com, which is owned and operated by Potloc, and includes all subdomains and apps, present and future (the “Website”), including through your participation in surveys and the provision of Testimonials (as defined below), (ii) provided to us by our clients and affiliates in order to enable us to reach out to you (e.g., a client may give us their custom audiences in order to enable us to conduct a survey targeted to people who clicked on the ad of that client), and (iii) when you communicate with us by any means or agree to receive emails from us.
For the avoidance of doubt, this Policy does not apply to the general practices and processing of personal information by third parties who do not process personal information on behalf of Potloc, including but not limited to (i) our clients if (and to the extent that) we act for them as their processor and, more generally, (ii) the editors/providers of any third-party websites or goods/services (“Third-Party Website” or “Third-Party Service”) that you elect to access/utilize through the Website or via a link from the Website. While we attempt to work only for clients – and 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 editors/providers of Third-Party Websites or Third-Party Services. We encourage you to carefully review the privacy policies of the editors/providers of any Third-Party Website you access or Third-Party Service you use.
Additional definitions may be made throughout this Policy, but they will be recognizable as they will be capitalized, bolded, and in quotation marks. Additional definitions may also be found in the Terms of Use (the “TOU”), and will have the same meaning in this Policy as they do there. The definitions found in this Policy shall also apply to the TOU. The Policy should be read in conjunction with the TOU, as both these documents govern your use of the Website.
If you have any questions, concerns or comments about our treatment of your personal information or this Policy, please contact our Privacy Officer and our Data Protection Officer appointed under the GDPR at privacy@potloc.com or at 5420 Saint-Laurent Street, Suite 300, Montreal, Quebec, H2T 1S1, Canada. Our representative in the European Union is Potloc France, which can be contacted at 63 Rue Sainte-Anne, Paris, 75002, France. Our representative in the United Kingdom is Rickert Services Ltd UK which can be contacted at PO Box 1487 Peterborough PE1 9XX United Kingdom or via email at art-27-rep-potloc@rickert-services.uk.
1. Collection and Use of Personal Information
We collect your personal information in a number of ways and for a number of different purposes, depending on their different categories. Please see the table below for more details.
Categories |
Examples |
Purposes |
Legal basis |
| Survey or testimonial information | First name, email address, age, gender, postal code, marital status, primary occupation and household income. You may also choose to provide us with additional personal information when you fill out free fields in our questionnaires. | Collected in the context of the consumer surveys Potloc conducts on behalf of its clients, leading to the establishment and transmission of statistics. Potloc’s activities actually consist in conducting surveys on behalf of its client towards a targeted audience. When Potloc acts as controller, Potloc determines the questions asked, and therefore, some of the personal information required, depending on the purpose and nature of the survey in question, as well as on the expected results. | It is necessary for the purposes of the legitimate interests pursued by us in performing the market study for the benefit of our client(s). |
| Communication information | Respondent, client or website visitor feedback, communication preferences and marketing preferences including email address and phone numbers. | Collected to enable us to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you as further described below in this Policy. In particular, Potloc may contact you – or enable our clients to contact you – individually following a survey or a Testimonial to provide you with information that may be of interest to you, subject to applicable laws. | You gave your consent to receiving electronic solicitation from us or on our behalf. |
| Technical information | Browser type, IP address, pages visited on our website. | Collected through cookies, including third-party cookies, on our Sites for the purpose of improving website functionality, and fixing bugs. For more information about our usage of cookies, please refer to our Cookie Policy. | (i) In case of use of cookies that are not strictly necessary for the operation of our website, you gave us your consent to store cookies on your terminal equipment and collect information from your terminal equipment for the purposes of improving our services (functionality and analytics cookies) or for advertisement purposes; (ii) Otherwise, it is necessary for the purposes of the legitimate interests pursued by us in improving our services. |
| Usage & performance information | The date, time and duration of your visits on the Website, the pages viewed and links clicked on the Website, your language preferences, browsing history, and the web pages that redirected you to our Website. | Collected through cookies, including third-party cookies, on our Sites to allow us to compile aggregate data about traffic and interactions on our Website in order to improve the experience and tools on our Website and to provide customized website experiences to our users. For more information about our usage of cookies, please refer to our Cookie Policy. | It is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing the contract with the company you are representing. |
| Contact details of individuals representing clients of Potloc | Name, role with the Client, email address. | Collected to enable us to contract with the company you are representing and delivering any notice the company we contracted with in performing such contract. | It is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing the contract with the company you are representing. |
Please note that we may also collect and use your personal information for any other purpose permitted or required by law.
In addition to the personal information we collect directly from you as described above, we may obtain the following personal information from other sources.
Categories |
Examples |
Purposes |
Legal basis |
| Online identifier of a terminal used for clicking on the advertisement of one of our clients | The client who sends us a custom audience (or other) file containing the online identifiers of the terminals that clicked on its advertisements for enabling us to contact the individuals whose terminals have been used for clicking on these advertisements and ask them to answer a survey for the benefit of this very client. | When our clients provide us with (i) custom audience files (containing an online identifier of the persons who clicked on our clients' advertisements) and/or (ii) contact details of their clients or prospective clients, we use this information to reach out to these individuals and ask them to answer the survey for the benefit of our clients. | It is necessary for the purposes of the legitimate interests pursued by our clients in improving and/or marketing their goods or services as well as our legitimate interests in delivering our market study services to our clients. |
| Contact details of their clients or prospective clients of one of our clients | The relevant client for enabling us to contact these individuals and ask them to answer a survey for the benefit of this very client. | ||
| Contact details of individuals representing prospective clients of Potloc | Our affiliates (e.g., Potloc France) through their sales teams. | When our affiliates provide us with the contact details of individuals representing prospective clients, we use this information to reach out to them for the purposes of entering into a contract with such prospective clients and subsequently performing such contract. | It is necessary for the purposes of the legitimate interests pursued by us in entering into and/or performing such contract. |
We would not generally need to obtain personal information from publicly accessible sources such as Facebook or Linkedin in order to conduct our surveys but would let you know if it is the case.
We may also generate anonymized or aggregated information, which we use for our business purposes at our sole discretion. This is necessary for the purposes of the legitimate interests pursued by us in algorithms and services and contributing to industry reports and academic research.
2. Disclosure of Personal Information to Third Parties
We share your personal information with third parties where necessary to fulfill the purposes identified above, and more specifically, as set forth in the table below:
Categories |
Purposes |
| Service providers | We may disclose your personal information to third party service providers to enable us to provide requested services, such as payment processing, marketing, maintenance, and website hosting. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information in compliance with applicable laws. |
| Professional advisors | We may disclose your personal information to our legal, financial, accounting or other consultants to the extent necessary to operate our business and comply with applicable laws. |
| Law enforcement & other government agencies | We may disclose your personal information to comply with legal obligations and respond to lawful requests. We verify that the request is legitimate before responding. For greater clarity, we may disclose personal information or other information if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. |
| Business transaction | We may disclose your personal information if Potloc merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy). |
| Affiliates | We may disclose your personal information 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 and applicable laws) to properly create consumer research reports or to carry out geolocated campaigns. |
Except as provided in this Policy, or subject to applicable laws, Potloc does not disclose any personal information to third parties.
We take steps to ensure that only those employees who need access to your personal information to perform their duties have access to it.
3. Transfer of Personal Information
Your personal information is hosted on the servers of our trusted service provider Amazon Web Service in the United States with backups located in Canada. As a result, your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers (e.g. Canada, United States, France). You consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country of residence. While such information is outside of your country of residence, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
However, our practices regarding your personal information will at all times continue to be governed by this Policy and, if applicable, we will comply with, where applicable, the GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country, notably by implementing appropriate safeguards such as standard contractual clauses in case of a country for which there is no decision of the European Commission. You may obtain a copy of the standard contractual clauses being relied upon by requesting it to us.
4. Security and Retention of Personal Information
Potloc has implemented reasonable physical, administrative and technical safeguards designed to preserve the confidentiality, integrity and security of personal information under our control. 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. However, information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure, and no security can provide absolute protection. As a result, we do not ensure, warrant or guarantee the security or integrity of such information.
Your personal information are retained for as long as is necessary for us to fulfill the relevant purposes specified in this Policy and to comply with our legal obligations. Particularly:
- Your personal information processed for the purpose of survey and statistical purposes will not be retained after the end of the corresponding survey (save for data collected by us in our capacity as processor on behalf of our clients, whereupon this data is retained in accordance with the privacy statement of the relevant clients);
- Your personal information processed for the purpose of sending you commercial communications or contacting you individually to provide you with information that may be of interest to you, will not be retained more than three (3) years after your consent or your subsequent last contact with us or our client on behalf of whom such commercial communications are made, as the case may be;
- Data collected through cookies (which expire after no more than six (6) months) is retained for a maximum of 25 months.
5. Devices and Permissions
- Localization services. Allows the Website to determine your location through network services to adapt the content locally.
- Cookies. Potloc uses cookies for the proper functioning of the website, establishing statistics and improving our services and also to facilitate your navigation on the website, to record your preferences, optimize the experience on the platform and know yourself better. For more information, please refer to our Cookie Policy.
6. Your Rights Regarding Personal Information
Under certain circumstances and subject to applicable data protection laws, supported by a written request and an proof of identification, you may consult the personal information that we have collected, used or disclosed, and/or ask that it be corrected, and/or withdraw your consent to our disclosure or use of personal information collected.
As required or permitted by law, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to object to unlawful data processing, under certain conditions; (iii) the right to erasure of personal information about you, under certain conditions; (iv) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe that we have exceeded the legitimate basis for processing, that processing is no longer necessary, or that your personal information is inaccurate; (v) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vi) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions. Where applicable, you have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the California Consumer Privacy Act (CCPA).
Finally, you have also a right to lodge a complaint with a competent data protection supervisory authority, in particular in the country/province/state where you normally reside, where we are based or where an alleged infringement of data protection law has taken place, such as the Commission d’accès à l’information du Québec or the Office of the Privacy Commissioner of Canada.
To exercise any of these rights, please contact us as set forth in the introduction.
7. Children’s Privacy
We do not knowingly collect personal information from kids under the age of 14 on our Website. If you are the parent or legal guardian of a child under 14 who has provided us with personal information, you may contact us using the contact information as set forth in the introduction to ask us to stop using or to delete that information.
8. Marketing Communications
If at any time you wish to stop receiving marketing messages from us, we include an unsubscribe mechanism in all of our electronic communications or you can contact us as set forth in the introduction. Please keep in mind that, if you choose not to receive marketing communications, you will continue to receive transactional or account communications related to services or products that you have requested on the Websites (e.g. confirmation e-mails, billing reminders, etc.).
9. Updates to this Policy
Potloc reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Website following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, you will be notified by email.
Learn more about Potloc and the California Consumer Privacy Act (CCPA) here.