Privacy Policy

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.          

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. 

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.

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.

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:  

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.

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.

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. 

Any information (personal or not) the Website collects while you use it may be stored locally on your computer or handheld or tablet device (the “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.

• 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.

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. 

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.

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.). 

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.