Privacy & Security
Privacy and Data Policy
Updated: May 15, 2019
1. Why do we handle personal information at Naborly?
Landlords have traditionally performed due diligence on prospective tenants with reference checks, confirmation of income and gathering any personal information on prospective tenants to properly protect their property as they could. Naborly does it for them with information the prospective tenant provides or makes publicly available. Additionally, Naborly maintains the Naborly accounts by tenants and landlords so they can access their rental information at any time.
2. How does Naborly collect personal information?
Naborly collects personal information through the naborly.com website, including all subpages and successor pages (collectively referred to as the “Website”), as well as through its services, including the Naborly Tenant Screening form that may be made available on a third-party website, or other services offered through our Website when prospective landlords and prospective tenants register through Naborly services. We may also collect information that are publicly available.
3. How does Naborly ensure consent?
Naborly ensures valid consent to the collection, use and disclosure of personal information in three ways:
(a) We alert visitors of cookies on our website and of the option to disable them.
(b) We receive consent when individuals choose to open an account with us.
(c) We require from Prospective Landlords evidence of consent from their Prospective Tenants with our Tenant Screening form.
Consent may be withdrawn by contacting Naborly at email@example.com. Please note that withdrawing consent may affect the ability to continue to receive certain products and services. IF YOU DO NOT CONSENT, OR HAVE WITHDRAWN YOUR CONSENT, TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY, YOU SHOULD IMMEDIATELY STOP USING OUR SERVICE AND WEBSITE, AND SHOULD NOT PROVIDE PERSONAL INFORMATION TO US.
4. What information does Naborly collect?
With consent, we may collect information from various sources, including credit reporting agencies, collection agencies, government entities, legal suppliers, and personal information that the individual has made available to the public. We also collect information directly, from Prospective Landlords or Prospective Tenants.
If you are a Prospective Landlord
To gain full access to our Website and Service as a Landlord, you must register for a Naborly account. When you register for an account, we need your personal information, including the following:
- Your name, company name, email address, physical address, phone number, account password and Government issued photo ID to ensure we send personal information about Prospective Tenants to the right person;
- Payment information, to complete your transactions;
- Your IP addresses, devices, and locations used to access Naborly;
- Information regarding your rental property.
We may request and collect additional information from you after you have registered for an account. If so, we will explain why and seek your consent.
When you register, we will also seek your consent to retrieve additional personal information about you from third parties and other identification/verification services such as credit-reporting agencies. We may also collect additional personal information in other ways, including through emails, surveys, and other forms of communication. Once you begin using the Service through your Naborly account, we will keep records of your transactions and collect information of your other activities related to our Service.
If you are a Prospective Tenant
Naborly collects personal information for the purpose of providing the Service to Landlords and operating the Website, some of which may be collected for the purpose of disclosure, with your consent, to the Prospective Landlord.
This information constitutes a Consumer Report Information which may include:
- Contact information, including telephone number, email address and postal code;
- Credit information, including credit checks, credit references, name, current/ former address, date of birth, current/ former employment, paying habits, outstanding debt obligations, estimated income, cost of living obligations, etc.;
- Identifying information, including your name, current/former address;
- Information for your co-applicant, as the case may be, such as name, email, and relationship to you;
- Information about dependents, such as name, age and relationship to you;
- Publicly accessible information, including but not limited to information from public records, tenant database records, public social media content, information accessible via the internet, etc.;
- Rental history information, including monthly rent, evictions, property damage, current and previous addresses, reasons for moving and landlord contact;
- Additional information through the Prospective Tenant form, such as vehicle and commute information, pets’ name, animal type, breed, age, weight and training.
Consumer Report Information will only be disclosed to the Prospective Landlord with your express consent, which is sought through our Service or Website.
5. How does Naborly use information?
We use collected information for a variety of purposes, including:
- to verify the identity of both landlords and tenants using our Service;
- to communicate with landlords, tenants and relevant third parties;
- to establish Prospective Tenant’s reliability and ability to pay;
- to obtain, review and analyze Consumer Report Information;
- to disclose Consumer Report Information to Prospective Landlords, where consent has been obtained from the Prospective Tenant;
- to investigate and resolve inaccuracies in the information we have obtained;
- to provide, maintain and improve the Service and the Website, including the user’s Naborly account;
- to monitor, review and improve customer service and internal business processes;
- to audit or investigate the use of our products and services, and to investigate and prevent fraud or other illegal activities;
- to track and analyze trends and usage of the Service and the Website;
- to offer and provide Naborly product and services;
- to create and develop new products and services;
- to provide to third party service providers in connection with provision of the Service and the Website and/or to create or offer products and services; and
- to comply with all applicable laws
6. How does Naborly share information?
Naborly will not disclose personal information except to share it with third party partners for the reasons we or Prospective Landlords have disclosed including the following:
- to provide the Service, the Website and other related services to you and to our customers;
- to collect and evaluate additional information about Prospective Tenants, in connection with provision of the Service;
- to deliver data and products to direct-to-consumer resellers with which the Prospective Landlord has contracted directly;
- to communicate with Prospective Landlords regarding services that may be of interest to them;
- to manage, administer, collect or otherwise enforce accounts;
- to third party service providers, in connection with provision of the Service and the Website and/or to create or offer products and services;
- to investigate or to assist in the investigation of a contravention of a law and/or fraudulent activities;
- to investigate or assist in the investigation of violations of our terms of service;
- to fulfill our obligations under consumer reporting and privacy legislation, as well as any other legal or regulatory obligation; and
- for other purposes as permitted or required by law.
7. Where is the personal information stored?
Personal information may be processed or stored in Canada, the United States and other countries. As a result, your personal information may be subject to local laws, which may permit local law enforcement, government or national security authorities to have access to your personal information in certain circumstances. Still, we never disclose personal information without demonstration of lawful authority to access it.
In the event that we disclose your personal information to a third party for processing or storage, we require such third party to protect your personal information in a manner consistent with our own privacy measures, subject to the law of the applicable jurisdiction.
8. How can you access your personal information at Naborly?
Upon request and subject to verification of your identity, we will inform you of the existence of personal information about you that we hold and, except in limited situations, will provide you access to the relevant information. In certain situations, we may not be able to provide access to some or all the personal information about you that we hold. This may include situations where information is prohibitively costly to provide, information contains references to other individuals, information cannot be disclosed for legal, security, or commercial proprietary reasons, or where information is subject to solicitor-client or litigation privilege. In such situations, Naborly will provide reasons for denying access to the information upon request.
Formal requests for access, deletion or concerns regarding protection of personal information at Naborly may be made to: firstname.lastname@example.org. In addition, complaints can be made to the Data Protection Supervisory Authority of your country or province.
9. How does Naborly keep your information accurate and for how long?
You may update or correct personal information about yourself by logging into your account at any time or by emailing us at email@example.com. You may also email us if you wish to deactivate your account. We will retain your information as long as you keep your account active. When you choose to deactivate your account your information is destroyed or made anonymous, except where required by law to retain archived copies of information about transactions for a fixed period of time.
With respect to credit reports, Naborly may utilize reports provided by one or more third-party credit-reporting agencies. If you have concerns regarding the content of your credit report(s), we encourage you to obtain and review such reports directly from these agencies. Under applicable laws, you may have certain rights to access and correct your credit information on file with these agencies.
10. How does Naborly protect personal information?
Naborly maintains safeguards to protect the personal information in its custody from loss or theft, as well as to prevent unauthorized access, collection, use, disclosure, modification, copying, disposal or similar risks appropriate to the sensitivity, amount, distribution, format and method of storage of the information.
Naborly employees are required as a condition of employment to respect the confidentiality of Personal information. Similarly, we require our third-party service providers to take appropriate measures to protect your personal information, by contractual agreement stipulating, among other things, the confidentiality of the information and the purposes for which it is to be used. Authorized third parties to whom we disclose personal information must also undertake to limit their use of personal information to the purpose of tenant screening, in accordance with any applicable laws.
Please be advised that authorization of disclosure to third party recipients must be sought from Prospective Tenants by Prospective Landlords who are responsible for its protection. Prospective Tenants should not consent to or authorize disclosure in situations where they suspect, or should reasonably suspect, that their personal information may be misused.
207 Adelaide Street East, Unit 302
Toronto, Ontario, M5A 1M8