Privacy & Data Policy
Privacy and Data Policy
Updated: October 28, 2021
Thank you for visiting the Naborly website located at https://www.naborly.com/ (the “Website”).
- Why do we handle personal information at Naborly?
When evaluating a tenancy relationship, landlords may wish to screen prospective tenants by conducting reference checks and confirming income and past tenant history. Naborly’s Services can help landlords with this process.
- How does Naborly collect personal information and what personal information do we collect?
Naborly collects personal information through our Website and Services.
Information you provide directly to us
When you visit our Website, use our Services or contact us, you may provide us with certain personal information. To gain full access to our Services, you must register for a Naborly Account.
The Application form may be made available on a third-party website, Landlord
With consent as part of the requested screening process 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 Landlord
When you register for an Account, you are required to provide certain personal information, including the following:
- Your name, company name, email address, physical address, phone number, Account password and a copy of Government issued photo ID Payment information, such as credit card and billing information, to complete your transactions; and
- Information regarding the Subject Property.
When you create an Account, 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 request and collect additional information from you after you have registered for an Account. If so, we will explain why and seek your consent.
- If you are a Tenant
When you register for an Account as a Tenant, you are required to provide us with the following information:
- First and last name;
- Current contact information such as address, email address and telephone number
- Current employer and/or income sources
- Government issued ID
To be considered for tenancy at a Subject Property, a Tenant must complete an Application. As part of the Application process, you must provide the following information:
- Previous rental addresses and/or past Landlord’s contact info
- Roommate, spouse or pet information for planned occupancy
- Vehicle/parking requirements for planned occupancy
When you complete an Application, you are required to provide consent for us to collect additional personal information from third party sources, such as credit reporting agencies. Tenants may also be required to consent to a background check, carried out by a third party. You acknowledge and agree that by completing an Application, you are providing express consent for us to (a) collect your personal information from third party sources for the purposes of providing the Services and (b) provide your Consumer Report Information (as defined below) to the Landlord who is associated with the Subject Property.
Following receipt of a complete Application, Naborly will collect the above information from third party sources to create the applicable Naborly Reports. The content of the report depends on the specific service requested by the Landlord, but such report may include the following information about a Tenant (collectively, the “Consumer Report Information”):
- Your name and date of birth;
- Current and prior contact information, including telephone number, email address, physical addresses 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.;
- 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, social media profiles, information accessible via the internet, etc.;
- Rental history information, including monthly rent, current and previous addresses, reasons for moving and landlord contact info;
- Additional information through the Prospective Tenant form, such as vehicle or pet info
The Consumer Report Information will be disclosed to the Landlord associated with the Subject Property. At any time, you may withdraw your Application or revoke a Landlord’s to your Consumer Report Information. The Landlord associated with the Subject Property will no longer be able to view your Consumer Report Information once it has secured a tenant for the Subject Property.
- For all Users
We may also collect additional personal information in other ways, including through emails, surveys, and other forms of communication, including when you contact our customer service representatives for assistance.
Information we collect automatically
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.
When you visit the Website, if you consent to cookies, we may automatically collect certain information about your device, including information about your IP address and other unique identifiers and device information, some usage information such as the browser type, time zone settings, language preferences, operating system, length of visit, pages viewed on the site and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website as this information helps us understand how you use the Website features and the content of the Website in order to make improvements and tailor the content to your preferences.
We collect this information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier.
- “Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.
You can opt-out of cookies or prevent third-party websites from accessing our Cookies through the privacy settings on your browser. However, opting-out of our Cookies may disable some of our website’s features, and may prevent us from providing you with the information and services you have requested. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.
Other types of information collected.
You may sign up for SMS text reminders and push notifications by providing your phone number and opting-in in your Account. To stop the SMS messages, you may opt-out by texting STOP to any text sent.
We may also seek your consent to send you promotional emails. Consent for promotional emails may be withdrawn by clicking the unsubscribe link in the email footer, by visiting our Preference Center or by contacting Naborly at firstname.lastname@example.org.
Please note that when completing an Application process, Tenants will receive emails that are transactional in nature (i.e.: Account issues, ID verification, Landlord invitations/messages).and such emails will still be sent to you even if you unsubscribe from marketing emails.
- How does Naborly use personal information?
We may use your personal information for a variety of purposes, including:
- to verify the identity of both Landlords and Tenants using our Services;
- to communicate with Landlords, Tenants and relevant third parties;
- to establish Tenant’s financial profile/cash flow;
- to obtain, review and analyze Consumer Report Information;
- to disclose Consumer Report Information to Landlords, where consent has been obtained from the Tenant;
- to process payment for Services;
- 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 detect, investigate and prevent fraud or other illegal activities;
- to track and analyze trends and usage of the Services and the Website;
- to offer and provide Naborly product and services;
- to provide to third party service providers in connection with provision of the Services and the Website and/or to create or offer products and services; and
- for any other purposes to which you provided consent.
You may refuse to provide us with your personal information; however, some personal information is necessary in order to provide certain Services. Accordingly, if you refuse to provide us with required personal information, we may not be able to provide you with the Services.
Our Website might include links to third-party websites as well as content and applications hosted and served by third parties. When clicking on those links, these third-parties may collect your personal information. If you follow a link to a third-party website, please refer to the third-party’s privacy statement for information on the type of personal information it collects, and how it uses or discloses it and for information on its privacy practices.
- How does Naborly share information?
We share your personal information for the following purposes:
- to provide screening services for Landlords, credit building services (if you opt-in for Tenants), and other related services to our customers;
- to fulfill our obligations under applicable law, consumer reporting and privacy legislation, as well as any other legal or regulatory obligation regarding accuracy of information;
- to communicate with 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;
- payment processing by our third party payment processors; and
- to deliver data and products to direct-to-consumer resellers with which the Prospective Landlord has contracted directly;
- for other purposes as permitted or required by law, including to comply with any court order, law or legal process, including to respond to any government or regulatory request, in accordance with applicable law, or when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Naborly, our users or others.
Please be advised that Tenants must provide consent to Landlords before the Landlord can disclose any Consumer Report Information to a third party. Tenants are solely responsible for making this decision and should not consent to or authorize disclosure in situations where they suspect, or should reasonably suspect, that their personal information may be misused.
- Where is the personal information stored?
Personal information may be processed or stored in Canada and the United States. Information stored in a foreign jurisdiction may be subject to the laws of general application in the foreign jurisdiction, including lawful access.
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 and data protection standards, subject to the law of the applicable jurisdiction.
- How can you access or delete 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. You may also request that we delete your personal information. In certain situations, information cannot be disclosed or deleted 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 your request.
Formal requests for access, deletion or concerns regarding protection of personal information at Naborly may be made to: email@example.com. In addition, complaints can be made to privacy authority or regulatory in your country or province.
- 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 firstname.lastname@example.org. 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 and/or scores, Naborly may utilize reports provided by one or more third-party credit-reporting agencies. We have no control over or responsibility for such information. 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 have certain rights to access and correct your credit information on file with these agencies.
For a full list of your rights under the Fair Credit Reporting Act (US), please visit www.consumerfinance.gov/learnmore .
For a full list of your rights under the FCAC (Canada), please visit https://www.canada.ca/en/financial-consumer-agency/services/credit-reports-score/credit-report-score-basics.html
- How does Naborly protect personal information?
Naborly maintains reasonable safeguards to protect the personal information in its custody or control 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 with a variety of security protocols and training. 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 set out herein and such personal information must be processed in accordance with any applicable laws.
Your California Privacy Rights
We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Services. Please be mindful that this would not ensure complete removal of the content posted by you on our Services. To make any request pursuant to California privacy law, please contact us.
We do not knowingly collect personal information from children under the age of 13. None of our services are intended for use by children under the age of 13. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us and we will promptly respond.
Naborly Inc., 207 Adelaide Street East, Unit 302, Toronto, Ontario, M5A 1M8 Canada, email@example.com 1- 844-622-6759