Privacy Policy

(Latest Update: September 26th, 2023)

Welcome!

Welcome to Trustii. We hope that you will appreciate using our “Services”, which may be visiting our “Website” at https://www.trustii.co/ or any subdomain there of or using our “Web Application”, which refers to the online application available to “Requesting Users” and “Candidates” and which is accessible via a our Website or via a unique online link that we will provide to you by email or text message (SMS). The Web Application allows the Requesting Users to send a verification request to the Candidates of their choice, who will then be required to fill out a “Questionnaire”) to provide the necessary information to continue the rental or hiring process. The Requesting Users using our Web Application are customers of Trustii’s background verification services. The information gathered from the Questionnaire allows us to generate reports on the Candidates. These reports are sent to the Requesting Users in order to assist them in making a decision regarding the selection of a Candidate. Our Website provides general information about our purpose, our values, our products and our team. The Website and Web Application can be accessed on any device with a web browser.

Trustii Technologies Inc. (“Trustii”) (the company that owns and operates the Services) takes your privacy and security of Personal Information very seriously. We have provided and will continue to provide a secure environment and this strict Privacy Policy (The “Policy”) describes the limited ways your information is used and the limited access to such information.

Key Elements of this Policy

Here are the key elements of the Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your Personal Information (as defined below). You can find the details in the rest of the Policy.

About Us and Definitions

The Services are owned and operated by Trustii Technologies Inc., a corporation located in Montréal, Canada at the address listed below. Where this Policy refers to “Trustii”it may refer to Trustii and / or its affiliates, and its respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Trustii and / or its Representatives. In this Policy, a Candidate or any Website visitor may be referred to as “you” or “your”.

Additional definitions shall 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 and will have the same meaning in this Policy as they do there. The definitions found in this Policy shall also apply to the Terms of Use.

Acceptance and Modifications

By visiting or using the Website in any way, by providing information to us via Web Application or by filling out a Questionnaire, you agree to be bound by the terms of the Policy. By submitting Personal Information to us on the Website, the WebApplication or via other means, you consent to Trustii’s collection, use and disclosure of such Personal Information in accordance with the Policy (as amended from time to time) and as permitted or required by law. If you do not agree to all the provisions contained in the Policy, you are not authorized to use the Services.

Trustii reserves the right, at any time and without prior notice, to modify or replace, in whole or in part, the Policy. Any changes to the Policy can be found at the URL. It is your responsibility to check the Policy periodically for changes. You can always find the date of the most recent version or the Policy at the top of this page. Your use of the Services 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, we will use commercially reasonable efforts to notify you by sending a notice to your email address if you have provided us with your email via the Services.

The Policy should be read in conjunction with the Terms of Use, as both these documents govern your use of the Services.

If you have any questions about the Policy or if you wish to inquire about and/or access any Personal Information Trustii holds about you, please contact:

Trustii Privacy Officer
[email protected]

or:

Trustii Privacy Officer
465 McGill St. #700
Montréal, Québec, H2Y 1H1

What Does This Privacy Policy Cover?

This Policy covers the treatment of personally identifiable information, i.e. any information that identifies an individual, or can be used in conjunction with other information to identify an individual (“Personal Information”) and other information gathered by Trustii when you are accessing the Services. This Policy also covers Trustii’s treatment of any Personal Information that Trustii may share with its business partners or other third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether Personal or not) by third parties that Trustii does not own or control, including, but not limited to, any third-party websites or services that you elect to access through the Services or via a link from the Services that are not owned by Trustii, including the third-party websites or services of any Requesting User (“Third-Party Websites”), or to individuals that Trustii does not manage or employ. While we attempt to facilitate access or link only to those Third-Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites. We encourage you to carefully review the privacy policies of any Third-Party Website you access.

Finally, this Policy does not cover any Personal Information you send to Trustii via any non-secured, non-encrypted mode of communication, such as email, instant messenger or other messaging service, or Facebook, Instagram or any other 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 Trustii via these methods.

No Collection of Personal Information as a Matter of Course

Trustii does not gather any of your Personal Information while you access the Services, unless permitted or required by law, or unless you are asked to provide such information and voluntarily choose to do so. Personal Information is only gathered with your informed consent. By using the Services to (i) complete a Questionnaire because you are a Candidate interested in renting a rental property from or in a job opening proposed by a Requesting User; or (ii) to browse the Website to learn more about us, you are giving your consent to the collection, use and disclosure of your Personal Information as set forth in this Policy.

Personal Information Collected and Its Uses

The following is a list of Personal Information collected from you when you access the Services and what we use it for. You acknowledge and agree that you are submitting this Personal Information with your informed consent.

• “Questionnaire Information for Requesting Users” if you are interested in renting a rental property or by job opening with a Requesting User using Trustii’s background check services, you will receive an email from Trustii containing a link to a Questionnaire. The Questionnaire requires you to provide the following Personal Information that will be shared with the intended Requesting User (and to whom you have previously provided your contact information): name, email address, phone number, current employment status, employment information including your employer, your manager’s name and phone number, your rental status, your current landlord’s name, phone number and email address. This personal information will also be used by Trustii in an aggregated and/or anonymous manner to improve the Web Application and for internal business purposes.
• “Report-Generating Questionnaire Information” Not all of the Personal Information that we collect through a Questionnaire is shared with Requesting Users. We collect your SIN number, your date of birth, your current and previous addresses and your banking information (the “Report-Generating Questionnaire Information” in order to, respectively: access your credit report, conduct a criminal background check, determine whether you have been the subject of any cases before Québec’s Tribunal administratif du logement and access your banking records (which shall be collectively referred to in this Policy as “Externally-Sourced Personal Information”). The Report-Generating Questionnaire Information is not shared with Requesting Users.
• “Externally-Sourced Personal Information.” As follows from the Report-Generating Questionnaire Information, when we receive Externally-Sourced Personal Information about you, we use and share that Personal Information as described in this paragraph. We share your credit report directly with the Requesting Users. We share the case references for any case involving you before Québec’s Tribunal administratif du logement with the intended Requesting Users. We share the details of your criminal convictions (if any) with the Requesting Users. We share information generated by your banking records with Requesting Users – this means that we analyze your banking records and provide Requesting Users with (i) a verification of your identity (confirmation that your declared name matches the name associated with your bank account(s)); (ii) an internally generated score relating to your payment capacity to make monthly rental payments; (iii) whether you have a history of making late payments; (iv) confirmation that you are making a regular salary; and (v) any details regarding past bankruptcies or insolvencies.
• “Questionnaire Information for Trustii.” We also collect Personal Information through the Questionnaire that is not shared with Requesting Users, but that is used by Trustii in an aggregated and/or anonymized capacity in order to improve the Web Application and for internal business purposes. This includes your declared gender, level of education, the number of hours you work per week, your salary (on an hourly basis), your employment start date, whether you own any pets, the type of pets that you have, as well as a list and description of the people that you live with (including their relationship to you).
• “Contact Information.” If you would like to communicate with us by email or by telephone, you will be required to share your name, email address and phone number on our Website so that we are able to respond to you.

In addition to the functions and uses just described, Trustii may also use your Personal Information you have submitted in order to:

• Perform general user support;
• For legitimate business reasons, including: (i) to investigate and manage complaints; (ii) to understand your preferences, needs and to improve the Website and the Web Application experience; (iii) to display and provide relevant and personalized content and advertisements through various channels based on information collected about you; and
• Perform any functions as otherwise explicitly described to you at the time of your submission of your Personal Information.

Security of Information

Trustii uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, Trustii uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their standards of security, both electronic and physical.

All information, including Personal Information, is transferred with encryption using Secure Sockets Layer (“SSL”) or TransportLayer Security (“TLS”), the most common security standards for Internet data transfer and transactions. You can use your browser to check Trustii’s valid SSL security certificate.

Personal Data Collected About You from Third Parties and What We Use It For

Sometimes we get Personal Information about you from third parties. This table explains the details about this Personal Information – what it is, where it came from and what we do with it. The legal basis for us having and processing this Personal Information is your informed consent.

To the extent that analytics identifiers are generated from third parties, these may be considered Personal Information collected from third parties, and you can find details about that further below in this Policy. The personal data is stored in accordance with the provisions and requirements stipulated by the Act modernizing legislative provisions on the protection of personal information, also known as Law 25.

Non-Disclosure of Personal Information to Third Parties

Except as provided in the next paragraph and specified in the next three sections of this Policy, Trustii does not divulge any Personal Information gathered via the Services to third parties. Moreover, Trustii does not sell, rent, trade or license any Personal Information regarding Candidates or other Website visitors to third parties. Only the Representatives and subcontractors of Trustii are responsible for the management and development of the Services, and only these individuals have access to the information collected therein. These Representatives and subcontractors have all been instructed to comply with the Policy and are under contractual obligations of non-disclosure.

Notwithstanding anything in the Policy to the contrary, we may share any information we have collected about you or that you have submitted (whether Personal Information or not): (1) in response to subpoenas, court orders, or legal processes, or to establish, protect, or exercise our legal rights or defend against legal claims or demands; (2) 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 Terms of Use; (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Services infrastructure or the Services generally); (4) to a parent company, subsidiaries, joint ventures, or other companies under common control with Trustii (in which case we will require such entities to honour this Policy); (5) if Trustii merges with another entity, is subject to a corporate reorganization, or 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).

Transfer of Personal Information to Third Parties

We routinely share some of your Personal Information with certain third parties in order to facilitate the functioning of the Services. These third parties are identified in the table below, along with what they do with the Personal Information transferred to them.

Cross-Border Transfer of Personal Information

When you use the Services, your Personal Information may be transferred to and/or stored in another country where we or our service providers operate, including the United States. By using the Services, you agree to such cross-border transfer of your Personal Information and understand that your information may be available to government authorities under lawful orders and laws applicable in foreign jurisdictions. Trustii will protect Personal Information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections.

Email Communications and Compliance with Anti-Spam Laws

Trustii uses ActiveCampaign to manage our mailing list and to send out our newsletter and promotional emails and SendGrid to send out emails related to the Questionnaire to send out emails related to the Questionnaire (ActiveCampaign and SendGrid, collectively, the “Email Service Providers”). Personal Information is transferred to the Email Service Providers in order for the emails to be sent out properly. Your email address is only used to send out emails; the Email Service Providers do not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party. For more information, please refer to ActiveCampaign’s Privacy Policy and Twilio’s Privacy Policy, which applies to SendGrid.

You may unsubscribe from Trustii’s mailing list at any time, by following the link at the bottom of the Trustii emails. Other types of emails, such as emails related to the Questionnaire will not have an opt-out option as they are necessary for the operation of our business.

Trustii’s practices with regard to its email are designed to be compliant with anti-spam laws, specifically the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of these laws, please contact us using the contact information further up in this Policy.

Limited Gathering of Information for Statistical, Analytical and Security Purposes

Trustii automatically collects certain information using third-party analytics programs to help us understand how Website visitors interact with the Website, but none of this information can identify you personally. Specifically, we use the following analytics programs: Google Analytics, ActiveCampaign and HubSpot. As an example of how these third-party analytics programs are used, each time you visit the Website, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors in the aggregate. Trustii also makes use of information gathered for statistical purposes to keep track of the number of Website visitors and the specific pages visited on the Website with a view to introducing improvements to the Website.

Your IP address and other relevant information we collect using third-party analytics programs may be used in order to trace any fraudulent or criminal activity, or any activity in violation of the Terms of Use.

Aggregated Information

In addition to the information collected by the analytics programs as described in the previous section, we may also generate, use and disclose aggregated and / or anonymized information and statistics about Candidates and Website visitors for marketing and strategic purposes. However, no Candidates or Website visitors will be individually identifiable from these aggregated and / or anonymized information and statistics.

Tracking Technology (“Cookies”) and Related Technologies

Trustii uses tracking technology (“cookies” and related technology, such as tags, pixels and web beacons) on the Website and by visiting or using the Website you agree to their use. Cookies are small text files placed on your computer or device when you visit a website, in order to track use of the site and to improve the user experience by storing certain data on your computer.

Specifically, we use cookies for the following functions:

• to facilitate the proper functioning of the Website;
• to facilitate online advertising, as described more fully below in this Policy; and
  
• to assist in identifying possible fraudulent activities.

Your browser can be set to refuse cookies or delete them after they have been stored. Please refer to your browser’s help section for instructions. Please note that deleting these cookies may reduce your experience on the Website by requiring you to re-enter certain information. Furthermore, deleting cookies may prevent certain Website functions from working at all. Trustii and its Representatives shall not be held responsible for any function that may not operate after you delete cookies, or any losses or damages (pecuniary or otherwise) arising from those functions not operating or having reduced functionality.

Trustii Advertising and Opting Out

Trustii uses certain advertising networks to provide advertising to you. Specifically, we use Google Ads, Meta Pixel and LinkedIn Ads and by using the Website, you consent to their use. Specifically, Trustii uses the remarketing features of Google AdWords’ interest-based advertising, which displays Trustii advertisements that should be of particular interest to you based on your browsing and activity history interacting with the Website. These advertisements will appear on third-party websites around the web. Google uses specific cookies to allow them to serve these advertisements to you. Additionally, Trustii also uses Meta Ads, Meta Pixel and LinkedIn Ads to serve you advertisements for Trustii when you are on Facebook or LinkedIn. You may prevent this type of advertising by deleting the appropriate Google, Facebook or LinkedIn cookie through your browser, though this may not be permanent. For a more permanent solution, you may opt out of such Google, Facebook and LinkedIn advertising by adjusting your Google, Facebook or LinkedIn ad settings or by using the WebChoices online opt-out tool.

Verification, Correction and Deletion of Personal Information

You have the right to:(i) verify what Personal Information Trustii holds about you; (ii) ask for your Personal Information to be corrected or updated; and (iii) to withdraw your consent to the use by Trustii of your Personal Information and have it deleted from our records. If you wish to inquire about and verify and / or correct Personal Information Trustii holds about you, or if you wish to have all your Personal Information permanently deleted from our records, please contact us using the contact information further up in this Policy. Please note that deletion of your Personal Information may make it impossible for you to use the Services or portions thereof, or may result in a Requesting User choosing not to select you, and Trustii and its Representatives accept no responsibility for any damages, pecuniary or otherwise, resulting from such situation. If you request deletion of your Personal Information, Trustii reserves the right to retain some of your Personal Information for a reasonable time in order to satisfy our legal obligations or under a legal procedure of any sort.

Risks Associated with the Internet and Wireless Data Transmission

Despite Trustii’s best efforts to ensure that third parties will not access or obtain your Personal Information through your use of the Services, complete confidentiality and security cannot currently be guaranteed on the internet or where data is transferred via digital wireless technology of any type. Communication via the internet or wireless data transmission is subject to interception, loss, or alteration. You acknowledge and agree that Trustii and its Representatives cannot be held responsible for damages resulting from the transmission of confidential information or Personal Information in this manner and that such communications are at your own risk.

Compliance with Privacy Laws

This Policy and Trustii’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 using the contact information further up in this Policy.

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