INTRODUCTION
With the advent of new communication tools, it is necessary to pay particular attention to the protection of privacy. That is why we, Location LocketGo Inc. (hereinafter referred to as “LocketGo”), are seriously concerned about the privacy of your personal information and we are committed to respecting the confidentiality of the information we collect.
LocketGo undertakes to respect, in accordance with the applicable laws, the obligations regarding the collection and processing of personal and confidential information obtained in the course of the operation of a business so that everyone can benefit from the respect of their private life.
The hereby privacy policy (hereinafter the “Policy”) describes the information that LocketGo may collect in the course of its business from its users (hereinafter collectively referred to as the “User” or “Users”), who are defined as any of the following:
LocketGo’s business partners (hereinafter the “Administrator”);
The natural persons authorized by an Administrator to use
LocketGo’s lockers (hereinafter the “Beneficiary”);
The natural persons who use LocketGo’s services autonomously and for personal purposes (hereinafter the “Individuals”);
This Policy indicates the User’s rights regarding the collection, use and communication of its personal information. LocketGo agrees not to collect, use or disclose the User’s personal information otherwise than in accordance with this Policy and the applicable laws in the province of Quebec.
SCOPE OF THIS POLICY
LocketGo operates the websites https://hellolocketgo.com/ and https://locketgo.com/ as well as the LocketGo Mobile and Web applications (hereinafter the “Platform“).
When the User browses the Platform or subscribe to our publications by email, he agrees to the terms and conditions of this Policy. If the User continues to use the Platform after a new version of this Policy has been posted there, he consents to and will be bound by the changes.
The information we collect is necessary when we provide a temporary rental service to a User. By providing us with this information, the User consents to its collection and use as defined in this Policy.
COLLECTION OF PERSONAL INFORMATION
LocketGo may obtain personal information from the User when he saves it on the Platform or, as the case may be, when the Administrator otherwise transmits personal information about its Beneficiary.
The User provides personal information by creating an account, choosing a password, logging in, reserving a locker, conducting a product search, requesting service, providing account information, contacting us by telephone, e-mail or otherwise, or by completing a form to enter a contest, an inventory request, a promotion, a survey or a job application.
We collect the following Administrator information, upon his registration:
The name;The e-mail address;
The phone number;
The payment method information
The Administrator subsequently sends the following information to LocketGo:
The name of the Beneficiary;
The Beneficiary’s email address;The Beneficiary’s phone number.
Where applicable, we collect the following information from the Individual upon his registration:
The last name;
The first name;
The e-mail address;
The phone number;
The information relating to the method of payment;
The event he’s attending, if any.
Beyond the purposes for which it was collected, the User’s personal information may be retained for statistical purposes.
The deletion of personal information takes place when the Individual or the Administrator makes a written request to do so. LocketGo reserves the right to refuse an Administrator’s request in the event that the Beneficiary continues to use, in any way, LocketGo’s services.
LocketGo respects the retention period established by the present policy, which is in compliance with the Privacy Act. Therefore, the deletion of the data will be effective thirty (30) days after the receipt of the request for deletion of the personal information.
The Platform is designed for use by adults only, as understood in the Province of Quebec. LocketGo does not knowingly collect any personal information from anyone under the age of eighteen (18).
For more information on the protection of your personal information and your related rights, you may contact the Office of the Privacy Commissioner of Canada or the Commission for the Protection of Privacy of Quebec.
Office of the Privacy Commissioner of Canada www.privcom.gc.ca
Commission for the Protection of Privacy of Quebec www.cai.gouv.qc.ca
FORMS AND INTERACTIONS
The User’s personal information may be collected through forms, namely:
The registration form for the Platform;
The contact form.
User information is also collected through the interaction that may take place between the User and the Platform and may be used for the following purposes:
allow LocketGo to provide its services;
allow the Administrator to monitor the use of the Service by the Users;
analyze the User’s usage trends and preferences;
improve LocketGo’s website and our services;
detect, prevent and address security issues;
respond to questions and requests for information;
for marketing, advertising or contest purposes;
share or sell Users’ data to partners;
any other purpose permitted or required by law.
ADVERTISING INFORMATION
LocketGo will contact the User only if the User wishes so. If the User is not subscribed to our newsletter, he will not receive any email from LocketGo, except in special cases (e.g.: follow-up, subscription expiration, participation in a contest, etc.).
If the User prefers not to receive any advertising information from us or if he does not want us to use his personal information to enhance his User experience, he must let us know by contacting the “Contact Person” indicated in the “RIGHT OF OPPOSITION AND WITHDRAWAL” section below.
The User will, however, continue to receive communications from LocketGo during the processing of his request.
THIRD-PARTY SERVICES
LocketGo may use third-party services for the management of its business and its Platform. In no event shall LocketGo be liable for any prejudice that may arise from such third-party services. LocketGo invites the User to consult these services’ respective website, in order to learn about their conditions of use.
LocketGo prohibits and is not responsible for the resale or use by third parties of the “opt in” obtained through the Platform by event organizers. If the User agrees to share his contact details with partner organisations, then we will share them with them. We do not sell or rent our lists.
AUTOMATICALLY EXCHANGED DATA
We collect certain information during exchanges between the User’s computer and our server. Cookies, created by a website and automatically stored on the User’s electronic devices, allow the User to log in to the Platform during subsequent uses and allow LocketGo to customize the Platform.
This information consists mainly of the following:
Domain name;
IP address;
Navigation history;
The type and version of the User’s browser; and
The User’s language.
Most of the automatically exchanged data do not allow to identify the User. They are collected only because of the technological requirements inherent in browsing the Internet. Most browsers automatically accept cookies, but it is usually possible to modify this setting. However, if the User chooses to refuse cookies, he may not be able to identify himself or use certain features of our Platform.
The use of such information allows us to improve the service, to personalize the User’s experience and to make a better follow-up of our services.
This information is also used for:
Process rental applications and answer questions;
Stay in contact with the User and provide him with a personalized service at all time;
Learn more about the User’s purchasing preferences; and
Conduct market and performance research to assess the customer service, measure the performance, enhance the experience provided to the User and generally improve the service provided to him.
These cookies are multiple, some expire when the User closes his browser and have no effect while others can be maintained. The User may disable cookies at any time. In this eventuality, LocketGo does not guarantee an optimal functioning of the Platform.
INTERNATIONAL COMMUNICATIONS
It is possible that in certain situations, the User’s information is transferred to servers outside of Canada. The User accepts and acknowledges that LocketGo is not liable for the consequences of such transfer.
SHARING PERSONAL INFORMATION
LocketGo undertakes not to sell the collected personal data without the User’s explicit consent. Personal data can exclusively be sold in the context of a partial or total disposal of LocketGo’s business to a third party. In such situation, the disposed data is subject to the same warranties that those contained in this Policy.
Unless otherwise stated in this Policy, the personal information the User provides will not be transmitted to third parties without his permission. However, we sometimes share this information with partners.
If the User does not wish to have his personal information communicated to third parties or partners, he may opt out at any time, as mentioned in the following section, “RIGHT OF OPPOSITION AND WITHDRAWAL”.
LocketGo may, in the following cases, exceptionally communicate the User’s personal information without his consent:
In case of legal obligation, notably when a Court order obliges LocketGo to communicate the User’s personal information.
When it is impossible to obtain the User’s consent and privacy laws allow LocketGo to disclose such personal information. This is particularly the case when the protection of the public interest requires it.
RIGHTS OF OPPOSITION AND WITHDRAWAL
We are committed to offering the User the right to oppose and withdraw his personal information.
The right of opposition is understood as the possibility offered to the Users to refuse to allow their personal information to be used for certain purposes mentioned during the collection.
The right of withdrawal is also understood as the possibility offered to the Users to request that their personal information no longer appears, for example, in a mailing list.
The User also has the right to request access to the personal information we have collected about him and to correct any information as needed by contacting the contact person whose information is listed in the section “Contact person” below.
ANTI-SPAM LEGISLATION
LocketGo complies with the dispositions of the Canadian Anti-Spam legislation (CASL). The User understands that he may expressly or tacitly consent to receive messages from LocketGo.
Express consent is the consent requested from the User or, where applicable, the Administrator, which must be stated in simple and clear terms and must include the purposes for which consent is sought, the regulatory information identifying the person seeking consent and, if it is sought on behalf of another person, regulatory information identifying that person; as well as any other information specified by the regulations made under this Act.
The User understands that he gives his tacit consent during ongoing business or private relationships; when the User publishes his e-mail address without mentioning that he does not wish to receive unsolicited commercial e-mail messages; or when the message is sent in the other circumstances provided for by the regulations under this law.
(a) For the purposes of this Policy, “current business relationship” refers to a business relationship between two persons such as a purchase or lease within two years prior to the date of sending the message; an investment or game being offered; the barter of a thing; any contract in effect or expiring during that period; or a request within six months prior to the date of sending the message.
(b) For the purposes of this Policy, an ongoing private relationship is defined as a relationship between two persons other than a business relationship, such as a gift or donation, volunteer work; and membership, as defined in the regulations; all during the the two years preceding the date of sending the message.
To withdraw your consent or to stop receiving electronic information or communication, please contact the “Contact Person” described below.
SECURITY
The personal information that LocketGo collects is kept in a secure environment. LocketGo has taken appropriate measures to maintain the confidentiality of personal information and protect it against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, taking into account, in particular, its sensitivity and the purposes it is used. In addition, LocketGo requires that each employee, mandatory or representative of LocketGo complies with this Policy.
In order to ensure the security of the User’s personal information, the Corporation uses, among others, the following measures:
SSL (Secure Sockets Layers) protocol;
Access management – authorized person;
Access management – person concerned;
Backup of data automatically generated by the AWS; – Network monitoring software;
Confidential logins/passwords;
Encryption of sensitive data;
Payment fraud detection system;
Confidentiality agreements with employees and;
Routine security measures updates.
LocketGo is committed to maintaining a high degree of security by incorporating the latest technological innovations to ensure the confidentiality of the User’s transactions in order to protect the User’s personal information and prevent it from being viewed, used or disclosed without authorization.
However, since no mechanism offers maximum security, there is always a degree of risk involved in using the Internet to transmit personal information. If a password is used to protect the User’s account and personal information, it is the responsibility of the User or, if applicable, the Administrator to ensure that it remains confidential.
ENGLISH AND FRENCH LANGUAGE
In the event of a conflict of definition or interpretation between the French and English versions of this Privacy Policy, the French version shall prevail.
APPLICABLE LAWS AND JURISDICTION
The Platform and its content are managed by LocketGo from their offices located in the province of Quebec, Canada. The Platform, its content, the present Policy and your use of the Platform are regulated by the applicable legislation in the province of Quebec, without giving effect to any principle regarding conflicts of laws.
The User accepts that any question or litigation regarding the Platform and his use of it will first be brought before a mediator and, in the absence of a compromise, settled by the courts of the province of Quebec.
If the User is a consumer under the Quebec Consumer Protection Act, then any litigation will be ruled by the law of the Province of Quebec and the competent jurisdiction will be determined according to the rules of Quebec Code of Civil Procedure.
INTERPRETATION
This Policy is governed by applicable Quebec and Canadian laws, including the Privacy Act of Canada. These laws apply without giving effect to any conflict of law.
Whenever the context so requires, any word written in the singular also includes the plural and vice versa; any word written in the masculine gender also includes the feminine gender and vice versa.
DIVISIBILITY
Each provision of this Policy is a separate and distinct whole so that a court decision that any provision of this Policy is invalid or unenforceable will not affect the validity or enforceability of the remaining provisions of this Policy.
CONTACT PERSON
You may exercise your rights provided in this Policy or you may address any other question or complaint regarding the LocketGo’s privacy practices by contacting us:
Name: GABRIELLE LA RUE
E-mail: gabrielle@locketgo.com
AMENDMENT OF THIS POLICY
LocketGo reserves the right to modify, change or update this Privacy Policy continued use of this Platform constitutes the User’s agreement to this Policy and to its updates.
If the User does not accept this Privacy Policy or, as the case may be, the Privacy Policy as amended, he must not, or must no longer, use the Platform.
However, when the Consumer Protection Act applies, LocketGo undertakes to notify, thirty (30) days prior to the coming into force of the modification herein, the Users of the Platform. If the User refuses these modifications and wishes to terminate the Agreement, the User will have at the latest thirty (30) days following the coming into force of the modifications to send a notice to LocketGo and to resolve, without charge or penalty, its obligations towards LocketGo.
LocketGo will attempt, to the extent possible, to inform Users of any changes to this Policy. However, it is the User’s responsibility to review them on a regular basis in order to be informed of any changes.
(Last update: Wednesday September 9th, 2020)
