A) Introduction to Rhenti.
1. Rhenti Ltd. (“Rhenti”,“us”, “our” and “we”) provides an online platform that connectsproperty owners with those seeking to rent residential and/or commercial properties,and provides ancillary services, products and content for both property ownersand renters (collectively, the “Services”).
2. The Services are accessiblethrough our website (www.Rhenti.com), and other websites which Rhentimay make the Services available through from time to time (collectively, the “Site”),as well as various applications for mobile, tablet and other ‘smart’ devices,and other application program interfaces (collectively, the “Application”).
3. We value the privacy of thosewho visit our Site and Application, and of those who use the Services(individually, “you”, or collectively, “Users”). We make it apriority to protect personal information that we obtain from and about ourUsers and any use of the Services by you shall be subject to the terms of thisprivacy policy (the “Privacy Policy”).
4. By visiting our Site and Application,and/or accessing the Services, you expressly agree and consent to theinformation handling practices described in this Privacy Policy. If you objectto the use of your Personal Information in the manner set forth in this PrivacyPolicy, please immediately leave the Site and/or Application, and cease all useof the Services.
5. “Personal Information”means information that is provided to us by you, or collected by us inconnection with your use of the Services, that identifies or can be used toidentify, contact, or locate you, including, without limitation, a naturalperson’s name, date of birth, photographic identification, address, telephonenumber, fax number, email address, government issued identifier,citizenship/residency status, education status, employment history/information,personal and/or professional references, details or property ownership,property information, internet protocol address, payment information, credithistory/reports, criminal background information, usernames and social mediaaccounts. Our collection and use of Personal Information is subject to theterms of this Privacy Policy.
6. This Privacy Policy isincorporated into, and subject to our Terms of Service, which can befound on our Site.
B) What Information does Rhenti collect?
1. Personal Information that youprovide.
From timeto time, we may ask you to provide Personal Information. If you choose toprovide such information you are granting us permission to use and store suchinformation as provided in this Privacy Policy. In order to use theServices, you must first complete the registration form, and choose a password.To complete your profile, you must provide your name, phone number, current addressand email address. We use this information to create your account and tocontact you in regards to the Services.
a. Property Owners.
If you are the owner of a residential orcommercial property (a “Property Owner”) and wish to rent your propertyand/or unit through Rhenti, you must provide your name, photographicidentification, phone number, current address, email address, proof ofproperty/unit ownership, date of birth, personal references, listing detailsand photographs, and payment information (such as Credit Card and/or Debit Cardpayment information). We use this information to confirm your identity,validate the ownership of your properties and to process fees for your use ofour Services, as needed. Rhenti does not collect or store any Credit Cardand/or Debit Card payment information or related data on any of its web serversand relies on third-party suppliers, to provide certainpayment processing services on our behalf.
b. Renters.
If you are seeking to rent a residential and/orcommercial property from a Property Owner through our Services (a “Renter”),you must create a Renter profile (a “Renter Profile”). To create aRenter Profile you will be asked to provide your name, the name(s) of anyco-applicants, phone number, current address, email address, employment history/information,proof of citizenship/residency status, personal and/or professional references(including, but not limited to previous tenancies), credit history/reports, socialmedia accounts, and such other Personal Information as may be requested by usor by a Property Owner in respect of the Services from time to time. Renterswill be asked to consent to a credit check in order to complete their RenterProfile. We use this information to confirm your identity and to assist PropertyOwners with making an assessment regarding your fit as a potential Renter oftheir properties (a “Renter Score”). Rhenti may from time to timedisclose certain Personal Information of Renters to Property Owners in respectof the Services, including but not limited to, your Renter Profile and RenterScore.
2. Information collected viacookies.
We use aseries of cookies to verify/authenticate your account, protect your PersonalInformation, and for ease of use purposes while accessing the Services. Forexample, when you use our Site and/or Application from any device (mobile, tablet, laptop or desktop) we may use cookies tocollect data from the device and application you used to access our Servicesand to track information about your browser’s activities, including but notlimited to,which of our pages you visit, what you click on, or when you performed thoseactions.Ifyou arrive at our Site from an external source (such as a link on anotherwebsite or in an email), we record information about the source that referredyou to us. Thesecollection and tracking methods allows us to provide you with better servicesand features while you access our Services. We do not link theinformation that we store in cookies to any Personal Information that yousubmit to us.
Our web servers keep logfiles that record data each time your device accesses those servers. The logfiles contain data about the nature of each access, including the originatinginternet protocol (“IP”) addresses. We may also infer your geographiclocation based on your IP address. The types of cookies that we may use tocollect data and track information are known as “session cookies” and“persistent cookies”.
a. Session cookies.
Session cookies make it easier for you tonavigate our Site and/or Application and store information onlyfor the length of time that you are connected to a website – they are notwritten onto your hard drive. Once you leave the website or close your browser,they expire and are no longer active. We use session cookies to record certaininformation from your browser including your IP address, browser type, internetservice provider (“ISP”), referring or exit pages, operating system andthe dates and times that you use our Site and/or Application.Additionally, we may record certain information regarding your use of featureson our Site and/orApplication.Session cookies allow us to gather statistical data which provides insight intohow we may improve our Services and to identify your current session to our webserver.
b. Persistent cookies.
Persistent cookies storeinformation on your hard drive and can be re-read when you return to the websitethat placed them on your hard drive. We set a persistent cookie to store yourpasswords, so you don’t have to enter it more than once. Persistent cookiesalso enable us to track and target the interests of our Users to enhance theexperience on our Site and/or Application. We use persistentcookies to record your preferences for informative purposes, provide you withalerts and notifications that may be of interest to you, allow you to rejoin sessionsthat you have left but return to at a later time, and help block unauthorizedattempts to access your Personal Information. You can remove persistentcookies by following directions provided in your web browser’s “help” file.
The persistent cookies we use includewithout limitation the following:
i. _ga (Google Analytics ID)
ii. _gat (Google Analytics Code)
iii. _gaid (Google Analytics ID)
iv. _fbp (Facebook Integration IDfor campaigns)
c. Accepting/Rejecting cookies.
If you have consented to cookies, butwish to withdraw your consent, you may do so at any point through our cookiecontrols on our Site and/or Application. Note that if you donot accept cookies, you may still use our Site and/or Application but you maynot have access to certain services and features on our Site and/or Application that relyon cookies for their functionality. For more information on cookies, pleasesee: http://www.allaboutcookies.org/faqs/cookie-file.html.
d. Location Information.
We may from time to time collect andstore information about your location if your respective computer or mobiledevice is enabled to send us location information. You may be able to changethe settings on your respective computer or mobile device to prevent it fromproviding us with such information.
e. Third-Party Web Beacons.
We may also implement third-partycontent on our Site and/or Application, from time to time that use “clear gifs”,“web beacons”, “pixel tags” andJavaScript or other similartechniques, which allow third-party content providers to read and write cookiesto your browser, or implement similar tracking mechanisms, in connection withyour viewing of that third-party content displayed on our Site. Thisinformation is collected directly by the third-party, and we do not participatein that data transmission. Information collected by third parties in thismanner is subject to that third-party's own data collection, use, anddisclosure policies.
Through our partners, we may use web beacons inour HTML-based emails to let us know which emails recipients have opened. Thisallows us to gauge the effectiveness of certain communications and theeffectiveness of our marketing campaigns. For more information on web beacons,please see: http://www.allaboutcookies.org/faqs/beacons.html.
f. Your Relationship With Us.
We will collect information arisingfrom your relationship with and through us, and our Users’ use of the Services.For example, we may maintain a record of your transaction and payment historyand when you send us an email, speak with one of our telephone servicerepresentatives, or communicate with us through any other means, we maymonitor, record and retain those communications for our mutual protection andin order to process your inquiries, respond to your requests and improve ourServices.
g. Personal Information from Other Sources.
We may also obtain Personal Informationfrom third-parties and sources other than the Services, such as “Facebook”, “Twitter”,“Instagram” and “LinkedIn”. If we combine or associate information from othersources with Personal Information that we collect through our Services, we willtreat the combined information as Personal Information in accordance with thisPrivacy Policy.
C) How does Rhenti use PersonalInformation?
1. To Serve You.
We use thePersonal Information that you provide or that we collect for legal and regulatorypurposes, to manage business risks, to provide our Services to you and toestablish and enhance our relationship with you. We generally use the PersonalInformation you provide or that we collect to operate, maintain, enhance, andprovide our Services. For example, we may use your Personal Information to:
a. provide you with customer service, and torespond to specific requests from you. We also use your Personal Informationfor general communications and to communicate with our external partners tocharge for services and other billing purposes;
b. contact you about your service or account. Weoccasionally send you communications of a transactional nature (e.g.service-related announcements, billing-related matters, changes to our servicesor policies, welcome emails when you first register, etc.). You cannot opt-outof these communications, since they are necessary in order for us toeffectively provide our services to you.
c. validate your identity, validate your RenterProfile, conduct reference checks, and/or validate your ownership of any listedproperties. We also use your Personal Information to comply with “Know Your Customer” (“KYC”) obligationsset forth by our third-party payment processors;
d. monitor and improve our services and features.We internally perform statistical and other analysis on information we collect(including usage data, device data, referral data, and information from pagetags) to analyze and measure user behavior and trends, to understand how peopleuse our services, and to monitor, troubleshoot and improve our Services;
e. respond to legal requests and prevent harm. Ifwe receive a subpoena or other legal request, we may need to inspect the datawe hold to determine how to respond. We also use your Personal Information toassist us with the enforcement of our Terms of Service, and to preventpotentially illegal or illicit activities from occurring on our Site and/or Application.We screen for undesirable or abusive activity with respect to your use of theServices;
f. create new services, features or content. Wemay use any information you provide us (e.g. via email or through our ticketingsystem) to create and provide new services, features or content. For example,we may publish interesting observations from the surveys for informational ormarketing purposes. When we do this, you will not be personally identifiableunless we first obtain your prior consent.
g. disclose Renter Profile, Renter Score and otherassessment data, including but not limited to, credit history/reports and otherrelevant Personal Information from Renters to Property Owners who have receiveda lease offer or other tenancy application from a Renter. We also use yourPersonal Information to assist us with pre-populating lease agreements.
h. offer you utility services while you are atenant.
2. Aggregate Information.
We may generatenon-identifying and aggregate profiles from the information you provide duringregistration for our Services and through your use of our Services. Non-identifyingand aggregate profiles are used to improve the quality of our Services and todevelop new Services. Aggregated non-personally identifying information may beshared with third parties.
3. Marketing and Experience.
If you have opted-in to suchcommunications on our registration page, we may from time to time use yourPersonal Information to contact and provide you with information about ourfeatures, services and other offerings that may be of interest to you andfacilitate your participation in surveys or contests and to fulfill prizes. If you no longer wish toreceive this type of communication, you can opt-out through the link in theemail communication.
If you haveelectedto participate, we may request further Personal Information from you for suchpurposes. Participation in these surveys or contests is completely voluntary,and you therefore have a choice whether or not to disclose such furtherPersonal Information. We use this further disclosed Personal Information tonotify contest winners and award prizes, and to process and analyze surveyresults. Wemay also share your Personal Information with certain other websites that welink to, to the extent that you click on such links, in order to enhance yourexperience in connection with our Site and/or Application.
D) What communications can I expect from Rhenti?
1. Special Offers and Updates.
We will occasionally send youinformation on products, services, special deals, and promotions (if you opt-inon our registration page). If you no longer wish to receive this type ofcommunication, you can opt-out through the link in the email communication.
2. Service-Related Announcements.
We will send you strictlyservice-related announcements on rare occasions when it is necessary to do so.For instance, if our Site and/or Application is undergoing temporarymaintenance, we might send you an email. Generally, you may not opt-out ofthese communications, which are not promotional in nature. If you do not wishto receive them, you have the option to deactivate your account.
3. Customer Service.
Based upon the PersonalInformation you provide us, we will send you a welcoming email to verify yourusername and password, as well as a number of on-boarding emails intended tofamiliarize you with the Site and/or Application. We will also communicate withyou in response to your inquiries, to provide the services you request, and tomanage your account. We will communicate with you through our ticketing system,via email, and by telephone.
4. Supplemental Information.
In order to provide certainservices to you, we may supplement the Personal Information you submit to uswith information from third party sources, including in respect of creditworthiness and verification of any information provided.
E) To whom does Rhenti share my PersonalInformation with?
1. Our subsidiaries or affiliates.
We mayshare your Personal Information with our subsidiaries or affiliates (the “Group”) for: fraud or crime prevention,suppression or detection; for legal and regulatory purposes and to meetregulatory, legal or reporting requirements; to manage business risks; toperform analytics; to ensure that we have correct and up to date informationabout you; and to the extent necessary if you have requested a Service that isjointly offered by more than one member of the Group. We may also share yourPersonal Information to better manage your total relationship with the Groupand enable other members of the Group to bring suitable Services to yourattention. We may share your Personal Information within the Group for thesepurposes unless prohibited by law or you tell us not to.
2. Suppliers.
We may use other suppliersand information technology service partners (the “IT Partners”), including but not limited to, third-party websites, “MicrosoftAzure”, “TransUnion”, “Adobe Sign” and “Stripe”, to provide certain services onour behalf. We may also share both aggregate (non-identifiable) information aboutyou and yourPersonal Information, with our IT Partners, suppliers, agents and otherorganizations that perform services for us or on our behalf to the extentnecessary to provide and administer the Services that you have requested fromus. Your Personal Information may be subject to the privacy statements of theseother companies or services partners, and as a result, we strongly encourageyou to be aware of and to read the privacy statements of such third-parties.
Our suppliers mayperform activities outside of your jurisdiction. As a result, your PersonalInformation may be securely used, stored or accessed in other countries and maybe subject to the laws of those jurisdictions. These companies may be requiredto disclose your Personal Information in response to valid demands or requestsfrom governments, regulators, courts and law enforcement authorities in thosejurisdictions or countries.
3. Merger or Sale.
In theevent that we are acquired by or merged with a third-party entity, or if wesell a part of our business, we reserve the right to transfer or assign thePersonal Information that we have collected from you as part of such merger,sale or other change of control and you hereby consent to the transfer orassignment of such Personal Information. You will be notified viaprominent notice on our Site and/or Application for 30 days following the dateof any such change in ownership or control of your Personal Information.
4. Where required by law.
We maydisclose your Personal Information if we have a good faith belief that access,use, preservation or disclosure of such Personal Information is reasonablynecessary to satisfy any applicable law, regulation, self-regulation, legalprocess or enforceable governmental request. When we provide PersonalInformation in response to a legal inquiry or order that we believe to bevalid, we disclose only the Personal Information that is legally required. Notethat for this purpose that we may store or process your Personal Informationoutside of your jurisdiction, which physical storage of your PersonalInformation may span multiple jurisdictions or countries and we may discloseyour Personal Information in response to valid demands or requests fromgovernments, regulators, courts or law enforcement authorities in thosejurisdictions or countries.
5. Protection of our interests.
We may alsodisclose your Personal Information if we believe, in good faith, that it is appropriateor necessary to take precautions against liability; to help us collect a debtor enforce an obligation owed to us by you; to protect against fraudulent,abusive, or unlawful uses; to investigate and defend ourselves against anythird-party claims or allegations; to assist government enforcement agencies;to protect the security or integrity of our Services; or to protect the rights,property, or personal safety of our Users, employees or others.
6. Consent.
We maydisclose your Personal Information where you have authorized us to do so. Forexample, if you have given us consent, we may share your Personal Informationwith business partners and other entities that are not affiliated with us whowould like to send you information about their products and services. We do notshare Personal Information with other third-party organizations for theirmarketing or promotional use without your consent or except as part of aspecific program or feature for which you will have the ability to opt-in. We do however share aggregate(non-identifiable) information about our Users with other third-partyorganizations for our own marketing and promotional purposes. If you no longerwish to receive our promotional communications, you may unsubscribe byfollowing the instructions included in each communication or by emailing us at contact@Rhenti.com.
If youregistered, requested or otherwise consented to receiving certain Services fromus, and delivering such Service to you requires disclosing your PersonalInformation to other Renters, Property Owners or other entities that are notaffiliated with us, we will disclose such Personal Information to these partiesin the course of providing you the Service you requested.
F) How does Rhenti protect PersonalInformation?
1. Security Processes.
We are committed tomaintaining the security of your information and havemeasures in place to safeguard your Personal Information from loss or theft,unauthorized access, disclosure, duplication, use or modification throughsecurity measures appropriate to the sensitivity of the information. Thesemeasures include internal reviews of our data collection, transit protocols, storageand processing practices and security measures which include appropriateencryption, password protection and physical security measures to authenticateand guard against unauthorized access to databases and systems where we storePersonal Information.
All Personal Information thatis collected by Rhenti, including any records pertaining to a leasingtransaction entered into in respect of the Services, is electronically storedon our databases and application services located in Toronto, Ontario, Canada,which are part of the Rhenti isolated “Microsoft Azure” virtual network. Ourdata center utilizes state-of-the-art physical security measures to preventunauthorized access to the facility. In addition, all information is stored ina secure location behind firewalls and other sophisticated security systemswith limited (need-to-know) administrative access. However, please be awarethat no security measures are perfect or impenetrable.
2. Confidentiality Obligations.
We restrictaccess to your Personal Information to certain employees who need to know thatinformation in order to process it on our behalf, or to provide our Services toyou. These employees include members of our “Leadership Team”, “Client SuccessTeam”, “Sales Team” and “Developer Team”. Our employees are bound byconfidentiality obligations and may not use the information for anyunauthorized purpose. Our employees may be subject to discipline, includingtermination and criminal prosecution, if they fail to meet their obligationsdescribed in this Privacy Policy.
G) How do I update, access or delete myPersonal Information?
1. Updating, Accessing andDeleting your Personal Information.
We makegood faith efforts to provide you with access to your Personal Information andto update, correct inaccuracies and delete such data at your request if it isnot otherwise required to be retained by law or for legitimate businesspurposes. Youmay request: access to, the updating of, corrections of inaccuracies, ordeletion of the Personal Information we have in our custody or control byemailing us at contact@Rhenti.com. We may requestcertain Personal Information from you for the purposes of verifying your identitywhen requesting access to your Personal Information records. If your PersonalInformation changes, or if you no longer desire our Service, you may correct it,update it, delete it or deactivate your account by emailing us at contact@Rhenti.com.
We maydecline to process requests that are unreasonably repetitive or systematic,require disproportionate technical effort, jeopardize the privacy of others, orwould be extremely impractical (for instance, requests concerning informationresiding on backup tapes), or for which access is not otherwise required. Inany case where we provide information access and correction, we perform thisservice free of charge, except if doing so would require a disproportionateeffort. We will advise you of any applicable fee prior to proceeding with yourrequest. Upon your request, we will make reasonable efforts to delete yourPersonal Information from our database, however, it may be impossible to deleteyour information without retaining some residual information for a period of timedue to backups and records of deletion.
2. Retention of your PersonalInformation.
We retainyour Personal Information only as long as it is required for the reason(s) thatit was collected. This length of time will vary depending on the Service andthe nature of the information and may extend beyond the end of yourrelationship with us. Moreover, we will retain your Personal Information asnecessary to comply with our legal obligations, resolve disputes, and enforceour agreements. When your information is no longer needed for the purpose forwhich it was collected, we will destroy, delete, erase or convert it to ananonymous form.
H) Can I withdraw my consent to providing Rhentiwith my Personal Information?
1. Providing or Withdrawing yourConsent.
Expressconsent may be obtained verbally, electronically or in writing from you or yourauthorized representative (such as a legal guardian or attorney appointedpursuant to a power of attorney) for stated purpose(s). Implied consent may beobtained through your use or continued use of a Services when the purpose(s)for collecting, using or disclosing your Personal Information is indicated bythe relevant circumstances or follows logically from purposes identified inthis Privacy Policy (such as when you approach us to obtain information orinquire about or request Services from us). We will seek your consent beforeusing your Personal Information for any purpose not previously identified inthis Privacy Policy or otherwise, and will limit the collection of yourPersonal Information to that which is reasonably necessary for the relevant purpose(s).We will not, as a condition of the supply of any of the Services, require youto consent to the collection, use or disclosure of Personal Information beyondthat which is reasonably required to fulfill the purpose for which it iscollected.
In mostcases you may refuse to provide your consent to our collection, use and/ordisclosure of your Personal Information in accordance with this Privacy Policy.Note, however, that if you refuse to provide your consent or withdraw yourconsent, we may not be able to provide you with a particular Service. You maywithdraw your consent provided that: you provide reasonable notice; we are notlegally required to collect, use or disclose your Personal Information; andwithdrawing your consent does not impede our ability to fulfill our obligationsto you. You may withdraw your consent by contacting us at contact@Rhenti.com. Our staff will be pleased to explainyour options and any consequences of refusing or withdrawing your consent, andrecord your choices.
I) What if I am not located in Canada?
1. International Jurisdictions(Outside of Canada).
Please notethat we may store or process your Personal Information outside of your own jurisdiction.The physical storage of your Personal Information may also span multiplejurisdictions or countries and the governments, regulators, courts or lawenforcement authorities in those jurisdictions or countries may be able toobtain disclosure of your information through applicable laws. Your use of theServices or your submission of any Personal Information to us will constituteyour consent to the transfer of your Personal Information outside of yourjurisdiction, which may provide for different data protection rules than thosein your own jurisdiction.
2. European Economic Area.
If you arelocated in the European Economic Area, you have certain rights under the General Data Protection Regulation 2016/679with respect to your personal data, including the right to request access to,correct, amend, delete, port to another service provider, or object to certainuses of your personal data.
a. Right of Access. You have the right toobtain from us confirmation as to whether or not personal data concerning you isprocessed, and, where that is the case, you have the right to request and getaccess to that personal data.
b. Right to Rectification. You havethe right to obtain from us the rectification of inaccurate personal data andyou have the right to provide additional personal data to complete anyincomplete personal data.
c. Right to Erasure (“Right to be Forgotten”). In certaincases, you have the right to obtain from us the erasure of your personal data.
d. Right to Restriction of Processing. You havethe right to obtain from us restriction of processing, applicable for a certainperiod and/or for certain situations.
e. Right to Data Portability. You havethe right to receive from us in a structured format, your personal data and youhave the right to transmit such personal data to another controller.
f. Right to Object. In certain cases, youhave the right to object to processing of your personal data, including withregards to profiling. You have the right to object at further processing ofyour personal data in so far as such data have been collected for directmarketing purposes.
g. Right to Not be Subject to Automated IndividualDecision Making. You have the right to not be subject to a decision basedsolely on automated processing.
h. Right to Filing Complaints. You havethe right to file complaints with the applicable data protection authority onour processing of your personal data.
i. Right to Compensation of Damages. In case webreach applicable legislation on processing of your personal data, you have theright to claim damages from us for any damages such breach may cause with you.
J) What if Rhenti changes this Privacy Policy?
We reserve the right to change this PrivacyPolicy at any time at our sole discretion, so please review it frequently. Ifwe decide to change our Privacy Policy, we will inform you of any such changeby posting a new Privacy Policy on our Site and/or Application and clearlymarking the effective date of any such change to the Privacy Policy. We encourage you to checkthis page periodically for any changes. Your continued use ofthe Services after the posting of changes constitutes your binding acceptanceof such changes.
k) Does this Privacy Policy apply to otherwebsites, applications or services?
OurSite and/or Application may be linked to internet websites and applicationsoperated by other third-party companies. You should consult the respectiveprivacy policies of these third-party websites. Our Privacy Policy does notapply to, and we cannot control the activities of, such other third-party websites. Please be aware that we do not warn you when you choose to follow a linkthrough to another website or application from our Site and/or Application.
l) Our commitment to Children’s Privacy.
Protectingthe privacy of young children is especially important to us. We do notknowingly collect any Personal Information of minors. If you are an individual,by accessing or using the Services you represent and warrant that you are oflegal age to form a binding contract. If we learn that Personal Information ofa minor has been inadvertently collected without parental or guardian consent,we will take the appropriate steps to delete this information. If you are aparent or guardian and discover that a minor for which you are responsible hasprovided his or her Personal Information to us without your consent, then youmay alert us by contacting us at contact@Rhenti.com andrequest that we delete such minor person’s Personal Information from oursystems.
m)How do I contact Rhenti?
Weregularly review our compliance with this Privacy Policy. When we receiveformal written complaints, it is our policy to contact the complaining Userregarding their concerns. We will cooperate with the appropriate regulatoryauthorities, including local data protection authorities, to resolve anycomplaints regarding the transfer of personal data that cannot be resolvedbetween us and you.
If you have any questions about this PrivacyPolicy, please feel free to contact us through the Services, or write to us at:
RhentiLtd.
18 King Street East, Suite 1400
Toronto, Ontario
M5C 1C4
contact@Rhenti.com