Privacy Policy

Value and Respect

Doing the right thing and being committed to the success of others. Showing others by our words and actions that we genuinely care about them personally and professionally.

Acting with integrity and leading by example. Always doing what we say we are going to do. Being trusting and respectful of others.

Comfort Owl Privacy Policy

Comfort Owl Rentals Corp. and its affiliates (“Comfort Owl” or “we”) values and respects the privacy of its users (“user” or “you”). User refers to anyone who visits our website www.comfortowl.ca/privacy/ (the “Website”), our customers, and anyone who engages with our social media, products or services (our “Services”).

For the purposes of this Privacy Policy, “personal information” means information that can identify an individual directly or is information about an identifiable individual. This does not include information that is used solely for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession.

Sections

Our privacy policy is broken down into 14 sections, as outlined below.

 

1. AGREEING TO THE TERMS OF OUR PRIVACY POLICY

2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED

3. HOW WE COLLECT YOUR INFORMATION

4. SHARING OF PERSONAL INFORMATION

5. TRANSFERS OF PERSONAL INFORMATION OUTSIDE OF CANADA

6. WEBSITE INFORMATION AND COOKIES

7. SAFEGUARDS AND RETENTION

8. YOUR CHOICES

9. ACCESS TO PERSONAL INFORMATION

10. THIRD PARTY LINKS

11. CHANGES TO THE PRIVACY POLICY

12. RISKS

13. GOVERNING LAW

14. CONTACT US – QUESTIONS OR COMPLAINTS

By providing personal information to Comfort Owl using our Website and/or engaging with our Services you are either expressly or impliedly consenting to our use, collection and disclosure of your personal information in accordance with the terms of this Policy. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Comfort Owl’s collection, use, and disclosure of personal information in accordance with this Policy.

 

1. AGREEING TO THE TERMS OF OUR PRIVACY POLICY

 

You have the right to ‘opt-out’ and withdraw your consent from us collecting and using your personal information in some or all instances, but this may limit our ability to provide you with our services or products, if applicable.  See Sections 8 and 9 below for details around how to withdraw your consent to our further use and communication of your personal information (subject to legal or contractual restrictions and reasonable notice).

 

2. PERSONAL INFORMATION COLLECTED AND HOW IT IS USED

 

The type of personal information we collect is largely driving by the type of services and products we are offering to you.  

Credit Offerings.  We may collect your name, date of birth (for identification and protection against error, theft, and fraud), home address, email address, telephone number, banking information, social insurance number (for identification, credit reporting, and monitoring purposes), credit history and financial information from consumer and credit reporting agencies, credit card details, employment history, income, real property ownership, driver’s license number, and any other information required to comply with applicable laws and regulations. 

We will use the personal information, as the case may be, to assess your creditworthiness as a borrower, lessee, or dealer and for the administration of your loan or lease from us, or your dealer relationship with us, including among other things, collection of loan and lease instalments, and payment of commissions, as applicable. 

Profile.  We may collect information on your user profile, including your username and password, applications made by you, your interests, preferences, feedback, and survey responses. 

Applying for a Job.  If you are inquiring about or have applied for a job with us, you may have provided us with certain personal information about yourself (through a resume, cover letter, or employment-related materials). This information will be used to assess your suitability for employment and to respond to your application for current and future career opportunities. 

Inquiries.  When you contact us with a comment, question, or complaint, you may be asked for information that identifies you, such as your first and last name, email address, industry, company name, company website, annual revenue (if applicable), loan amount needed (if applicable), and phone number along with additional information we need to help us promptly answer your question or respond to your comment. We may retain and use this information to assist you in the future and to improve our customer service and product and service offerings. 

Call Recording: We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know at that time. 

Other Uses: Other uses of personal information include: i) business and Website operations such as for troubleshooting, system maintenance, data hosting, and data analysis; ii) business development and market research by using data to understand demographics, interests, usage patterns, and other characteristics of customers; and iii) marketing and advertising through contests, catered content, and promotional materials. 

Legal Requirements.  We may use your personal information for legal and regulatory compliance purposes. 

3. HOW WE COLLECT YOUR INFORMATION

 

Personal information may be collected in a number of ways, including through our website, in person, by mail, by email, from our applications or other software, and from third parties whom you have authorized to disclose personal information to us including credit agencies, financial institutions and employers. 

If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent. 

Visiting our Website: In general, you may visit our Website without telling us who you are or submitting any personal information. However, we collect the Internet protocol (IP) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system, and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.

COOKIES

We may also collect information through “cookies” on our website. Cookies are small text files inside your computer that contain a unique identifier, allowing us to recognize you when you visit our website again. This helps us tailor our content to meet your needs and for advertising purposes. The cookie identifies your browser and will not let a website know any personal information about you, such as your name and address. Since cookies are only data files, they cannot run on your computer, search your computer for other information or transmit any information to anyone.  You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website. 

Like most web sites, Comfort Owl uses cookies and web log files to monitor site usage and measure user traffic on the Website. We use this formation to maintain and improve Website performance. A cookie is a tiny data file which resides on your computer which allows Comfort Owl to recognize you as a user when you return to the Website  using the same computer and web browser. If you prefer, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. If your browser settings do not allow cookies, some elements of our website will not function correctly. Like the information you enter at registration or in your profile, cookie and log file data is used to customize your experience on the web site. Most browsers are initially set up to accept cookies. 

One type of cookie, known as a “persistent” cookie, is set once you’ve logged in to your Comfort Owl account. The next time you visit the Website, the persistent cookie will allow us to recognize you as an existing user so you may not need to log in before using the Services. In order to access or change any of your private information, however, you must log in securely again with your password even if your computer contains your persistent cookie. Additionally, if you log out of the Website you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Website. Session cookies expire after a short time or when you close your web browser. 

Due to the communications standards on the Internet, when you visit the Website we automatically receive the URL of the site from which you came and the site to which you are going to when you leave the Website. We also receive the Internet protocol (IP) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your ISP. This information is used to analyze overall trends to help us improve the Services. The linkage between your IP address and your personally identifiable information is never shared with third-parties without your permission or except when required by law.

PHONE CALLS

For the purpose of maintaining quality service, telephone calls to our service lines may be recorded.  If your call is subject to a quality assurance program, you will be advised prior to speaking with a representative. 

SOCIAL MEDIA

If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.

4. SHARING OF PERSONAL INFORMATION

We don’t sell your personal information to a third party.   We may share personal information with those third parties service providers and affiliates who are reasonably required to help us provide the services to you, for purposes of legal compliance and as otherwise set out herein.   

Service providers and Affiliates: To assess your application we may share your personal information with credit bureaus, credit reporting agencies, credit insurers, telecommunications providers, and financial institutions. Your personal information may be transferred (or otherwise made available) to, maintained or processed by our affiliates and other third parties in Canada or other jurisdictions who provide services on our behalf. We use service providers to send communications, provide back-office support functions, host the Website and operate certain of its features, and provide advertising and marketing services. Our service providers are given the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. 

Legal and compliance: We and our Canadian, United States, and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, United States, or other foreign law or legal process, which may include lawful access by Canadian, US or foreign courts, law enforcement, or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. 

Sale of business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our assets or securities, as part of a corporate reorganization or other change in corporate control. 

Investigations and Protection of Rights.  Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

5. TRANSFERS OF PERSONAL INFORMATION OUTSIDE OF CANADA

Some of our service providers and affiliates may be located in the United States or another foreign jurisdiction. If personal information is transferred to the United States or another foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement, and governmental authorities in accordance with those laws.

6. WEBSITE INFORMATION AND COOKIES

Cookies: As discussed above in Section 3a, our Website uses a technology called “cookies” and if you decide not to accept cookies from our Website, you may not be able to take advantage of all the features on the Website.
 

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at: 

https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/topic/2919631

7. SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job and service requirements. All employees and authorized service providers are expected to maintain the confidentiality of personal information. 

We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes described above or to otherwise meet legal requirements (which may extend beyond the end of your relationship with us).

8. YOUR CHOICES

If you have signed up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link at the bottom of the email. Alternatively, you can opt out of receiving our email communications by contacting us as provided below at “Contact Us”.

9. ACCESS TO PERSONAL INFORMATION

We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. We encourage you to verify the accuracy and completeness of your personal information in our records. You have the right to access, update, and correct inaccuracies in your personal information in our custody and control as well as to withdraw your consent, subject to certain exceptions prescribed by law by emailing or writing to us as provided below at “Contact Us”. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to and/or erasure of their personal information records. Summary information is available on request and we will attempt to respond to the request within 30 days of receipt.  More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees and may take longer to respond to.

10. THIRD PARTY LINKS

Our Website may contain links to other websites we do not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for how the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

11. CHANGES TO THE PRIVACY POLICY

Comfort Owl strives to evolve to meet our Customer’s needs and expectations, and that means our services may change and how we offer our products may change.  As well, laws governing the protection of personal information change from time to time.   With that in mind, we review our privacy practices from time to time, and our information handling practices may change.   If Comfort Owl makes a material change to this Policy, we will provide a revised version on our Website and set out the date on which changes were made.  Changes shall take effect upon notification of such changes.  You may determine when this Policy was last updated by referring to the date found at the bottom of this Policy. If at any point you do not agree with the terms of this Policy, you must not use Comfort Owl’s platform, Website or services.

12. RISKS

While we take industry standard precautions against the unauthorized access, use, and disclosure of personal information, no system is 100% fault proof. The risks associated with the unauthorized access, use, and disclosure of personal information depends on the nature of the personal information involved and the context around such unauthorized accident. We strongly encourage people to use unique log-ins and passwords for every account (don’t use the same password across multiple accounts) and don’t share your password with any third parties. 

Be mindful of emails, text, or other electronic messages that ask you to click on links, provide log-in or password information, or send information. Err on the side of caution and report any suspicious activity to us as soon as possible. If you are in doubt, reach out to the organization by a different means of communication (such as a separate email or text to the address and number you know to belong to the applicable organization, or a phone call to a known legitimate phone number). Do not simply ‘reply’ to the suspicious email or text or call the number provided.

13. GOVERNING LAW

This Privacy Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.


14. CONTACT US – QUESTIONS OR COMPLAINTS

If you have any questions or comments about this Privacy Policy or how we or our service providers treat your personal information, or to request access to your personal information in our records, please contact us at:

Privacy Officer
Comfort Owl Rentals Corp.

8 King Street East, Suite 300
Toronto, ON M5C 1B5

Tel: 1(877) 386-0825
Email: [email protected]