Last update: 06/18/18
This policy describes how Soul City Group Inc. collects, processes, uses and shares personal information and personal data about users of the Soul.City App (the “Application” or “App”).
In this policy, the term personal data refers to information that relates to an individual who is identifiable.
The contact details of the data controller under this policy are as follows:
Soul.City Group Inc.
1228-5333 Casgrain Avenue
Montreal, Quebec H2T 1X3
Attn: Privacy Officer
Basis for Data Processing
In order to enable you to use the Application and the services offered through the Application, we must collect and process personal data about you. Our processing of personal data is mainly based on the following principles:
- We must process some personal data in order to be able to provide you with services and to allow you to use the Application.
- We may process certain personal data because you have given specific consent. You may withdraw your consent at any time and we will stop personal data processing that is based on your consent.
- We process certain personal data when necessary for the purpose of our legitimate interests, those of our users and partners, when the processing does not violate users’ fundamental rights.
Data We Collect
Information that comes from you
We collect the information you provide to us (for example by completing a form) through the Application interface or otherwise. This information may include:
- Your first and last name;
- Your email address;
- The content you download to the Application, for example if you liked an itinerary or leave a comment about an itinerary or point of interest on the Application;
Data Collected Automatically
We collect information automatically when you use the Application. This information is saved each time you interact with the Application and includes information about your mobile device and data about your interactions with the Application, in particular:
- The operating system and identification number of your mobile device;
- The make and model of your mobile device
- The version of the Application in use;
- The operating language of your mobile device
- The IP address from which your mobile device accesses the Application;
- The country, state, city, and zip code where your mobile device is located
- Screens consulted, actions taken, the number of connections to the Application, the date of the connections to the Application.
When your mobile device’s location feature is turned on and you have granted the Application access to our location data, we collect precise location information. By allowing the App to access the location data of your mobile device, you consent to our collection and use of your location data in accordance with this policy. You can use the Application even if you have not granted access to your location data, but some features will be disabled.
When we have your consent, your location data is saved each time you interact with the Application. This data could be used to infer additional information about you, such as the points of interest you visited and the itineraries you completed.
Data From Analysis Tools
When you access the Application, we collect data provided by analytics tools such as Google Analytics. This data may include, for example, sex, age, interests, but it is not associated with you personally and is provided to us in aggregated form.
Data From Social Networks
We collect information from sites or social networking applications (Facebook, LinkedIn, Twitter, YouTube, Google+, etc.) when you interact with profiles belonging to us. These sites or applications are also governed by their own policies regarding your personal data which may be different from ours and may be applicable.
How We Use your Data
We process personal data collected through the Application for the purposes described below. Some processing is subject to your specific consent, while other processing is necessary to provide you with services or is based on the pursuit of legitimate interests.
We use the personal data you provided us (for example your name and email address) to contact you about your use of the Application, but only if you have provided such data and if you agree to receive communications from us. We abide by applicable regulations with respect to unwanted electronic communications. If you no longer wish to receive electronic communications from Soul.City, you can notify us at any time at the following address: email@example.com.
If you agreed to receive push notifications from the App, we use some personal data to determine when to send you a push notification and to personalize the content of the notification. For example, you may receive a notification because you are near a point of interest or because you have completed a particular itinerary. You may withdraw your consent to this processing of your personal data by disabling push notifications from the Application in your mobile device settings.
Customizing Our Services and the Application
We use data collected automatically during your connection to the Application to offer you itineraries that correspond to your general geographic location (depending on the country and the city). We also use this data to provide you with content that matches your interests, depending on the content you viewed through the App (such as pages, itineraries, points of interest).
If you have granted the Application access the location data of your mobile device, we will use your location data to provide you with content and itineraries that correspond to your precise location. We also use location data to provide you with content that matches your interests based on the points of interest you have visited.
Providing Information to Our Partners
We use the data collected through the Application, in aggregate form that does not associate data to a particular individual or mobile device, in order to provide marketing information to our business partners. We share statistics that are segmented using certain personal characteristics, without these characteristics being associated with any particular individual.
We use data collected through the Application and data collected from analytics tools to monitor usage of the Application generally, to prevent misuse of the Application, to identify problems or bugs in the Application and to determine which features we should improve.
We process personal data collected through the Application to fulfill our legitimate interests, including improving our services and providing our users with personalized content. Since the Application is offered to users free of charge, we rely on our legitimate interests in providing value to our business partners by processing the data (including personal data) collected through the Application, to enable them to use personalized advertising and improve the marketing of their products and services.
We take the privacy of our users seriously. That is why the processing of personal data based on our legitimate interests never involves targeted monitoring or communicating specific personal data about identifiable individual to third parties.
How do we Store your Data?
We keep your personal data until you ask us to destroy it, until our activities no longer require keeping your data for up to 36 months after your last connection to the Application. We do not, however, undertake to keep any data for a determined period of time.
Personal data is stored electronically on our servers located in Beauharnois, province of Quebec, Canada. These servers are operated by our hosting provider, OVH Canada which undertakes in writing to keep your personal data confidential.
Personal data collected about individuals located outside of Canada is transferred to Canada. Canada is recognized as an appropriate jurisdiction for the transfer of personal data from the European Union.
How Personal Data is Protected
Your personal data is hosted by our hosting provider, OVH Canada, which agrees to use industry-standard security measures to maintain the integrity and confidentiality of data.
Our employees and service providers are aware that the personal data collected through the Application is confidential and are informed about the appropriate security measures to prevent unauthorized access to personal data.
How Personal Data is Disclosed
We only share your personal data as described in this policy or when we have your consent. Your personal data may be disclosed to the categories of recipients described below for the purposes mentioned.
Collected personal data is only available to our officers and employees who must access it for the purposes described in this policy.
We share some personal data with service providers that enable us to render our services more efficiently. These providers agree in writing to keep personal data confidential and to limit their use of personal data to what is necessary to provide their services.
We disclose personal data, in an aggregate form that does not identify the individuals involved, with business partners for advertising and marketing purposes. This data includes, but is not limited to, statistics about our users, how the App is used, the moods selected by users, how they use the itineraries, which points of interest they visit, comments about itineraries and points of interest .
When you have given your consent, we may share personal data about you with our business partners so that they may offer you products and services directly, based on your use of the Application, the itineraries you choose, the mood you select on the App or the points of interest you have visited or are about to visit.
We may also disclose personal data to third parties if the law expressly authorizes or requires such disclosure, or if we are ordered to do so by a competent authority. We may disclose personal data in the context of court proceedings if necessary to protect our rights or those of our users.
Sale of Business
In the event that the sale or restructuring of all or part of our business is envisioned, we may disclose collected personal data to the persons or organizations involved before and after the transaction, whether or not it takes place. In such a case, these persons or organizations undertake to keep disclosed personal data confidential and to use same exclusively in order to evaluate the feasibility or the opportunity of the proposed transaction as well as in accordance with this policy.
The App includes features that allow you to share content through social networking platforms. If you share content that includes personal data, that information may become publicly available based on the settings you selected.
What are your Rights about your Personal Data
Access your data
You may have access to some personal data that you have personally provided to us by accessing your account through the Application.
To access the personal data that we hold about you or to rectify personal data that is incorrect, you may make a request in writing to the following address: firstname.lastname@example.org or to the address of the data controller at the beginning of this policy.
We will respond to your request promptly (within 30 days of receipt), allowing you to access your personal date that is under our control. When required by law, we will provide your data in a portable machine-readable format.
Withdrawal of Consent
You may withdraw your consent to the collection and processing of some personal data, including location data, by denying the Application access to the location data of your mobile device.
The Application allows you to withdraw your consent to certain processing of your personal data, including by opting in or out of promotional offers based on your activities on the Application.
If you wish to withdraw your consent to the processing of your personal data beyond what the Application or your mobile device allows, please notify us in writing at email@example.com. It is not possible to stop all processing of your personal data and continue using the Application. The only way to stop all processing of your personal data is to stop using the Application.
In certain circumstances, depending on your place of residence, you may have the right to object to the processing of your personal data based on our legitimate interests. You may object to the processing of your data in writing at firstname.lastname@example.org.
You may request the erasure of personal data that we hold about you in writing at email@example.com. We will respond to your request as soon as possible (within 30 days of receipt).
If you continue to use the Application after your personal data has been erased, we will continue collect certain data about you.
If you reside in the European Union, you have the right to lodge a complaint about the processing of your personal data with a supervisory authority responsible for the protection of privacy. The competent authority may vary depending on your country of residence.
If you reside outside of the European Union, this policy shall be governed by the laws applicable in Canada and the Canadian authorities shall have exclusive jurisdiction to hear any complaint or proceedings.
We reserve the right to verify the identity of individuals requesting access to personal data. Any information collected to perform this verification will not be used for any other purpose.
Updates to This Policy
We may update this policy from time to time to reflect changes in our personal data management practices. If this policy is modified, the new policy will be available through the Application and on our website at the following URL : ●.
For any additional information concerning the processing of your personal data, you may contact us using the contact information at the beginning of this Policy.