Welcome to the web site or mobile application (as the case may be) (collectively, the “Platform”) of Qira Group (“Qira”) which includes services supplied by Rentigo Inc., HelloRented Inc. and Globipay LLC (including its subsidiaries, affiliates, agents, and service providers, collectively, “Qira”, “we”, “us” and/or “our”). This Privacy Policy (the “Policy”) describes how we and our Agents (defined below) collect, use, protect and disclose information collected through the Site or our Platform or through a tenant lease application that makes rent payment and apartment applications easier for tenants and landlords, or through application for the Qira security deposit replacement service (the “Services”). By accessing the Site, using the Platform or utilizing the Services, you consent to the information collection and handling practices outlined in this Policy. This Policy does not apply to third party sites or services that may collect information for their own purposes using our platforms. We are committed to protecting and using your personal information subject to your informed consent under this Policy and the Terms of Use of our Services posted at the Site.
We post the effective date of this Policy above. We encourage you to check this Site frequently to see the current Policy and Terms of Use in effect and any changes that may have been made to them. If we make material changes to this Policy, we will post the revised Policy and the revised effective date on this Site. Qira has the right to change this Policy by posting an update to it on www. Qira.com (the “Site”) or through the Qira mobile device application (the “Qira App”). If you keep using Qira services for 30 days after a revised version of this Policy is posted to the Site or the Qira App, you will be deemed to have accepted the new version. Please check back here periodically to consult the latest version of the Policy.
YOUR CONTINUED ACCESS AND/OR USE OF THE SITE, THE APP OR OUR SERVICES FOLLOWING ANY CHANGES TO THIS PRIVACY POLICY, MEANS YOU AGREE TO BE LEGALLY BOUND BY BOTH THIS PRIVACY POLICY AND OUR TERMS OF USE. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT USE THE SITE OR THE APP OR PROVIDE ANY INFORMATION TO US.
Terms not defined in the body of this Policy are defined in a list of defined terms at the end of this Policy.This Policy forms part of our Terms of Use.
General information
We believe that you have the right to understand how your information is collected, used, disclosed, maintained, protected and stored. Please note that the Site contains links to third party sites. We are not responsible for the privacy practices or the content of any such third party sites and we encourage you to read the privacy policies and terms of use of those third party sites.
Information You Provide Us
In general, you can visit this Site without telling us who you are or revealing any information about yourself. If you wish to obtain information about our Services, you can contact us at the address listed below. We may collect your name, email address, and street address along with other information you may choose to submit, as part of the inquiry process.
Tenants: When you set up an account with us, as a tenant, through use of our App, Site or through the Services, we may collect, either directly through you or through your Property Management Company, and store personally identifiable information about you – such as your name, date of birth, address, e-mail address, Social Security number, driver’s license number, utility bills, telephone number, prior addresses, rent paid at prior residences, rent paid or owing at your current residence, information concerning your access to your current residence building, device and location information concerning your mobile device, IP address, current and/or previous employers, job titles, income, debit card information, credit card information, bank account information and routing numbers, gender, age, marital status, username and password, password hints and security questions, emergency contact information, information about your pets, information about your vehicles including license plate numbers and other information necessary to supply the Services. If you agree to a credit check for the benefit of a Property Management Company, then we may, at our discretion, also collect information regarding your credit history, criminal history, social security verification, motor vehicle and driving records, verification of your education or employment history or other background checks from credit reporting agencies, demographic and lifestyle information, information we receive when making a decision about you, your loan or application (including information collected from the Credit Bureaus), details of the credit you have and have had with us and all transactions, if you change your bank and your old bank informs us of your new bank account details, we will hold the new bank account details, and use them to operate your account as well as any other information which we reasonably need to operate your account, make decisions about you or fulfil our regulatory obligations. We may also collect your mobile phone number if you provide that number to receive messages by text or calls to your cellular phone. We may also ask you personal identifier questions for purposes of verifying your identification. We may collect transaction and experience information, such as information necessary to complete any transactions with us, as well as information about our communications with you. We may, at our discretion, use this information to provide the Services that you request, to let you know of additional products and services about which you might be interested, and for marketing, research and other purposes. We may also use information that we collect and maintain to determine your eligibility for additional products and services of our or of third parties.
Property Management Companies:
When a Property Management Company (i.e. landlord) sets up an account with us, we may collect and store sensitive corporate and personal information about you and the company, including personally identifiable information such as your name, address, e-mail address, Tax I.D. number, telephone number, data associated with your payment method (credit card or bank account information), information concerning properties you own or manage, information concerning your leases with tenants in such properties and information concerning the operation of such properties (e.g. services in the property). We will also collect other personally identifiable information from Third Parties such as consumer and business credit reporting agencies as part of our due diligence and underwriting process. We may also ask you personal identifier questions for purposes of verifying your identification. We may collect transaction and experience information, mobile device location information, rent roll information, and other information necessary to any transactions with us, as well as information about our communications with you. We need this information to provide the products and services that you request from our website and to let you know of additional products and services about which you might be interested.
By providing your information to us, you agree to our, our Agents’ and where applicable, the Property Management Company collection and use of such information to deliver the Services, as described in the Terms of Use and this Policy. You also acknowledge and agree that if the Services involve the participation of the Property Management Company, the information that you provide or your information that we collect may be shared with and used by the Property Management Company.
If you connect with us via social media, such as Facebook or Twitter, we may collect additional information about you and your connections if you authorize us to do so by providing the necessary consents
We collect this Personal Data for the purposes of providing the Services to you, as well as providing customer service, conducting research and improving the Services. For more details on why we collect your Personal Data and how we use it, please see the section below entitled “Our use of Personal Data and other information.” While you are under no obligation to provide any Personal Data, should you choose to withhold such information, we may not be able to provide you with some or all of the Services.
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Qira and the authorized third parties referred to herein.
Other information
Non-Personal Data
When you interact with Qira through the Services, we automatically receive and store certain non- identifiable personal information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Examples of this non-identifiable personal information include the type of internet browser or mobile device you use, any website from which you have come to the Services, your operating system, location data (which is anonymous and where you log in through the Platform you will be asked if you consent to the Services accessing your location, which can be updated at any time in your device settings) (“Non-Personal Data”). Qira may store such Non- Personal Data itself or such information may be included in databases owned and maintained by Qira affiliates, agents or service providers. The Services may use such Non-Personal Data to assist us in providing effective Services and to collect broad demographic information for aggregate use.
Aggregated Data
In an ongoing effort to better understand and serve the users of the Services, Qira often conducts research on its customer demographics, interests and behavior based on the Personal Data, Non-Personal Data, and other information provided to us. This research may be compiled and analyzed on a de-identified, aggregate basis, and Qira may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. Qira may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Payment Information
Payment Information is collected for the purpose of allowing the Property Management Company, its payment processors and processing bank and ourselves to process payments under the Property Agreement and for us to collect fees owing to us under our Terms of Use. Any such information may also be used to collect any amounts owed to us in the event of a breach of this agreement. All other references to use or sharing of information in this policy shall exclude Payment Information.
Location Information
We and our Agents may collect and record information about your location if you have accessed our Services using a mobile device. We may collect information based on where you have used your phone to interact with the Services and in connection with applications you have downloaded. If you have provided us your consent, we may also obtain location information from cellular service providers. We use this information to supply the Services and also promote Third Parties. We and our Agents may use this information for statistical purposes, for other purposes as set out in this Policy or as permitted by applicable law.
Information Collected Automatically
When you use the Services, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, IP address, device and hardware specifications, cookie information, access times, browser type, language, the page you requested, search terms used on the Site, duration of visits and the website visited that directed you to our Site. We treat this data as non-personal Information, except where we are required to do otherwise under applicable law. We may provide information to our Agents but only for the purposes set out in this Policy.
Email Integrations
The Services may collect Personal Data relating to third parties stored in your email and mobile device address books, including, without limitation, names, email content, email addresses, and phone numbers (collectively, “Third-Party Personal Data”). The Services may request your permission to access such Third-Party Personal Data. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Email Service. When you add an Email Services account to the Services or log into the Services using your Email Services account, we will collect relevant information necessary to enable the Services to access that Email Service and your data contained within that Email Service. As part of such integration, the Email Service will provide us with access to certain content and information that you have provided to the Email Service, and we will use, store, and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Email Services use, store, and disclose your information is governed by the policies of such third parties, and Qira shall have no liability or responsibility for the privacy practices or other actions of any Email Services that may be enabled within the Services.
Please visit the privacy policy of the relevant Email Service to find out more information about your rights and choices.
Mobile Services
The Services include certain services that are available via a mobile device, including (i) the ability to upload content to the Services via a mobile device, (ii) the ability to browse the Platform and Services from a mobile device, and (iii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the “Mobile Services”). To the extent you access the Services through a mobile device, your wireless service carrier’s standard charges, data rates, and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices. By using the Mobile Services, you agree that we may communicate with you regarding Qira by SMS, MMS, text message, or other electronic means to your mobile device and that certain information about your usage of the Mobile Services may be communicated to us. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Qira account information to ensure that your messages are not sent to the person that acquires your old number. We may at all times rely upon the information contained in your Qira account.
Protecting Children’s Privacy
This Service are not designed nor intended to be attractive to be used by people under the age of 18 (“Minors”). We do not knowingly collect information from Minors. If you are a parent or guardian of a Minor and believe he or she has disclosed personally identifiable information to us, please contact us at the contact information set out below. A parent or guardian of a Minor may review and request deletion of such Minor’s personally identifiable information as well as prohibit the use thereof. If you are under the age of 18, please do not submit any information to us.
Cookies
We use cookies to personalize our Site and Services for you and to collect aggregate information about Site usage by all of our users. The aggregated information is used to understand and analyze users’ responses, needs and preferences and to develop, improve, market and/or offer products and services of our own and Third Parties to meet users’ needs and preferences. A cookie is a text file that our Site transfers to your computer’s hard drive for record-keeping purposes and to enhance the quality of your visit to our Site. The cookie assigns a random, unique number to your computer. Our cookie may record “clickstream” information (data reporting the URLs or names of the pages on this Site that you have visited). We may use cookies that stay on your device after you leave this Site so that we can recognize you when you return. We also use cookies that are deleted when you leave the Site. You can set your browser to refuse cookies but doing so will limit system performance and may even cause certain features of the Site to malfunction or not work.
Use of Information
The information you provide to Qira will be used for the following purposes:
- to provide the Services;
- to accurately record and update your account provided through the Services;
- to process payments under Property Agreements;
- to search Credit Reference Agencies’ and Fraud Prevention Agencies’ records (including information from overseas);
- to share with our designated insurance broker and / or insurance carrier for the purposes of their underwriting efforts;
- to make, or assist in making, credit decisions about you, assess lending and insurance risks, and to check the details that you have let us and others have;
- operate and manage your account and manage any application, agreement or correspondence you may have with us;
- to identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
- to form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
- carry out market research, business and statistical analysis;
- provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
- carry out audits;
- perform other administrative and operational purposes including the testing of systems;
- trace your whereabouts;
- recover any debt you owe us;
- comply with our regulatory carry out, monitor and analyze our business; and
- contact you by email, SMS, letter or telephone about our products and services, unless you tell us that you prefer not to receive marketing.
- to send you alerts concerning a premises that you lease from a Property Management Company;
- to communicate with you and Property Management Company, concerning visits to a Property, entry into and performance under a Property Agreement;
- to assist Property Management Company in screening you as a potential party to a Property Agreement;
- to better understand and analyze your needs and preferences in respect of the Property and Third Parties;
- to communicate offers and promotions and events of Property Management Company or Third Parties to you; and
- to develop, enhance, market and/or provide products and services to meet those needs and determine eligibility for those services if applicable
By providing your information to us, you consent to us and our Agents using the information for the uses specified herein. If you are a Property Management Company, you authorize us to use your and your tenants’ information to provide them with our Services that you have selected.
Information we share
we will keep your personal information confidential and only share it with others for the purposes explained in this policy. We have trusted relationships with carefully selected third parties who perform services on our behalf. All service providers are bound by contract to maintain the security of your personal information and to use it only as permitted by us.
Information we share
Our Site, the Platform and the Services are designed to share information about you with your Property Management Company which you are renting from, and to facilitate the provision of other services that may be beneficial to you. The information we collect and share about you is shared to the extent reasonably necessary to support your Property Management Company and us in performing the Services, and to determine your eligibility and interest in additional services. Through the use of the Site, App and Services you agree to the disclosure of such information by us to the Property Management Company and other service providers and third parties as applicable. We do not disclose your personal information with any other third parties than described in this Policy. Please note that we do not maintain control over the privacy policies and practices of your Property Management Company, landlord or any third party companies, Agents or contractors.
We will not use or disclose your information for purposes other than those for which it is collected, except as described in this policy or with your consent or as required or permitted by law. The provisions contained herein supersede all previous notices or statements regarding our privacy practices with respect to this Site, though individual “Terms of Use” or other agreements with specific tenants may over-ride the policies contained herein. Information collected through this Site, the App and our Services is automatically provided to our Agents. They may use the information as described in their privacy policies.
We and our Agents may use aggregated data (independent of personal identifiers) for research, to improve our Services and for commercial purposes. This information includes what areas our users visit most frequently and what rewards, services or products they access or purchase most often.
We and our Agents may use your information for our general commercial purposes including, among other things, to offer our own, our affiliates’ or Third Party products and services that we think you may find of interest. We and our Agents may use your email address, cell phone number, social media accounts or other means of contacting you to respond to your inquiries, obtain or to provide information on our products or services or those of third parties. You can elect not to receive emails from us either by “unsubscribing” to an email you receive or by contacting us as indicated below. We may use your mobile phone number to contact you by text message if you have provided that number to us for such purpose. You can stop receiving text messages by following the directions on this Site or by contacting us as indicated below.
Property Management Company may use your information in order to obtain a screening report that may include credit information. Under the Fair Credit Reporting Act (15 U.S.C. 1681ff), you may have the right to access, view and correct credit information relating to you held by a credit reporting agency by contacting the credit reporting agency that provides credit information.
We may store your information outside of the United States in a cloud-computing service that is protected by commercially reasonable security systems. By submitting your personal information, you agree to the transfer, storing, or processing in destinations inside or outside the United States. We may transfer personal data to recipients in countries other than the country in which the data was originally collected, including the United States. These countries may have different data protections rules than the United States. We will take measures to ensure that any such transfers comply with the applicable data protection laws and that your personal information data remains protected to the standards described in this Policy.
We may reveal personally identifiable information about you to affiliated and unaffiliated third parties: (1) if you request or have consented to it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a consumer reporting agency for fraud protection
etc.); (4) if the disclosure is done as part of a purchase, transfer or sale of services or assets or in the case of bankruptcy or reorganization (e.g., in the event that some or all of our assets are acquired by another party, customer Services information may be one of the transferred assets); (5) if the information is provided to our Agents; (6) in an emergency to protect the health personal safety of Qira employees, Agents, its customers or the general public; (7) to protect the rights and property of Qira, including both intellectual property and physical systems infrastructure or (7) as otherwise described in this Policy.
Withdrawal, Opt-Out, Access, and Retention
If you wish to withdraw from our Services, you can do so by contacting us at the address indicated below. This will terminate your participation in the Services. You will no longer be able to use the Services and information in your Services account, and any information may be deleted. Any data concerning your past transactions or account activity will no longer be available to you and will stored in a secure manner. We are legally required to keep a backup copy of such data for seven (7) years after the transaction was completed and we may also use that information for a time following termination to manage chargebacks and other risks in our delivery of the Services. Thereafter, the copies of data you have provided in connection with any transaction you complete the use of the Services are removed from our secure storage and securely destroyed.
We will retain personal information only as long as necessary for the fulfillment of the purposes identified in this Policy. Personal information that is no longer required to fulfill such purposes are destroyed or anonymized.
To access and review your information, make any changes or corrections or to request that we remove your information please contact us at the address below. To protect your privacy and to comply with federal regulations, we will need to verify your identity before you update or review your information. Any changes will affect only future uses of your information.
Security
We have physical, administrative, technical and organizational security measures in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to reasonably protect information contained within our facilities or systems from accidental loss, damage, destruction, misuse or alteration appropriate to the sensitivity of the information.
The safety and security of your information also depends on you. Where we have given you, or where you have chosen a password to access certain parts of the Services, you are responsible for keeping the password and login credentials secure. We ask that you not share your password or login credentials with anyone.
Transmission of information to and from this Site or the App is not secured by encryption except as otherwise required by law or payment card industry data security standards applicable to the storage, processing and transmission of payment card data. By providing your information to us or our Agents, you expressly agree to the above described cross border transmission of information and manner of transmission. Your email transmissions and other communications containing information may be unlawfully intercepted or accessed by third parties and/or the Site and the Services may be subject to hostile network attacks or administrative errors. We cannot and do not guarantee the security of any information transmitted over the internet. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or in the App.
Once we receive your information, we take steps that we believe are commercially reasonable to limit access to your information to only those employees, business partners and service providers whom we determine need access to the information to provide the requested services, products, offers or opportunities that may be of interest to you. However, even after we receive your information, we cannot guarantee that your information may not be accessed, disclosed, altered, or destroyed as a result of a breach of our commercially reasonable efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your information is completely secure and safe from such risks. We maintain security incident response policies and procedures to handle incidents involving unauthorized
FOR THE AVOIDANCE OF DOUBT, WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION, INCLUDING PERSONAL INFORMATION OR USAGE INFORMATION, THROUGH THE WEBSITE.
Marketing Communications
We may send you marketing communications about Qira products and services, update you on new features, or otherwise communicate with you for marketing purposes via email, SMS Text, via the mail, social media messaging accounts or through other communications methods. If you no longer wish to receive marketing related communications from us, you may opt out by following the instructions included in those communications. You may also send requests about your contact preferences by emailing the contact email set out below with the subject line “Privacy Policy Notice”. If you opt out of receiving marketing emails, we may still send you emails or other communications about your account(s) or our ongoing business relations.
California Civil Code §1798.83 permits residents to request certain details about information we disclose to Third Parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at the address listed below.
Contacting Us
If you have any questions or suggestions with respect to this Policy, or if you wish to ask us to delete, correct, or show you your information as provided above, feel free to contact us at the address indicated below with the subject line “Privacy Policy Notice”.
Qira, LLC
49 West 45th Street New York, NY 10036
Attention: Chief Privacy Officer [email protected] Qira.com
Definitions In this Policy
“Agents” means Property Management Company, our outside vendors, payment processors, banks, gateways, technology suppliers, service providers or other agents who perform functions on our behalf or on behalf of us or Property Management Company related to the Services or the Property Agreement; “Information” shall mean information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization
“Payment Information” means your bank account number, check information or debit card number, expiry date and security code.
“Property” means the property or service you procure pursuant to a Property Agreement;
“Property Agreement” means your agreement with the Property Management Company concerning your lease or use of the Property;
“Property Management Company” means the entity (e.g. landlord) with whom you have contracted to rent a Property and to which you wish to make a payment that is supported by the Services.
“Third Parties” means third parties who provide services for tenants and other people using properties such as the Property.
