Thanks for using Pillar Security. This policy explains the what, how, and why of the information we collect when you visit our website, or when you use our services such as virtual concierge and our condo management software. It also explains the specific ways we use and disclose that information. We value your trust and take your privacy extremely seriously!
1. DEFINITIONS WITHIN THIS POLICY
Pillar Security Service or Service (“Us”, “We”)
That’s us! Our Service consists of our website www.pillarsecurity.com and all of its associated features, functionalities and interfaces related to Virtual Concierge website and condo management software.
Content
Any PDFs, images, text, sound and other material that is posted to or accessed via Pillar Security electronic services.
Data Subject(s) (Also known as “You”, “Client (condo corporation)” & “Residents”)
In most circumstances that’s you, the Client (condo corporation), a Pillar Security
client. You as an individual provide us with your personal data in order to use the services of
Pillar Security. Data subjects can also be “Residents” - the people who read and interact with
Pillar Security Services and products.
Data Controller
In most circumstances, that’s us. We’re the individuals responsible for things like
personal data collection in connection with creating an account, collecting consent, managing
consent revocation, enabling right to access, etc. In certain circumstances, you as the Client
(condo corporation) can also be a Data Controller when collecting and processing your visitors’
Personal Data. We refer to these circumstances specifically in Section 7.
Data Processor
The Data Processor is a person or organization who processes your personal data as
instructed by us for specific purposes - for example, our accountants, our marketing partners,
our cloud service providers etc. In certain circumstances, we can be a Data Processor instead of
a Data Controller. We refer to these circumstances specifically in Section 7.
Personal Data (also referred to as “data”)
Any information relating to an identifiable natural person (‘data subject’); an
identifiable natural person is one who can be identified, directly or indirectly, in particular
by reference to an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
Usage Data
Information collected automatically through Pillar Security (or third-party services
employed by Pillar Security), which can include: the IP addresses or domain names of the
computers utilized by the Client (condo corporation)s who use Pillar Security, the URI addresses
(Uniform Resource Identifier), the time of the request, the method utilized to submit the
request to the server, the size of the file received in response, the numerical code indicating
the status of the server's answer (successful outcome, error, etc.), the country of origin, the
features of the browser and the operating system utilized by the Client (condo corporation), the
various time details per visit (e.g., the time spent on each page within Pillar Security) and
the details about the path followed within the Application with special reference to the
sequence of pages visited, and other parameters about the device operating system and/or the
Clients (condo corporation) IT environment.
Cookies
Cookies are small pieces of data that are downloaded to your computer or mobile device
when you visit a website or application. For a full overview of cookies, please see our Cookie
Policy.
2. SCOPE
This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you, according to our Terms of Use. This Privacy Policy applies to all digital services offered by Pillar Security, represented digitally as www.pillarsecurity.com (hereinafter “Pillar Security”).
3. TYPES OF DATA WE COLLECT
a) Information you voluntarily provide to us: When you sign up for and use Pillar Security, consult with our customer service or sales team, send us an email, fill out a lead form, send us a message in chat or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include: your or your client’s name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, occupation, location, purchase history, and other demographic information.
b) Information we collect automatically: When you use Pillar Security, we may collect information about your visit to our site, your usage of the Services, and your web browsing. That information may include: your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with Pillar Security or other websites. We may collect this information through the use of cookies or other tracking technologies. See our Cookie Policy.
c) Information from your use of the Service: We receive information about how and when you use Pillar Security. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve the services of Pillar Security.
d) Cookies and tracking: Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information and data used for marketing and targeted advertising. You can see how we use cookies, which data we collect and change your preferences or opt out via our Cookie Policy.
e) Anonymous usage data: Pillar Security collects anonymous usage data whenever a Client (condo corporation) or Resident interacts with our Service, for example: number of views and downloads, type of device, type of browser, links clicked, geographic location and referral source.
4. WHAT WE USE YOUR DATA FOR
We may use the Personal Information we collect through Pillar Security or 3rd party sources for a range of reasons, including:
5. OUR LEGAL BASIS FOR COLLECTING THIS DATA
We legally collect and process your data under the following premises:
6. RETENTION OF DATA
For Clients (condo corporation), we keep your Personal Data as described in the previous sections of this Privacy Policy as long as you have an active account with us. Once your account is deleted, we take steps to remove all of your personal data from our systems and 3rd party providers within 90 days (the “Buffer Period”). After the buffer period, all data is permanently and irrevocably deleted from our system, except for the data which is mandatory in order for us to comply with our legal, regulatory and taxation obligations. For Residents, your personal data is permanently deleted from our system when the Client (condo corporation) deletes or cancels their account associated with your data input.
7. WHEN PILLAR SECURITY’S CLIENT (CONDO CORPORATION) COLLECT PERSONAL DATA FROM THEIR RESIDENTS
With some of Pillar Security’s virtual concierge and condo management software features a Condo corporation is able to collect Data from their residents and download that collected Data in CSV format. In these instances, the condo corporation becomes the Data Controller and Pillar Security becomes the Data Processor. This is because the condo corporation exercises overall control of the purpose and means of the processing of the Data (they decide what to process from their residents and why), while Pillar Security only facilitates the data collection from a technical perspective and acts on behalf of the condo corporations’ instructions.
As such, condo corporations are responsible for having the appropriate permission and consent relevant to collect and process Data about their residents, as well as ensuring that their manner of processing the Data is consistent with this Privacy Policy.
If you are a resident who has voluntarily submitted Personal Data to one of our clients (condo corporations) via these features and wish to exercise any of your data rights (See Section 11 below), please contact the condo corporation directly. Should you contact us, we may remove or update your information within a reasonable time, after providing notice to the condo corporation of your request.
We will only retain the Data we process on behalf of our client (condo corporation) for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
Types of personal data Pillar Security Clients (condo corporation) may collect from their Residents:
The Personal Data collected depends entirely on the fields the Client (condo corporation) is requesting for the Resident to fill out; however, examples may include: the Resident’s email address, full name, company, address, phone number etc. It is important to note that as a Resident, you are not required to fill out any information, but rather, that submission of your information is voluntary and at your own discretion.
As a client (condo corporation), you should know that your usage of the Resident’s collected Personal Information is limited to:
Additionally, usage and storage of collected Personal Information is limited to the terms set out in this Privacy Policy. Any breach of such terms may result in Pillar Security suspending your rights to use these data collection features, termination of your account or in some cases, legal action.
8. OUR THIRD PARTY PROVIDERS
When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.
ANALYTICS & MARKETING/REMARKETING
The 3rd party services contained in this section enable Pillar Security to monitor and analyze web traffic & client (condo corporation) behavior, as well as to market relevant offers/advertisements.
MANAGING CONTACTS AND SENDING MESSAGES
This type of services makes it possible to manage a database of email contacts. These services may also collect data concerning the date and time when the message was viewed by the Client (condo corporation), as well as when the Client (condo corporation) interacted with it, such as by clicking on links included in the message.
MANAGING SUPPORT AND CONTACT REQUESTS
This type of service allows Pillar Security to manage support and contact requests received via email or by other means, such as the chat widget. The Personal Data processed depends on the information provided by the Client (condo corporation) in the messages and the means used for communication (e.g. email address).
9. PROTECTION OF DATA
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include: firewalls, data encryption, dedicated servers, physical access controls to our data centers & offices, information access authorization controls, protection against script injection and A+ server SSL ratings.
While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party.
10. NOTICE OF BREACH OF SECURITY
Every care is taken to protect your Personal Data from accidental or deliberate incidents that compromise security. In the unfortunate and unlikely event that a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify both you and the relevant supervisory authority about the breach within 72 hours of becoming aware of it. We will also inform you of the steps we’ve taken to remediate the breach at our earliest possible opportunity.
11. UK & EU CLIENTS RIGHTS
As a data subject, you are entitled to eight (8) client (condo corporation) rights under the GDPR. Information about how to manage your rights can be found in Section 12 below. In most cases we do not charge fees to comply with your requests; however, we will charge a reasonable fee for our administration costs if we deem your request to be manifestly unfounded or excessive. We will always inform you prior to completing your request if we will charge a fee. We also reserve the right to refuse to comply with manifestly unfounded or excessive requests.
THE RIGHT TO BE INFORMED
You have the right to be provided with information about our data processing activities.
THE RIGHT OF ACCESS
You have the right to know which personal data we collect from you.
THE RIGHT TO ERASURE
You have the right to request the deletion of your personal data.
THE RIGHT TO RESTRICT PROCESSING
You have the right to restrict processing of personal data under certain circumstances. Should you exercise this right, we may not be able to provide a portion or entirety of our services to you.
THE RIGHT TO OBJECT
You have the right to object to the processing of your personal data.
THE RIGHT TO RECTIFICATION
You have the right to rectify any inaccurate or incomplete personal data.
THE RIGHT TO DATA PORTABILITY
Under certain circumstances, you have the right to copy, transfer or move your personal data.
THE RIGHT TO AVOID AUTOMATED DECISION-MAKING
You have the right to be provided with safeguards against automated decision-making. As a responsible service, we do not use any automated decision-making or profiling.
12. HOW TO MANAGE YOUR DATA WITH PILLAR SECURITY
How to exercise your data subject rights under the GDPR
Should you wish to exercise any of your data subject rights under the GDPR. It is important to note that, in some situations, restricting or withdrawing your consent for us to process your data may result in reduced account functioning or inability for us to offer you our Service.
How to update your personal information
You can change or correct your personal / account information with Pillar Security at any time by logging in to your Pillar Security account & updating your information (*Please note, certain changes may affect the functioning of your account).
How to delete your data from Pillar Security
If you’d like to delete all of your data from Pillar Security, you should simply delete your account. Please note, this action is irreversible and means you will have to delete your existing account and everything that is stored in your account (flipbooks). Once you delete your Pillar Security account, we will take steps to remove your personal data from our systems and from 3rd party processors, within the timeframes stated in Section 6 (“Data Retention”).
How to opt out of email communications from Pillar Security
As a Pillar Security client, you receive two types of email communication from us - system emails and marketing emails. You can adjust or opt out of receiving marketing emails at any time by clicking on the unsubscribe button at the bottom of the marketing email you receive. Regarding our system emails, you are unable to opt out as they are required legal, payment or system notices in accordance with your use of Pillar Security’s Service.
How to opt out of 3rd party processing
You can easily change your preferences or opt out of 3rd party processing when using our Service. You can do this via the cookie dialog box on our website, or by visiting our Cookie Policy and changing your consent.
13. REPRESENTATION FOR DATA SUBJECTS IN THE UK (UK GDPR)
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights.
14. PIPEDA - CANADIAN CLIENTS (CONDO CORPORATION) RIGHTS
The Personal Information Protection and Electronic Documents Act (PIPEDA) is a Canadian federal law, enacted in April of 2000 and updated several times since then, that applies to private sector businesses engaged in a commercial activity. The law governs the collection, use, and disclosure of personal information for private-sector organizations in Canada.
How is Pillar Security compliant with the PIPEDA?
Pillar Security is committed to compliance with the requirements of the PIPEDA and its underlying principles, where it applies to our data processing activities. Our compliance efforts in this respect are guided by the 10 fair information principles published by the Office of the Privacy Commissioner, including:
15. QUESTIONS & CONCERNS
If you have any questions or comments, if you have a concern about the way in which we have handled any privacy matter or wish to exercise your privacy rights, please contact our Data Protection Officer (DPO) at info@pillarsecurity.com You can also send us a request via registered mail to:
Pillar Security
Attn. Data Protection Officer
21 Four Seasons Place Unit 327,
Toronto, ON, M9B 6J8
16. DATA PROCESSING ADDENDUM (DPA)
We provide all of our customers with the opportunity to sign a Data Processing Addendum (DPA) with us. Executing a DPA does not change any of our practices concerning the protection of your privacy and your data. Everyone using our service gets the same high standards of privacy and security. If you require an executed DPA with us, please contact us at the DOP address.
17. CHANGES TO THIS POLICY
We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to be bound by this Privacy Policy.
LAST UPDATED: 13.9.2022