LuxOasisOS Privacy Policy
Agreement to this Privacy Policy
This Privacy Policy explains how 13707245 Canada Inc. ("LuxOasisOS", "we", "us" or **"or") collects, uses, discloses, stores, and retains personal information in connection with the Platform. This Privacy Policy forms an integral part of, and is incorporated by reference into, the LuxOasisOS Terms of Service (the "Terms"). By creating an account or otherwise using the Platform, you accept this Privacy Policy and the Terms. If you do not accept this Privacy Policy, do not use the Platform.
- Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms. If there is a conflict or inconsistency between this Privacy Policy and the Terms, the Terms govern, except that this Privacy Policy governs the collection, use, disclosure, storage, and retention of personal information.
- Reach our Privacy Officer at support@luxoasisos.com.
This summary is not the whole policy. Read the rest.
1. Who this policy covers
LuxOasisOS operates a software platform that landlords and tenants use to manage their rental relationship. This policy explains how we handle personal information about:
- Landlords who hold an account,
- Applicants who apply for a unit through the Platform,
- Tenants who use the Tenant Portal, and
- Visitors to our website.
"Personal information" means information about an identifiable individual, as Canadian privacy law defines it and It does not include de-identified or aggregated data of the kind.
Who is responsible for what. LuxOasisOS and each landlord are separate organizations under applicable privacy legislation, and each is accountable for the personal information under its own control.
We are accountable for personal information under our control, which includes personal information collected through the Platform, held in our systems, or received through our communications with landlords, applicants, and tenants. We are responsible for safeguarding that personal information while it is under our control, for limiting our collection, use, and disclosure of it to the purposes described in this Privacy Policy, and for requiring the service providers we engage to protect it to a comparable standard.
A landlord is accountable for personal information under its own control, including information it collects or holds outside the Platform, any credit check, background check, or reference check it arranges itself, and its handling of an application after we deliver it. A landlord may maintain its own privacy policy and privacy practices, which govern that handling; this Privacy Policy does not. We do not control a landlord's privacy practices and are not responsible for them. Direct any question about how a landlord handles your personal information, or any request to access or correct information a landlord holds, to that landlord.
Applicable privacy law. We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where it applies to our activities, substantially similar provincial legislation, including the Personal Information Protection Act (Alberta) and the Personal Information Protection Act (British Columbia). Where provincial legislation governs our handling of personal information in a province or territory, we comply with that legislation in addition to or in place of PIPEDA, as that legislation requires. Nothing in this Privacy Policy limits a right you have under applicable privacy legislation.
2. What we collect
From landlords
- Identity and contact. Name, email, phone, mailing address, and business registration details. Where we verify your identity, we use Stripe Identity to do so — your government-issued identification document goes to Stripe and is not stored by us or on the Platform.
- Personnel and authorized representatives. Where the account holder is a corporation, partnership, or property management company, the name, business email, phone number, job title or role, and account permissions of each individual authorized to use the Platform on the account holder's behalf, and a record of which of them took a given action in the account. If you provide us with an individual's personal information, you confirm that you are entitled to do so and that you have made that individual aware of this Privacy Policy.
- Property. Addresses, unit details, photos, listing content, and proof of ownership or authority.
- Listing Studio media. Where you book an on-site photography, video, or virtual staging visit (Edmonton and the surrounding area only), the raw and finished photos and video from that visit, and scheduling and access details you give us to arrange it. A shoot can incidentally capture people present, their belongings, or identifying details visible in the unit — tell any occupant before we visit.
- Billing. Your plan, invoices, and payment history. Card numbers go to Stripe and never reach us.
- Activity. What you and your authorized representatives do on the Platform and on our website, including listings posted, applications received, messages sent, searches run, pages and listings viewed, features used, and sign-in and sign-out records.
- Support and communications. Records of your contact with our support team, including email, chat, and telephone calls, the content of those communications, and any attachments or screenshots you send us. Where we record or transcribe a support call, we tell you before the recording begins.
- Device and technical information. IP address, device and browser type, operating system, language settings, and cookie and session identifiers captured when you or your authorized representatives use the Platform or our website. See Section 9.
From applicants and tenants
- Identity and contact. Name, email, phone, date of birth, and current and previous addresses. Where you verify your identity for your Tenant Portal profile, we use Stripe Identity to do so — your government-issued identification document goes to Stripe and is not stored by us or on the Platform.
- Application content. Employment, income, the name and contact information for references, occupants, pets, and anything else the application form asks for.
- Identity documents. Government-issued identification, where a landlord requires it separately as part of your application.
- Tenancy activity. Rent reminders, repair requests, photos you upload, and messages with your landlord.
Automatically, from everyone
IP address, device and browser type, operating system, pages viewed, time on page, referring site, and cookie identifiers. See Section 9.
Referral information
If a User or other person participates in our referral program, we collect the information necessary to administer it, including the referrer’s name, business or practice name, notice address, and any GST/HST registration number or tax residency declaration, withholding waiver application, or similar form we require in order to pay a commission and satisfy our tax withholding and reporting obligations. Where a referrer submits a referral notice, we receive the name and primary contact information of the prospective User identified in that notice. We also retain the referral attribution, commission, and net revenue records necessary to calculate and support amounts payable to a referrer.
What we do not collect
We do not ask for information about race, ethnic origin, religion, sexual orientation, family status, disability, or citizenship. Do not enter it into free-text fields.
3. Why we collect it
We use personal information for these purposes:
- creating and administering accounts, and verifying identity, including showing a "Verified" indicator on a landlord's or tenant's profile to other Platform users once verification is complete,
- publishing listings and syndicating them to rental sites,
- scheduling viewings,
- scheduling and delivering Listing Studio photography, video, and virtual staging where you book that service,
- receiving applications and delivering them to the landlord the applicant applied to,
- sending rent reminders and recording repair requests,
- billing you and collecting subscription fees,
- providing customer support,
- detecting and preventing fraud, abuse, and unauthorized access,
- improving the Platform and understanding how it is used,
- producing aggregate statistics that identify nobody, and
- meeting our legal and regulatory obligations.
We use it for marketing only where you have consented. See Section 8.
We do not sell personal information. We do not rent it, and we do not trade it.
Collected for landlords, not for our own decisions. We collect applicant and tenant information for the benefit of the landlord the applicant applies to — to centralize it in one place and to facilitate the landlord-tenant relationship. We are not a party to the relationship between a landlord and a tenant, and we take no part in any tenancy decision. The Platform does not provide any automated processing to decide anything about you: applications are not scored, ranked, or filtered by our systems, and no algorithm approves, rejects, or recommends anyone. Each landlord applies its own criteria and makes every tenancy decision itself. If you disagree with a decision about your application or tenancy, or want to know the reasons for it, raise it with the landlord. We are not able to explain, review, or reverse any decision made by a landlord.
4. Consent
We collect, use, and disclose personal information with your consent, unless the law permits or requires otherwise.
How you give it. Creating an account, submitting an application, or ticking a consent box. For applications, consent is express and specific: you see which landlord will receive your application before you submit it.
Withdrawing it. You are entitled to withdraw consent at any time by writing to support@luxoasisos.com. We will tell you what withdrawing means in practice. Some withdrawals end a service, since we cannot run an application without the application data. Withdrawal works going forward and does not undo a disclosure we already made.
Where consent is not needed. Canadian privacy law permits collection, use, or disclosure without consent in limited situations, including where a law or court order requires it, where it is necessary to investigate a breach of an agreement or a contravention of law, and in an emergency threatening someone's life, health, or security. We disclose no more than the situation requires.
5. Applications Summaries
We do not run credit checks, background checks, or pull data from any credit bureau, consumer reporting agency, or court database. Applicants submit information directly through the Platform, and that submission is the entirety of what a landlord receives from us.
Who sees it. The landlord who received the application, and nobody else. We do not share an application with a second landlord, we do not add it to a database other landlords can search, and we do not sell it.
Further checks are the landlord's responsibility. If a landlord wants a credit report, a background check, or a reference check, they arrange it themselves, outside the Platform, with an agency or service of their choosing. Obtaining the applicant's consent and complying with the consumer reporting and privacy law that applies to that check is on them, not us.
If your landlord orders their own check. Your rights to access and correct that data run against the agency or service your landlord used, not against us. We have no access to it and cannot amend its records.
What happens after delivery. Once we deliver an application to a landlord, that landlord becomes responsible for the personal information in it under privacy law. Their retention, their security, their use. We require landlords to use application data only for the application at hand, and we are entitled to close accounts that break that rule. We delete application materials from the Platform in accordance with Section 11 below. Where a landlord records an applicant as a tenant, the information in that applicant's application may instead be ported to a tenant account on the Platform and retained for the duration of the tenancy, after which the retention periods in Section 11 apply.
6. Who we share with
We do not sell Personal Information. We disclose Personal Information to:
Service providers. Companies that run parts of the Platform for us, under contracts limiting them to our instructions. Currently: Stripe for payments and identity verification (Stripe Identity), Auth0 for sign-in and account management, DigitalOcean for infrastructure, Mailchimp for our email newsletter and mailing list signups, Web3Forms to deliver our contact and application form submissions, and, where you book Listing Studio, the photo-editing and virtual staging tools our team uses to produce your images. A current list of our subprocessors, including their function and the country in which they process personal information, is available on our Subprocessors page.
Landlords. An applicant's application goes to the landlord they applied to.
Marketplace providers. Only when you ask us to connect you, and we tell you what we are sending before we send it.
Legal and safety. Where a law, subpoena, or court order requires disclosure, or where we believe disclosure is necessary to prevent serious harm.
A business transfer. If we are acquired or merge, personal information moves with the business. The buyer stays bound by this policy or gives notice before changing it.
We share nothing else. There is no advertising network, no data broker, and no list sale.
7. Where your information lives
Where we store it. We store personal information on servers located in Canada. Our personnel outside Canada. Some of our personnel, including software developers who support the Platform, are located outside Canada, including in Vietnam. Those personnel do not have access to live personal information; they work only in development and testing environments using synthetic, non-identifying data. If our access model changes so that personnel located outside Canada would have access to live personal information, we will update this policy before that access begins and, where the law requires it, seek your consent. Foreign service providers. Where we engage a service provider or contractor located outside Canada, we will do so under a written data processing agreement that limits them to processing personal information on our instructions and for the purposes described in this Privacy Policy, requires safeguards comparable to those described in Section 10, requires them to notify us of a breach without delay, restricts onward transfer to their own subcontractors, and requires them to return or delete the information when the engagement ends. Information held outside Canada is subject to the laws of that jurisdiction, and its courts, law enforcement agencies, and regulators may be able to access it under their own legal processes. What applies to you depends on where you are. The Platform is available across Canada, and the rules governing personal information that leaves your province or the country differ from province to province. Our Privacy Officer is the person able to answer questions about the collection, use, disclosure, and storage of personal information by service providers outside Canada, and can provide written information about our related policies and practices, at support@luxoasisos.com or the address in Section 16. We give this notice in accordance with section 13.1 of the Personal Information Protection Act (Alberta), and we meet the corresponding requirements of the Personal Information Protection and Electronic Documents Act and of any other provincial legislation that applies to you.
8. Marketing messages
We send marketing email only where you have consented, as Canada's Anti-Spam Legislation requires. Unsubscribe using the link in any message or through your notification settings.
Service messages continue after you unsubscribe from marketing. Rent reminders, repair updates, security alerts, and billing notices form part of the service you asked for.
Referral invitations. If someone refers you to LuxOasisOS, the referral message names the person who referred you and explains how they know you. We do not send you anything further unless you sign up or consent.
9. Cookies and analytics
We use cookies and similar technologies for three purposes:
- Strictly necessary. Signing you in, keeping your session, and securing the Platform. These cannot be turned off.
- Functional. Remembering your preferences, such as language.
- Analytics. Understanding how people use the Platform so we can improve it. We use Google Analytics.
Manage non-essential cookies through our cookie banner or your browser settings. Turning off strictly necessary cookies breaks parts of the Platform.
We honour Global Privacy Control signals where your browser sends one.
10. How we protect your information
We use technical and organizational safeguards appropriate to the sensitivity of the information, including logging and monitoring, and an incident response plan.
No system is completely secure. We cannot guarantee absolute security, and you play a part too: use a strong unique password, keep your credentials private, and tell us immediately if you suspect unauthorized access.
If a breach happens. We will report it to the Privacy Commissioner of Canada and to any other regulator with jurisdiction, and we will notify affected individuals, within the timelines the applicable statute sets. We keep records of breaches as the law requires.
11. How long we keep information
| What | How long |
|---|---|
| Account records | 2 years after closure |
| Listings | While the account is open |
| Listing Studio raw photos and video | While the account is open, so you can reorder edits or virtual staging without a new shoot |
| An accepted application that becomes a tenancy moves into the tenancy file | Duration of the tenancy, then 2 years |
| An incomplete application abandoned partway | 30 days |
| An applicant who asks us to delete their data | 3 business days. Some information may be required to be retained. For example, if their information is relevant to a known active claim as between the applicant against LuxOasis or the applicant against the landlord. |
| Sensitive identity data, such as Government ID, any SIN, banking details | 30 days |
| Application content, including income, employment, references, addresses | 60 days |
| The decision record, including applicant name, unit address, date applied, and outcome | 24 months after the decision |
| Rent and repair records | Duration of the tenancy, then 2 years |
| Billing and tax records | 6 years, as tax law requires |
| Support conversations | 2 years after closure |
| Analytics data | 26 months, aggregated |
We delete or anonymize personal information when we no longer need it for the purpose we collected it, unless a law requires us to keep it longer.
12. Use of Artificial Intelligence
The Platform uses artificial intelligence models, including models operated by third-party AI infrastructure providers under contract with us. Account information is not used to train or fine-tune any underlying AI model. Content is processed by the relevant AI model solely to generate the listing content and is handled in accordance with our Data Processing Agreement and the confidentiality commitments of our AI infrastructure providers, who covenant that they restrict using that content to train models for other customers.
13. Your rights
You are entitled to:
- See what we hold. Ask for access to your personal information and information about how we have used and disclosed it.
- Correct it. Ask us to fix anything inaccurate or incomplete.
- Withdraw consent. See Section 4.
- Take it with you. Ask for a copy in a structured, commonly used technical format.
- Ask us to stop. Request deletion or de-indexing where the law provides for it.
- Complain. See Section 16.
How to ask. Write to support@luxoasisos.com. We will respond within 30 days. We may ask for identification before we act, so nobody obtains your information by pretending to be you.
When we say no. We are permitted to refuse a request where the law allows, including where granting it would reveal another person's personal information or breach legal privilege. We will explain why and tell you how to challenge the decision.
Access is free unless a request is repetitive or excessive, in which case we will tell you the cost before we proceed.
13. Children
The Platform is for adults. We do not knowingly collect personal information from anyone under 18. If we learn we have, we delete it. Contact us if you believe a minor has given us information.
14. Changes to this policy
We will update this policy as the Platform changes. Material changes come with 30 days' notice by email and a posted update. Continuing to use the Platform after the effective date means you accept the change.
15. Contact and complaints
13707245 Canada Inc. o/a LuxOasisOS support@luxoasisos.com
Bring a concern to us first. We will investigate and respond in writing.
If you are not satisfied, you are entitled to complain to a regulator:
- Office of the Privacy Commissioner of Canada, priv.gc.ca
- Office of the Information and Privacy Commissioner of Alberta, oipc.ab.ca
- Office of the Information and Privacy Commissioner for British Columbia, oipc.bc.ca
Language. We publish this policy in English and French for convenience. Where the two versions conflict, the English version governs.