PRIVACY POLICY
Welcome!
Welcome to Reservit.ca! We hope that you will appreciate using our “Services”, which includes visiting our “Website” at https://www.reservit.ca/en, including all subpages and subdomains, or using our
software “Platform” that allows our “Clients” (which include various tourism establishments, restaurants and experience providers) to manage their online activities, bookings and reservations. The
Platform also allows Clients to connect with various “Partners”, which include numerous third-party integration and software service providers, to enhance their use of the Platform and their relationship
with End Users (as defined below).
This Privacy Policy (the “Policy”) covers personal data collected from you or about you when: (1) you are using or visiting the Website; (2) you are a “Client Representative”, meaning that you work for a Client
who has signed a Reservit License Agreement with us and you may have an account to access the Platform; (3) you are a “Partner Representative” who has received access to the Platform from a Client;
(4) you are making a reservation with one of our Clients from their website, which integrates our Platform (an “End User”); or (5) you have otherwise interacted with us in various ways.
Reservit takes your privacy and security of personal data very seriously. We have provided and will continue to provide a secure environment and this Policy describes the limited ways your information is
used and the limited access to such information. We ask that you read it carefully.
Key Elements of This Policy
Here are the key elements of this Policy so that you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal data. By submitting any personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.
| Personal data we collect from you but only with your consent | What we do with it | Third parties we share it with |
|---|---|---|
| Prospective Client Information | Contact you about our Services | Brevo, our email service provider |
| Prospective Partner Information | Contact you about becoming a Partner | Brevo, our email service provider |
| Client Representative Account Information | Manage your account and enable logging into the Platform | Companies providing the technical infrastructure for the Platform; companies providing email services; Partners that a Client has selected as a collaborator |
| End User Information | Share it with Clients with whom you have made a reservation |
Companies providing the technical infrastructure for the Platform; companies providing email services; Clients with whom you have made a reservation; Stripe, the payment processor for End User transactions |
Some Terms
Before we get started with the details, here are a few terms we think you should know as you read this Policy.
“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. Reservit is committed to adhering to all applicable Data Protection laws.
The Data Protection Laws include: (1) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) ) the “UK GDPR” which applies to our activities in the United Kingdom; please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR as applicable; (3) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our activities in Canada; and (4) Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (the “Quebec Privacy Act”) as amended by Law 25, that applies to our activities in Quebec.
“Personal data” – this is information that we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA and the Quebec Privacy Act, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information.
About Us and Contacting Us
Softbooker Technologies Inc., who owns and operates the Website, Platform and Services in Canada, is a Quebec corporation located in the province of Quebec, Canada with an office at the address listed below.
Softbooker Technologies Inc. licenses the Reservit Platform and software from Interface Technologies (“Interface”), a company based in Marseille, France and the owner of the Reservit Platform and software. All personal data collected by Softbooker Technologies Inc., as detailed in this Policy, is available to Interface and processed in accordance with its own privacy policy (available here) and all applicable Data Protection Laws. The Platform is partially hosted at Interface’s premises in La Penne-sur-Huveaune, Marseille, France and partially hosted by Jaguar Network at a separate data centre in Marseille, France.
In this Policy, Softbooker Technologies Inc. will be referred to as “Reservit” and, wherever this Policy refers to Reservit, it may refer to Softbooker Technologies Inc. and/or its affiliates, and their respective shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns (collectively “Representatives”), depending on the context. Any reference to “we”, “our”, or “us” in this Policy shall also refer to Softbooker Technologies Inc. In this Policy, a Website visitor, Client Representative, Partner Representative, End User or any other individual for whom we hold personal data may be referred to as “you” or “your”.
Under the GDPR, Reservit is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means the collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way. Sometimes, Reservit acts as a “data processor” when we collect personal data on behalf of Clients and process it on their behalf, for example, when collecting End Users’ personal information in connection with a reservation and then transferring that personal information to the applicable Client.
Under PIPEDA, Reservit is an “organization”, and under the Quebec Privacy Act, Reservit is an “enterprise”. PIPEDA uses the phrase “collection, use and disclosure” and the Quebec Privacy Act uses “collects, holds, uses or communicates to third parties” as the rough equivalent to the “processing” of the GDPR. When we use “processing” in this Policy, you can substitute either of those phrases.
If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can contact:
Reservit Privacy and Data Protection Officer – Thibault Nahon
or:
Reservit Privacy and Data Protection Officer – Thibault Nahon
384 Avenue Laurier Ouest,
Montreal, Quebec, H2V 2K7
Canada
Your Rights
You have the following rights regarding your personal data held by Reservit, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. Please note that exercising certain of these rights may affect your ability to use some or all of the Website, Platform or Services.
- The right to withdraw your consent for Reservit to process your personal data at any time;
- The right to have your personal data erased from Reservit’s records, and to have your name de-indexed if we link to any information about you (which we currently do not);
- The right to have your personal data erased from Reservit’s records;
- The right to access your personal data and any relevant information around its processing and use;
- The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to any data controller or data processor, as those terms are defined in the GDPR;
- The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
- The right to opt out of marketing communications we send you, at any time;
- The right to know whether Reservit sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy and Data Protection Officer if you need additional information or clarification;
- The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and
- The right to refuse any marketing or advertising targeted at you by Reservit (although we are not currently engaged in any targeted advertising campaigns).
If you wish to exercise any of these rights, please contact our Privacy and Data Protection Officer at the contact information above or refer to certain relevant sections further in this Policy.
Limited Personal Data Collected From You and What We Use It For
Reservit limits the amount of personal data we collect to what is necessary and appropriate for the identified purposes. We will not use or disclose your personal data for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.
In the table below, please find all the personal data that we may collect from you directly, what we use it for and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA and the Quebec Privacy Act, the legal basis is your informed consent and by submitting this personal data to us, you acknowledge having granted this consent to Reservit.
| Personal data category | Personal data processed | What we use it for (the “purpose” of processing) | Legal basis for processing under the GDPR |
|---|---|---|---|
| Prospective Client Information | First name, last name, email address, your affiliation with the prospective Client and, possibly, your phone number | To contact you about our Services and about becoming a Client; to schedule a demo of our Services with you | Your consent in giving us this information |
| Prospective Partner Information | First name, last name, email address, your affiliation with the prospective Partner, and, possibly, your phone number | To contact you about our Services and about becoming a Partner; to schedule a demo of our Services with you | Your consent in giving us this information |
| Referral Program Information | First name, last name, email address, phone number, your affiliation with a Client or a prospective Client | To acknowledge a Client or a prospective Client as a participant in the Reservit Referral Program; to contact you about the Reservit Referral Program | Your consent in giving us this information |
| Client Representative Account Information | First name, last name, email address, your affiliation with the Client and, possibly, your phone number | To create your account so that you can access the Platform; to manage your account and enable logging into the Platform | Your consent in giving us this information; performance of a contract between us and a Client |
| End User Information | First name, last name, email address, phone number, country of residence and, depending on the nature of your reservation, a credit/Visa debit card number, credit/Visa debit card holder name, CVV number and postal code/zip code Each Client may also request additional personal data from End Users, depending on the nature of the tourism establishment, restaurant or experience provider and whether you are booking lodging or an activity. For example, you may be asked to provide your home address, billing address, age, weight or the personal data of other people staying with you or participating in the activity with you | To communicate with you about your reservation | Performance of a contract between us and a Client |
For Client billing purposes, note that we do not collect any billing or payment information from you directly. We use GoCardless to facilitate Client payments for our Services and access to the Platform. Clients provide any necessary personal data and billing information directly to GoCardless via a unique Client link and Reservit does not receive or process any personal data from you in connection with this process.
Personal Data Collected About You from Third Parties and What We Use It For
Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from, what we do with it, and the legal basis for us having and processing this personal data under the GDPR. Under PIPEDA and the Quebec Privacy Act, the legal basis is your informed consent which you gave to the third party who collected it. None of this data comes from publicly available sources.
| Personal data category | Personal data processed | Who we get the data from | What we use it for (the “purpose” of processing) | Legal basis for processing under the GDPR |
|---|---|---|---|---|
| Client Representative Account Information | First name, last name, email address, your affiliation with the Client and, possibly, your phone number | Your employer (or the company for which you provide services), who can create an account on the Platform for you | To create your account so that you can access the Platform | A company’s legitimate interest in setting up accounts for its employees and contractors |
| Partner Representative Account Information | First name, last name, email address, your affiliation with the Partner and, possibly, your phone number | A Client, who can create an account on the Platform for Partner Representatives | To create your account so that you can access the Platform | Performance of a contract between us and a Client |
| Client Billing Contact Details | First name, last name, email address, your affiliation with the Client | To have a designated Client contact for billing purposes; to communicate with a Client about billing details and questions | Performance of a contract between us and a Client |
In addition, to the extent that analytics identifiers are generated from third parties, these may be considered personal data collected from third parties and you can find details about those further below in this Policy.
Sensitive Personal Data
We do not collect any of what the Data Protection Laws consider sensitive personal information from you when you use or access the Website, unless you voluntarily submit it via one of our Website’s forms, which we encourage you not to do. A Client may request sensitive personal data from you when you make a reservation with such Client. In such case, the relevant Client will treat your sensitive personal data in accordance with their own privacy policy, which we encourage you to read in detail, and all applicable Data Protection Laws.
Who We Transfer Your Personal Data To
We only share some of your personal data with third parties who are identified in the table below in this section, along with what they do with it.
We will share personal data with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person; (3) we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website, Platform or Services infrastructure or the internet in general (such as voluminous spamming or denial of service attacks); or (4) we are required to under any applicable law.
We may also share personal data: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with Reservit (in which case we will require such entities to honour this Policy); (2) if Reservit merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case, we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).
Some of these third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area or the U.K., please see the “Transfer of Your Personal Data Outside of the European Economic Area” section further down in this Policy for more information, including on how we safeguard your personal data when this occurs. If you are in Quebec, please see the “Transfer of Your Personal Data Outside of Quebec” section further down in this Policy for information on how we safeguard your personal data when this occurs.
We will never share your personal data with other third parties except under these circumstances. We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose.
| Personal data category | Who we transfer it to | What they do with it |
|---|---|---|
| Prospective Client Information |
Store it; keep it for record-keeping purposes
Send you emails |
|
| Prospective Partner Information |
Store it; keep it for record-keeping purposes
Send you emails |
|
| Referral Program Information | Store it; keep it for record-keeping purposes | |
| Client Representative Account Information |
Interface and Jaguar Network, who host the Platform and provide the technical infrastructure for the Platform
The Partner(s) that a Client has selected as a collaborative tool or software to use in connection with the Platform
Companies that provide email services, specifically Brevo, as detailed more fully in the Email Communications section below |
Store it; keep it for record-keeping purposes
Communicate with you about the Partner-Client integration
Send you emails |
| Partner Representative Account Information |
Interface and Jaguar Network, who host the Platform and provide the technical infrastructure for the Platform |
Store it; keep it for record-keeping purposes |
| End User Information |
Interface and Jaguar Network, who host the Platform and provides the technical infrastructure for the Platform
The Client with whom you are making a reservation. (Clients will have their own privacy policies, which describe how they use the personal data that we share with them. We encourage you to review the privacy policies of Clients with whom you make a reservation)
Certain Partners, if the applicable Client has chosen to make End User information available to certain Partners using the Platform
Companies that provide email services, specifically Interface, as detailed more fully in the Email Communications section below
Stripe, the payment processor for End User transactions |
Store it; keep it for record-keeping purposes
Confirm your reservation; communicate with you about your reservation
Facilitate your reservation; follow the instructions of the applicable Client
Communicate with you about your reservation
Process the payment for your reservation |
| Analytics identifiers and related information, including IP address |
Companies that provide data analytics for the Website and the Platform, specifically Google Analytics, Matomo and Google Tag Manager |
Provide us with analytics about (i) Website visitors and how the Website is used; and (ii) Clients and how the Platform is used, as further detailed in the Limited Gathering of Information section below |
Email Communications and Compliance with Anti-Spam Laws
Reservit uses Brevo to (i) send emails to Clients and to prospective Clients who have signed up to receive our newsletter; and (ii) send emails related to the Services and the Platform. Reservit uses Interface to send emails to End Users related to their reservations. Personal data is transferred to Brevo and Interface, our “Email Service Providers”, in order for the emails to be sent out properly. Your email address is only used to send out emails; the Email Service Providers do not use this personal data for any other purpose and will not transfer or sell your personal data to any other third party. For more information, please refer to Brevo's Privacy Policy and Interface's Privacy Policy.
You may unsubscribe from the Reservit newsletter list at any time by following the link at the bottom of our newsletter emails or by responding to one of our emails with a request to unsubscribe. Other types of emails, such as emails related to the Platform, the Services and any reservations, will not have an opt-out option as they are necessary for the use of the Services.
Reservit’s practices with respect to its email are designed to be strictly compliant with anti-spam laws, including, but not limited to, the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of this law, please contact our Privacy and Data Protection Officer using the contact information further up in this Policy.
Limited Gathering of Information for Statistical, Analytical and Security Purposes
Reservit automatically collects certain information using the “Third-Party Analytics Programs” from Google Analytics, Matomo and Google Tag Manager to help us understand more about Website visitors and Clients and how they use the Website and the Platform, but none of this information identifies you personally, except via an alphanumeric string. For example, each time you visit the Website or the Platform, we automatically collect (as applicable) your IP address, browser and computer or device type, access times, the web page from which you came, the web page(s) or content you access, and other related information. We use information collected in this manner only to better understand your needs and the needs of Website visitors and Clients in the aggregate. Reservit also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website and the Platform, the specific pages visited on the Website and the Platform, and the number of Website visitors and Client Representative/Partner Representative log-ins, with a view to introducing improvements to the Website, Platform and our marketing activities.
Your IP address and other relevant information we collect using the Third-Party Analytics Programs may be used in order to trace any fraudulent or criminal activity.
Tracking Technology (“Cookies”) and Related Technologies
Reservit uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) on the Website, Platform and in emails. Cookies are small text files placed on your computer or device when you visit a website in order to track the use of the site and to improve the user experience by storing certain data on your computer or device. More specifically with respect to emails, Brevo uses pixels in the emails that it sends on our behalf in order to determine whether you open an email that you receive from us and whether you click on any links included in the email. By visiting or using the Website or the Platform, you agree to the use of cookies and related technologies, but only if you explicitly consent to such use, according to the cookie banner presented to you when you visit the Website or the Platform. By default, all non-essential cookies are turned off when you first visit the Website and the Platform – you can use our cookie management tool to accept or decline other categories of cookies.
Specifically, we use cookies and related technologies for the following functions:
- to provide general internal and user analytics and to conduct research to improve the content of the Website, Platform and Services, and to monitor the performance of the Services, using the Third-Party Analytics Programs as described above in this Policy;
- to facilitate your logging in to the Platform;
- to facilitate the proper functioning of the Services;
- to track information about emails you receive, for example whether you open a given email; and
- to assist in identifying possible fraudulent activities.
Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:
Please note that deleting these cookies may reduce your user experience on the Website or Platform. Furthermore, deleting cookies may prevent certain functions from working at all.
How We Protect Your Personal Data
We have implemented very strict technical and organisational procedures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way. Examples of such procedures include restricted access to offices, training of personnel, using passwords and well-defined internal policies and information technology practices.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws require us to do so and within the time frame required by the applicable Data Protection Law.
Reservit uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Website and the Platform, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Reservit uses OVHcloud for hosting of the Website and all related data, which has a robust security program that you can read about here.
All information, including personal data, when transferred via the Website or the Platform, is done with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer. You can use your browser to check Reservit’s valid SSL security certificate on the Website and the Platform.
Internal Procedures and Policies
In addition to the measures to protect your personal data described in the previous section, we have drafted and implemented certain internal procedures and policies regarding personal data, including the following:
- A framework for the keeping and destruction of the personal data that we collect, including where we may keep anonymized data;
- Defining and describing the roles and responsibilities of the members of Reservit personnel throughout the life cycle of the personal data;
- A process for dealing with individual complaints and requests for personal data and exercising of the individual’s rights under Data Protection Laws; and
- A management strategy for addressing potential data breach incidents involving personal data in the custody of Reservit.
Transfer of Your Personal Data Outside of the European Economic Area (“EEA”) and the U.K.
For our European Website visitors, we endeavour to keep your personal data inside the EEA or the U.K. (as applicable). However, certain of our data processors (and Reservit) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:
- We will transfer personal data to our operations in Canada, but Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law.
- The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA and the U.K.
That’s it! You have the right, however, to refuse to have your data transferred outside the EEA or the U.K. Please contact our Privacy and Data Protection Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Website or the Platform.
Transfer of Your Personal Data Outside of Quebec
For our Quebec Website visitors, Client Representatives and End Users, we endeavour to keep your personal data in Quebec. However, certain of our third-party service providers are in other provinces or countries where your personal data may be transferred. When this happens, we do the following to safeguard your personal data:
- We will perform what the Quebec Privacy Act calls an “Assessment of the privacy-related factors” (what is generally called a “Privacy Impact Assessment,” or “PIA”) prior to the personal data leaving Quebec. If the PIA does not meet our standards and the standards required by the Quebec Privacy Act, we will not transfer your personal data to such a service provider; and
- If the PIA allows us to transfer the personal data to such a service provider outside Quebec, we will sign what is generally called a “Data Processing Agreement,” or DPA, with the service provider, which protects the personal data transferred to them and limits their use of it to what we have contracted with them to do. This DPA will adhere to the requirements of the Quebec Privacy Act.
Supervisory Authorities and Complaints
If you are in the EEA or the U.K., under the GDPR, you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy and Data Protection Officer, or if you would like to make a complaint directly about Reservit’s data practices, we invite you to contact the supervisory authority in your country. For example, if you are in the U.K., you should contact the Information Commissioner’s Office, who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l'Informatique et des Libertés which is the supervisory authority there. Their contact information can be found here. The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here.
If you are in Canada and you are not satisfied with the response received or the actions taken by our Privacy and Data Protection Officer, you can make a complaint to the Office of the Privacy Commissioner of Canada. Instructions on how to do so can be found on their website. In Québec you can make a complaint to the Commission d’accès à l’information, with the instructions for contacting them on their website.
Data Retention
Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your Client Representative Account Information for as long as the company that you work for or to which you provide services maintains a license agreement with us for access to the Platform.
We may have to keep your data for a longer period of time to satisfy our requirements under any applicable law, including anti-spam laws, or to protect our legal interests.
In some cases, where permitted by the Data Protection Laws, we may keep personal data that has been anonymized, for our legitimate business purposes.
Automated Decision-Making
Reservit does not use any automated decision-making processes regarding your personal data in providing the Website, the Platform or the Services.
Children’s Privacy Statement
The Services are only intended for persons who are 18 years old for a resident of a Canadian province or the age of majority in any other country.
The Data Protection Laws have various age limits as to the minimum age required for us to hold personal data about an individual. We do not knowingly collect any personal data from a child under those minimum ages. If we become aware that we have inadvertently received personal data from a person under the minimum ages through the Website, Platform or Services, we will delete such information from our records.
Changes to this Privacy Policy
The date at the top of this page indicates when this Policy was last updated. Because Data Protection Laws are constantly evolving, every now and then we will have to update this Policy. You can always find the most updated version at this URL. If we make significant changes to the Policy, we will always post a notice on the Website and, if you are a Client Representative, we will notify you the next time that you log in to the Platform and provide you with the updated Policy at that time.
© Softbooker Technologies Inc., 2023