Tenant Screening Acceptable Use Policy

On this page

This Tenant Screening Acceptable Use Policy (the "Policy") sets the rules for every business and person that uses the Platform operated by on Carousel Inc. to screen rental applicants — landlords, property managers, brokers and agents, and their teams. It forms part of our Terms & Conditions (the "Terms") and sits alongside our Privacy Policy.

Capitalized terms not defined here have the meanings in the Terms, including "Platform", "Application", "Requesting Party", "Verification Step" and "Verification Result". In this Policy, "you" means the person or business that holds an account on the Platform and acts as a Requesting Party, and "Applicant" means a person you screen through the Platform, including a co-applicant or guarantor.

By creating an account, accepting this Policy when you sign up, or sending a screening, you agree to follow it. If you have signed an agreement with us that includes its own Acceptable Use & Compliance Policy, that schedule continues to apply to you, and this Policy applies to anything it does not cover.

#1. Who This Policy Applies To

• You and your team. This Policy applies to you and to everyone you allow to use your account — employees, workspace members, property managers, and brokers or agents acting for you (your "Team Members"). You are responsible for their use of the Platform, must make sure they follow this Policy, and must remove a Team Member's access promptly if you learn they have broken it.
• Brokers and agents. A broker or agent may use the Platform and its results on behalf of the property owner or landlord it acts for in that rental, and may share results only with people who need them for that tenancy decision.
• Connected apps. This Policy also applies to any software you connect to your account, including your own systems through the Carousel API and AI assistants you connect through Sign in with Carousel. What a connected app does with information it receives is your responsibility as the account that approved it.
• Tenant screening only. This Policy covers tenant screening. A tenant-screening check or result must never be used to screen for employment, lending, insurance, or any other purpose. Carousel's other products are offered under their own terms.

#2. Permitted Purpose

• A real applicant for a real rental. You may use the Platform only to assess a specific, identifiable Applicant who has applied for a genuine prospective tenancy of a unit you own, manage, or act for.
• United States. For a property in the United States, this is the tenant-screening permissible purpose recognized by section 604(a)(3)(F) of the Fair Credit Reporting Act.
• Only what you need. Collect only the information, and run only the checks, reasonably necessary to assess the Applicant as a tenant — for example, their ability to pay rent, their rental history, and their willingness to meet the lease terms.
• One rental at a time. Use a result only for the application it was ordered for. If an Applicant shares an existing Application with you, use it only for the tenancy they shared it for.
• Real listings only. Do not advertise a unit that is not genuinely available, or use any listing, as a way to collect applicants' information.

#3. Applicant Consent

• Consent comes first. Carousel asks each Applicant for consent in its hosted flow — and, where the law requires, for written authorization for a consumer report — before any information is collected or any Verification Step runs. Running a check before consent is not allowed.
• No workarounds. You must not set up or use a workflow in a way that skips, hides or changes the consent step, and you must not run a Verification Step on anyone without their participation.
• Applicants apply for themselves. Do not fill in an Applicant's flow or give consent on their behalf. Each co-applicant and guarantor completes their own flow and gives their own consent.
• You remain accountable. You must have a lawful basis to screen each Applicant. The consent Carousel collects does not replace your own obligations under privacy and consumer-reporting law.
• Notices you owe. Give Applicants any notice the law where the property is located requires before screening — in some US states and cities, for example, your screening criteria and fees.
• Withdrawn consent. An Applicant may withdraw consent at any time. If they do, run no further checks for that Applicant.
• Consent records. Carousel keeps a record of each consent, including the date, time and version of the notice accepted, and can make it available to you on request.

#4. What You May Not Do

Without limiting the rest of this Policy, you must not, and must not let anyone using your account:

• screen anyone who has not applied to rent from you, or use the Platform to look up, monitor, track or compile information about people generally;
• use any result to discriminate on a ground protected by law (Section 5);
• sell, resell, rent, license, publish or otherwise pass results to anyone without a lawful basis — commercial resale or redistribution requires a separate written agreement with Carousel;
• use results for marketing, for building lists or profiles, or for any purpose the Applicant did not consent to;
• share login credentials, or use the Platform on behalf of another business that is not you or one of your Team Members;
• require, or say you require, that an Applicant buy a Carousel screening as a condition of applying (Section 9);
• submit false information, impersonate anyone, or send a screening in someone else's name;
• try to re-identify de-identified data, scrape, probe, reverse engineer or interfere with the Platform, get around usage limits or security controls, or use the Platform to build a competing product; or
• use the Platform in breach of applicable law, including human-rights, fair-housing, privacy, consumer-reporting and consumer-protection law.

#5. Fair Housing and Non-Discrimination

You must not use the Platform, or any result, to treat an Applicant differently on a ground protected by the human-rights or fair-housing law where the property is located. The lists below are a summary, not a complete statement of the law.

5.1 Canada

• Québec (Charter of human rights and freedoms, s. 10): race, colour, ethnic or national origin; religion; sex, gender identity or expression, pregnancy, sexual orientation; civil status; age, except as provided by law; political convictions; language; social condition; a handicap or the use of any means to palliate a handicap.
• Ontario (Human Rights Code, accommodation): race, ancestry, place of origin, colour, ethnic origin; citizenship; creed; sex (including pregnancy), sexual orientation, gender identity, gender expression; age; marital status and family status; disability; receipt of public assistance.
• British Columbia (Human Rights Code): race, colour, ancestry, place of origin; religion; marital status and family status; physical or mental disability; sex, sexual orientation, gender identity or expression; age; lawful source of income.
• Alberta (Alberta Human Rights Act, s. 5): race, colour, ancestry, place of origin; religious beliefs; gender (including pregnancy), gender identity, gender expression, sexual orientation; physical and mental disability; age; marital status and family status; source of income.
• Other provinces and territories. The grounds in the local human-rights law apply.

5.2 United States

The federal Fair Housing Act protects race, colour, national origin; religion; sex (including sexual orientation and gender identity); familial status (including children under 18 and pregnancy); and disability. Many states and cities add further grounds — commonly source of income (including housing vouchers), age, marital status, military or veteran status, immigration or citizenship status, ancestry and, in some places, criminal history — and those bind you for properties there.

5.3 Fair Criteria

• Don't ask about protected grounds. Do not ask questions, or add questions to a workflow, that seek information about a protected ground, unless the law expressly allows it. In particular, do not ask about an Applicant's immigration or legal status in Canada.
• The same rules for everyone. Apply the same screening criteria to every Applicant for the same unit.
• No automatic rejection for a thin file. A limited or missing credit or rental history must not, on its own, disqualify an Applicant who can show they can pay in other reasonable ways.
• Income rules. In Ontario, use income information only together with other permitted information, such as credit checks, credit references and rental history, as Ontario Regulation 290/98 requires — never as a stand-alone cut-off. In the United States, where source-of-income protections apply, base any income requirement on the Applicant's share of the rent after any voucher or subsidy.
• No SIN or SSN requirement. Do not require a Social Insurance Number as a condition of applying. In the United States, do not require a Social Security Number where the Applicant can be screened by other lawful means, and do not reject an Applicant only because they do not have one.

#6. Credit Bureau, Court-Record and Police-Check Rules

6.1 Credit Reports

• Where they come from. Credit reports are produced by a licensed credit bureau, not by Carousel. A credit check may be a hard inquiry that appears on the Applicant's credit file and can affect their score; the flow tells the Applicant before it runs.
• Bureau certifications. Before you receive credit results, Carousel may ask you to confirm your identity and your business and to accept the certifications its credit bureaus require — for example, that you have a permissible purpose and will not use the report in breach of human-rights, fair-housing or equal-opportunity law. Your answers must be true, and you must keep them true.
• Use and sharing. Use a credit report only for the tenancy decision it was ordered for, and never sell it or pass it on.
• Bureau reviews. Credit bureaus may require Carousel to show who requested a report and why. You agree to give us the information and help we reasonably need to answer such a request.

6.2 Court and Eviction Records

• What they are. Court and eviction searches look for public court and tribunal files that match the Applicant's name and, for some searches, date of birth. In Québec, these records come from the official court registers.
• A match is not proof. A file can belong to someone else with the same name. Confirm that it relates to the Applicant before you rely on it, and do not treat a match as proof of an eviction unless the file shows one.
• Not a criminal record check. A Québec court search is not an official criminal record check: pardoned or purged files, and files from outside Québec, will not appear. Do not present it as one.
• A file is not a verdict. An eviction or other court file does not, on its own, disqualify an Applicant. Give them a chance to explain it before you decide.
• Unrelated files. Do not refuse an Applicant because of a court file that has nothing to do with renting, such as a family-law matter or a human-rights complaint they filed.
• Restricted records. Where the law of the property's location restricts the use of eviction or court records, follow it. Carousel may limit or switch off a search in those places.

6.3 Police Checks and Penal Searches

• Use with care. Use criminal-history information only as far as the law where the property is located allows. Do not apply a blanket ban on anyone with a record, and do not refuse an Applicant because of an arrest or charge that did not lead to a conviction. Consider any conviction individually — what it was, how long ago it happened, and whether it matters to the tenancy.
• Fair-chance laws. Where a state or city restricts or bans criminal-history screening, do not run a police check or penal search for that property, or run it only within the limits that law allows.
• Explanations and disputes. Let the Applicant explain any finding, and point them to the provider if they say it is wrong.

6.4 Identity Verification

• Identity only. An identity-verification result confirms whether an Applicant is who they say they are. It is not a consumer report and must not be used to judge creditworthiness, character, reputation or way of life.
• Innocent failures. A failed or inconclusive identity check can have innocent causes, such as a poor photo or an expired document. Give the Applicant a reasonable chance to try again or to verify another reasonable way before deciding against them on that result alone.

#7. Decisions, Accuracy and Disputes

• The decision is yours. You alone decide on each Application. Carousel does not make tenancy decisions or recommend accepting or rejecting anyone.
• Results can be wrong. Results come from third-party providers that Carousel does not control. Do not treat them as conclusive, and check any information your decision depends on before you rely on it.
• A chance to explain. Before a final decision that rests in whole or in part on a result, give the Applicant a reasonable opportunity to explain or correct it. Carousel's consent notice tells Applicants that you will.
• If you decline. If you decline an Applicant based in whole or in part on a consumer report or other result, you must tell them that a report was used and which provider supplied it, so they can check and correct it, and you must give any notice the law requires — in the United States, the adverse-action notice under the Fair Credit Reporting Act.
• Disputes. If an Applicant disputes a result, direct them to the provider that produced it, and reconsider your decision if the information is corrected. Carousel will tell an Applicant which provider produced a result on request.

#8. Handling and Keeping Reports

• Need to know. Share results only with people who need them for the tenancy decision.
• No onward sharing. Do not pass results to other landlords, lenders, employers, data brokers or anyone else, even if the Applicant applies elsewhere. An Applicant who wants to reuse an Application shares it themselves.
• Keep only what you need. Keep results only as long as you need them for the tenancy decision and to meet your legal obligations, then delete them. Deleting a screening on the Platform deletes the results stored with it; copies you download, print or export into your own systems are yours to secure and delete.
• Keep them secure. Protect results with reasonable safeguards, and control which of your Team Members can see them.
• Connected apps and AI assistants. Before you let an app or AI assistant read applicant results, make sure you are allowed to share them with it. Turning on results access confirms that you will use them only to evaluate the Applicant and that you are allowed to share them with that app. What the app does with them is governed by its own terms, and you can disconnect it at any time in Developers → Keys.
• Report misuse. If you believe results have been accessed or used in breach of this Policy, tell us promptly at privacy@oncarousel.com and help us address it.

#9. Applicant-Paid Screenings and Fees

• Optional for the Applicant. Where an Applicant can pay for their own Carousel screening, it must stay optional. Do not require it, or say it is required, as a condition of applying.
• Other ways to apply. Accept applications by other reasonable means — for example, documents and information the Applicant gives you directly — and do not refuse to consider an Applicant only because they did not buy a Carousel screening.
• Existing screenings. If an Applicant already holds a valid Carousel screening and shares it with you, accept it rather than asking them to buy a new one.
• Fee limits. If you charge an Applicant any application or screening fee, or pass screening costs on to them, follow the limits that apply where the property is located. Some places do not allow these fees at all.

#10. Security of Your Account

• Accurate details. Keep your account and business details accurate. Carousel may verify your identity, and that you are a genuine landlord or business, before giving you access to some checks or results.
• Your login is yours. Keep passwords and API keys confidential and do not share logins; give each Team Member their own access instead. You are responsible for activity under your account.
• Remove access. Remove a Team Member's access when they no longer need it, and disconnect apps you no longer use.
• Report a compromise. If you think your account or keys have been compromised, tell us right away at privacy@oncarousel.com.

#11. Records, Reviews and Cooperation

• What we record. Carousel keeps records of Applicant consents and of activity on your account, such as screenings sent and apps connected.
• Reviews. Carousel may review how an account uses the Platform to check that this Policy is followed, and may ask why a screening was ordered or how results were used. You agree to answer promptly and accurately and to cooperate with us, our providers and regulators in addressing misuse.

#12. Enforcement: Suspension and Termination

• Suspension. Carousel may suspend or end access for your account, a Team Member or a connected app immediately if it reasonably believes this Policy or the law has been broken, or that continued access creates a security risk.
• Cancelled screenings. Carousel may cancel screenings and refuse service where it reasonably suspects fraud or misuse.
• Breach. A breach of this Policy is a breach of your agreement with Carousel. Where the law requires it, or to protect Applicants or the Platform, Carousel may report misuse to the authorities or to the provider concerned.

#13. Changes to This Policy

We may update this Policy from time to time. Updates are posted here with a revised date, and for material changes we will tell account holders by email or in the Platform before they take effect. The version in effect when you send a screening governs that screening.

#14. Contact

on Carousel Inc.
5101 rue Buchan, Suite 210, Montréal, Québec H4P 1S4, Canada
Email: privacy@oncarousel.com