Introduction

2749103 Ontario Ltd. (“StayHi”, “we”, “us”, “our”) cares about privacy and is committed to protecting the personal and business information that users share and/or store with us. This Privacy Policy governs the manner in which StayHi collects, uses, processes, maintains, and discloses your personal information. This Privacy Policy covers our privacy practices in relation to your access to and/or use of our website (the “Website”), including when you communicate with StayHi or other users on the StayHi platform and use applications on the Website (the “Services”), or when you provide StayHi with personal information in any other manner.

Information We Collect

Information Necessary to Access the Website and Services

Users who do not have an account with StayHi are able to visit the Website anonymously, but you will be required, due to promotional restrictions on cannabis, to confirm that you are of legal age to possess cannabis in your jurisdiction of residence before you are permitted to access the Website.

Information You Provide that is Necessary for the Use of the Website and Services

We will ask for and collect the following information about you when you sign up to use StayHi Services by opening an account. This information is necessary for StayHi to provide its services to Hosts, Guests, and users.

• Account information – when you sign up for a StayHi account, we will require certain personal information, including your first and last name, email address, password, date of birth, phone number, province of primary residence (as indicated on your government issued identification) and profile picture.

• Identity verification and authentication information – in order to foster a trusting environment, and in order to promote compliance with various legal obligations, we may collect identity verification information, including images of your government issued identification, or other authentication information, in accordance with applicable laws.

• Financial and payment information – in order to use certain Services on the StayHi Website, you will be required to provide financial information, including credit card information. The financial and payment information is used to facilitate the processing of payments between Hosts and Guests. StayHi may require verification of certain identifying information in order to process payments and provide payment services to you, in compliance with the applicable laws.

• Communications with StayHi and other users – your communications on the Website, whether with StayHi, other users, Guests or Hosts, are collected by StayHi.

Additional Information That You Choose to Provide to Us

• Additional profile information – in addition to the necessary information outlined in the preceding section, you may choose to provide additional information as part of your StayHi user profile, including your social media addresses, employer or school, gender, preferred language(s), city/location, education level, certifications, association memberships and other biographical information including a personal description. Some or all of this information (depending on your profile settings and choices) will be publicly available on your public profile page and will be publicly accessible and visible to other users.

• Other information – You may also choose to provide us with additional information, such as address books or contacts, information from promotions, communications, or surveys, or through communications with StayHi, or any other information you choose to disclose.

Information We Automatically Collect Upon Your Use of the Website and Services

When you use the StayHi Website and associated Services, we automatically collect personal information about the Services you are using and the manner in which you use them. This information is necessary for the delivery of our Services to you, as well as to enable StayHi to comply with legal obligations and to further our legitimate interest in providing and continually improving the StayHi Website and Services that we offer to you.

• Geo-location information – We may collect information about your location when you access or use the Website and Services in order to provide an enhanced user experience – this collected information may include your precise or approximate location as determined through your IP address or mobile device’s GPS.

• Usage data – StayHi will collect information about your interactions with the Website and Services, including pages or content you view, your searches, bookings you have made, and other actions on the StayHi Website.

• Log data – StayHi will automatically collect log information and data when you access the Website or use Services, even if you have not created a StayHi account or logged in. This information includes details about your use of the Website and Services, your IP address, length of use of the Website and Services, the frequency of your visits, various hardware and software information, unique device identifiers, device event information, such as crash data and cookie data, and the page(s) you visited or interacted with before or after visiting the StayHi Website and Services.

• Cookies (and similar technology) – When you access StayHi’s Website and use StayHi’s Services, we (including companies we work or partner with) will use cookies and other similar technologies to collect certain information and may place small data files on your computer or other device, which may be or include cookies, clear gifs, pixel tags, e-tags, browser analysis tools, server logs, and mobile identifiers. In many cases, the information collected through cookies and other technologies is used in a non-identifiable manner without reference to the user’s personal information. In other cases, we may use the information collected using cookies and other technology in association with your personal information. Our business partners may also use these tracking technologies. Third parties, including Facebook and Google, may use cookies and other technologies to collect and receive information from our Website and elsewhere on the internet, and to use that information to provide services and targeted advertisements.

  • Users can opt-out of the collection and use of information for ad targeting by updating their account settings or by contacting hi@stayhi.com with a description of your request and the necessary validation information. At this time, the StayHi Website does not respond to “Do Not Track” signals in the HTTP header from your browser or mobile application.

Information We Collect from Third Parties

StayHi may collect information, including personal information, that other users provide about you when they access the StayHi Website or use StayHi Services, as well as obtain information from other sources that we combine with our information collected through StayHi.

• Third party services – If you opt to log in to our Website through a third-party service or website (such as, Google or Facebook), the third-party service may send us information, including your registration and profile information from that service, friend list, and other profile information from that service. This information that we receive from third-party providers varies and it is controlled by that specific service or website in accordance with your privacy settings at that specific service or website. By associating an account managed by a third party with your StayHi account and authorizing StayHi to have access to this information, you agree that StayHi may collect, store, and use this information in accordance with this Privacy Policy. StayHi is not responsible for how third parties use and share your information, and you should refer to those third parties’ policies to understand how they use and share your personal information.

• Reviews – If another user has submitted a reference pertaining to your account, whether as a Host or a Guest, it will be published on your StayHi profile.

• Background information – to the extent permitted by applicable laws, StayHi may obtain reports from public records of criminal convictions or local versions of background checks and/or registered sex offender registrations. We may use your information, including your full name and date of birth, to obtain such reports.

• Referrals – If you are invited to StayHi, the person who invited you may submit personal information about you, including your email address or other contact information.

• Other sources – To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, fraud detection information, safety-related data from third-party service providers and/or partners, and combine it with information about you that we have about you.

How We Use the Information We Collect

We may use, store, and process personal information to provide and improve our Website and Services, and to ensure that the Website and Services are developed and maintained in a secure and safe way to create a trusted experience for the user. We may use your information:

• To provide, improve, and develop our Website and Services, including to:

  • Enable you to access and use the StayHi Website and Services, and to communicate with other users;

  • Provide customer support;

  • Analyze and improve the Website and Services provided by StayHi;

  • Send users support and administrative messages, reminders, updates, security alerts, technical notices, and account notifications;

  • Personalize or customize your StayHi experience;

  • Facilitate your use of StayHi through third-party service providers, such as Google and Facebook;

  • Enhance your use of StayHi through the use of third-party service providers, such as SUPERHOG, StayHi’s official trust and safety provider (www.superhog.com)

  • Process contact information of other non-StayHi users (if you choose to provide such information to StayHi or its associated third-party service providers) in order to facilitate your referral invitations, send your requests for reviews, for fraud detection and prevention, and for any other purpose you authorize at the time of collection; and,

  • Provide referral programs, rewards, surveys, contests, or other promotional activities or sponsored events.

• To further our legitimate interest in improving the StayHi Website and Services: we may use this information to analyze and improve our Website and Services in order to develop and implement new products and services to improve your experience.

• To send you marketing and/or promotional communications: we may send you StayHi-related marketing and communications as permitted by law. Our third-party partners may also send you social media advertising through social media platforms, such as Facebook or Google. We may also administer referral programs, rewards, and surveys, as well as conduct profiling of your characteristics and preferences to send you promotional messages that may be of interest. You have the ability to opt-out of marketing and promotional communications as described in the “Opting out of marketing” section of this Privacy Policy.

• To create and maintain a secure, safe, and trusted user experience, including to:

  • Detect, prevent, or remedy fraud, abuse, security incidents and any other potentially harmful, prohibited, or illegal activities;

  • Verify your identity or authenticate information you provide, including procedures for verification/authentication during account creation and password resets;

  • Conduct security investigation and risk assessments;

  • Comply with our legal obligations;

  • Conduct checks against databases and other information sources, including background checks or police checks, to the extent permitted by applicable laws and with your consent where required;

  • Resolve disputes, collect fees, and enforce our agreements with any third-party partners;

  • Enforce our Terms of Service, including detecting, preventing, and remedying any activities that are not in compliance with our Terms of Service; and,

  • Protect our information technology infrastructure.

• To create anonymous, de-personalized data: we may aggregate, de-identified or other anonymous data from your personal information and from other individuals whose personal information we have collected. When we create this de identified, anonymous data we will remove any information that makes the data personally identifiable to you or any other individual. We may use this anonymous data and share it with third parties for our legitimate business interests in accordance with applicable law, including to analyze and improve the Website and Services and to promote our business.

• To comply with applicable laws: we will use your personal information as we believe necessary or appropriate to comply with applicable law, lawful requests, and any other applicable legal processes, such as to respond to subpoenas or other requests from government or legal authorities.

• With your consent: in some cases, we may ask for your consent to process, use, disclose, or store your personal information.

• We may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

How We Disclose Your Personal Information

You may direct us to share your information or consent to it being shared as described at the time of sharing.

• Profiles, listings, and other public information:

  • The StayHi Website and associated Services always include some basic information necessary for the provision of StayHi’s Services to users, including your username/name associated with your account, your public profile photo, your city/province, and for Hosts, the city where your accommodation is located, your listing description of the accommodation, calendar availability, and reviews and feedback, as well as any other information you choose to make available publicly.

  • Your publicly available Listing may also include aggregate demand information, including the number of page views over a period of time and information about cancellations.

  • In furtherance of StayHi’s legitimate business interests, we allow your public profile and public listing pages to be included in search engines and they may sometimes be posted or promoted on websites or platforms hosted or managed by StayHi’s third-party partners. Your public profile and public listing pages may be indexed by search engines and may be published as search result.

  • In order to further promote your Listings and expand their exposure, we also allow your public profile and public listing pages to be included on partner websites.

• Third-party platforms, advertising, and social media:

  • If you have enabled features or functions that connect StayHi Services to a third-party platform or social media network, such as Facebook or Google, we may disclose the personal information that you have authorized us to share. We do not control a third party’s use of your personal information.

  • Where you have provided consent, we may share your information, including personal information, as described at the time of consent with third parties.

• Sharing between Users, Hosts, and Guests:

  • To facilitate bookings, interactions, and communication between StayHi users, we may share certain personal information with other users, Guests, or Hosts where it is reasonably necessary to facilitate the Services offered by StayHi, as follows:

    • When a Guest requests a booking, certain information about you is shared with the Host, such as: your profile, full name, the full name of any additional Guests, your cancellation history, and other information you have agreed to share;

    • When a Host confirms a requested booking, certain information is shared with the Guest (and any additional Guests they may have invited) to coordinate the booking, such as your profile, full name, phone number, the address location of your accommodation, and any other information that you have agreed to share; and,

    • When a Host uses a third-party provider outside of and unrelated to StayHi, then the Host who shares information about themselves or their Guest(s) is responsible to ensure those third-party service providers are processing that information securely and in compliance with applicable laws.

  • Guests, Hosts, and other users should not share their billing and payment information with other users.

• Service Providers:

  • StayHi may share personal information with vendors and service providers who are engaged by or work with us in connection to the processing of payments, operation of our Services, provision of customer support, and who need access to such information to perform their work or duties for us, including marketing, authentication, background checks, product development and maintenance, insurance, claims administration, customer support, analytics, email, and other various services. Service providers will have limited access to personal information to perform these tasks on our behalf and will be contractually required to protect this personal information and only to use this personal information in accordance with our instructions.

  • Some of our service providers may be collecting information directly from you on our behalf. These service providers will only be permitted to use personal information as directed or authorized by StayHi and will use the information in accordance with the terms of this Privacy Policy or the terms of their own privacy policy which they disclose to you.

• Professional advisors and business transfers:

  • We may disclose your personal information to our professional advisors, such as lawyers, bankers, auditors, insurers, and other professionals where necessary in the course of the professional services that they provide to us.

  • We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or a potential business transaction), such as a corporate divestiture, merger, consolidation, acquisition, reorganization, sale of assets, or bankruptcy or dissolution. In the event that StayHi is involved in a business transaction, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

• Responding to legal requests, protecting our rights, and preventing harm:

  • We may disclose your personal information to courts, law enforcement, government or tax authorities, or other authorized third parties where and to the extent required by law or where such disclosures are reasonably necessary to:

    • Comply with our legal obligations or legal claims against StayHi; ;

    • Respond to a valid legal request relating to a criminal investigation or suspected illegal activity, or any other activity that will expose StayHi, you, or any other user to legal liability;

    • Enforce or administer our Terms of Service; and,

    • Protect the property and personal safety of StayHi employees, its users, Guests, Hosts, or any member of the public.

  • We may also disclose your information as described in this Privacy Policy.

  • StayHi may inform users, Guests, or Hosts about legal request where appropriate, unless doing so is prohibited by the legal request itself, court order, or the applicable law, or if we believe providing notice may create a risk of bodily harm to an individual or group, or create a risk of damage or fraud to an StayHi user’s property.

• Aggregated Data:

  • We may share anonymous, de-personalized aggregated data or information and other anonymized information for regulatory compliance, market analysis, research, demographic profiling, marketing, advertising, and other legitimate business purposes.

You Preferences, Choices, and Rights

In accordance with applicable law, you may exercise the rights outlined in this section by contacting hi@stayhi.com. We may ask you to verify your identity and request prior to taking further action.

• Managing your information

  • You may access and update some of your information through your account settings, and where users have connected through a third-party provider, such as Facebook or Google, you can change your settings or remove permission for the app by changing your account settings. Users are responsible for keeping their personal information up to date.

  • You have the right to ask us to correct inaccurate or incomplete information about you, that you cannot change yourself. You may request a correction of your information by contacting us at hi@stayhi.com. As noted above, we may require you to certify your identity prior to taking further action.

• Communication Preferences

  • StayHi will contact you through email messages at the email address you provide to us. You can control the frequency of how often StayHi will contact you by email and for what purposes in your account settings.

• Opting out of marketing communications

  • You may opt out of marketing-related emails, advertising, or other promotional communications by following the opt out or unsubscribe instructions at the bottom of StayHi emails. If you are having issues with unsubscribing or opting out, please contact hi@stayhi.com for assistance.

• Data accessibility and portability

  • In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us, and you may also be entitled to request copies of personal information you have provided to us in a structured, commonly used, machine-readable format. You may also request us to submit this information to another service provider, where feasible.

• Account closure, data retention, and erasure

  • If you wish to close your account with StayHi, please do so through the Settings tab on your Guest or Host Dashboard. If you experience issues closing your account, please contact hi@stayhi.com.

  • We will retain your personal information for as long as is necessary for the performance of our services and to comply with our legal obligations. We retain and store all of our data on Canadian-based servers.

  • In some jurisdictions, you may request to have all of your personal information permanently erased or deleted. We may retain data to the extent necessary to comply with our legitimate business interest and legal obligations. The information contained within your Listings will be deleted upon account closure, but transaction data will be retained for a period of at least two (2) years. There may be residual information that remains in our databases or records that is not removed.

• Facebook Platform Data, retention, deletion and accessibility policies

  • Unless required to keep Facebook Platform Data under applicable law or regulation, StayHi will to the best of its ability do the following:

  • Make reasonable efforts to keep Facebook Platform Data up to date, including Platform Data that has been modified or deleted. Users will be given an easily accessible and clearly marked way to ask for their Facebook Platform Data to be modified or deleted.

  • StayHi will delete all Facebook Platform Data as soon as reasonably possible in the following cases:

  • When retaining the Platform Data is no longer necessary for a legitimate business purpose that is consistent with these Facebook’s Terms and policies;

  • When Facebook requests StayHib delete the Platform Data for the protection of Users (which Facebook will determine at our sole discretion);

  • When a User requests their Facebook Platform Data be deleted or no longer has an account with StayHi (unless the Facebook Platform Data has been aggregated, obscured, or de-identified so that it cannot be associated with a particular User, browser, or device), or the Client no longer has an account with StayHi:

  • When required by applicable law or regulations.

• Withdrawing consent and objections to processing:

  • Where StayHi is processing your information based on your consent, you may withdraw that consent at anytime by changing your account settings or by sending a specific communication to hi@stayhi.com.

  • In some jurisdictions, the law may entitle you to require StayHi not to process your personal information for certain processes, if you object to StayHi processing this information we will not process it unless we can demonstrate a legitimate reason that such processing is necessary.

• Making complaints

  • Any complaints you have about our privacy practices should be sent to hi@stayhi.com or to a supervisory authority.

Security

We take the safety and security of your personal information seriously, and we employ a number of technical, administrative, and physical safeguards to protect your information against unauthorized access, destruction, use, or alteration while under our control. If you know or have a reason to believe that your StayHi account has been compromised or is subject to unauthorized use, please contact us at hi@stayhi.com.

Other Important Information

This section outlines some additional privacy information related to your use of StayHi’s Website and Services.

• Sensitive information:

  • We ask that you do not send or disclose any sensitive information unless specifically requested, including your social security number, social insurance numbers, passports, information related to racial or ethnic origin, health, sexual orientation, or any other sensitive information that is not necessary for the provision of our Services and has not been requested by StayHi.

• Children’s privacy:

  • Our website requires users to input their age and province of residence to determine their eligibility to access our Website. Our Website and associated Services are not intended for minors or anyone unable to legally possess and consume cannabis in the applicable jurisdiction where they are seeking accommodation.

  • Where a child under the age of 18 has provided us with information, their parent or guardian may contact StayHi for the purpose of deleting this information and closing the account through the Guest Dashboard.

StayHi welcomes questions, feedback, and comments about our privacy practices and what we are doing to protect your privacy. Please feel free to contact us at hi@stayhi.com if you have any questions or comments.