Privacy Policy

Last Updated: 3 November 2018

1 CANLEAD PRIVACY POLICY

Canlead provides an online platform that connects hosts who have business opportunities, solutions and referrals to list and work with leads, leaders, candidates or seekers requesting for such business (collectively, the “Services“), which Services are accessible at https://canlead.io/ and any other websites through which Canlead makes the Services available (collectively, the “Website“) and as applications for mobile, tablet and other smart devices and application program interfaces (collectively, the “Application“).

If you are using the Website, Application or Services and you reside in the UK, these Terms of Service are between you and Canlead Ltd. If you reside outside of the UK, these Terms of Service are between you and Canlead Ireland UC (hereinafter referred to as Canlead Ireland). Canlead Ltd and Canlead Ireland are each hereinafter referred to as “Canlead“, “we“, “us“, or “our“ and Host, Leader, Candidate and Seeker are each hereafter referred to as “user”, “member”, “you”, “they”, “he”, “him”, “she” or “her”.

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your Canlead Account. You can find out more about how to deactivate your Canlead Account at www.canlead.io/help.

2 DEFINITION

Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Opportunity”, “Content,” “Services” etc.), it shall be given its definition as outlined in our our Terms of Service.

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Data Controller” means Canlead, the company responsible for the use and processing of Personal Information.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Canlead.

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

“Cardholder Data” means any personally identifiable information (PII) associated with a person who has a credit or debit card. Cardholder data includes the primary account number (PAN) along with any of the following data types: cardholder name, expiration date or service code.

3 WHAT TYPES OF INFORMATION DOES CANLEAD GATHER ABOUT ITS USERS?

3.1 Information that you give us

We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

·      fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;

·      access or use the Platform, such as to search for or post Opportunities, make or accept bookings, pay for Opportunities, book or pay for any associated services that may be available (such as but not limited to cleaning), post comments or reviews, or communicate with other users;

·      link your account on a Third-Party site (e.g. Facebook and LinkedIn) to your Canlead Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

communicate with Canlead; and

·      share information with another Member.

3.2 Information we get from your use of our Platform

We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

3.2.1 Mobile Data

When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

3.2.2 Contact Information

You may use your contact information, such as your email address, phone number or WeChat account ID to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address, phone number or WeChat account ID, you agree to receive emails to that email address, text messages to that phone number or messages to that WeChat account, as the case may be. We may use your contact information to send you information about our Platform and Services, to market to you, and to help prevent spam, fraud, or abuse.

3.2.3 Log Data

We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Canlead or logged in to your Canlead Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

3.2.4 Cookies and other Tracking Technologies

Canlead uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Canlead services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.

Third Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.

3.2.5 Third-Party social plugins

Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.

3.3 Cardholder data we get from you during payment registration process

We also request for your cardholder information in order to complete the payment registration process. Cardholder information will not be stored in the Canlead mobile application, and will be passed to our payment gateway provider (PayPal) who is a Payment Card Industry Data Security Standard (PCI DSS) Compliance company to store and process payments.

4 HOW CANLEAD USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

We use, store and process information about you for the following general purposes:

·      to enable you to access and use the Platform;

·      to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Booking process;

·      to operate, protect, improve and optimize the Platform, Canlead’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

·      to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

·      to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

·      to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Canlead, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Canlead Account;

·      if a Seeker has an employment or consulting relationship with a company or other organization that participates in the Canlead Business Program, and that Seeker has linked their Canlead Account to that organization, to administer the Canlead Business Program;

·      to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Canlead or our Third Party business partners; and

·      to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

4.1 How Canlead Uses and Processes User Communications

We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Seekers to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Canlead, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

5 WHEN CANLEAD DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM

IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries in accordance with this Privacy Policy.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Platform, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

Canlead Ltd complies with the US-Swiss Safe Harbor Framework and principles, as described in its certification (https://safeharbor.export.gov/companyinfo.aspx?loc=swiss&id=32707).

In addition, if you reside outside of China and you create a Listing in China, book an Opportunity in China or message the Host of a Listing in China, this paragraph applies to you: When you take any action that would result in any transfer, storage, use or processing of your Personal Information in or to China, we will notify you before any such transfer, storage, use or processing is undertaken. We will also notify you if we adopt any practices for China that differ from what is described in this Privacy Policy, including any practices pertaining to disclosures to Chinese government agencies; otherwise all of the provisions of this Privacy Policy will apply.

Your Personal Information may be transferred, stored, used, processed and disclosed as follows:

A.    Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.

B.    Your public Listing page will always include some minimum information such as the city and neighborhood where the Opportunity is located, your listing description, your calendar availability, your public profile photo, your responsiveness in replying to Seekers’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Opportunity’s approximate geographic location on a map, such that a user can see the general area of the Opportunity.

C.   The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.

D.   When you submit a request to book an Opportunity, your full name, and the full name of any confirmed Seekers staying with you, and other Personal Information you agree to pass through to the Host(s) will become visible to the Host(s) of any Listing you Book or request to Book. We may also disclose parts of your public profile; your public Wish List; other Member reviews of you; and any additional information you share with other Members. In addition, if you agree to be contacted by the Host(s) by phone before your request to Book is accepted, and the Host(s) decides to do so, Canlead will call your phone number first, before connecting you with the Host(s). We will not share your phone number unless there is a confirmed booking; if there is a confirmed booking, your phone number will become visible to the Host(s)/Seeker, who may call you directly.

E.    When your request to book an Opportunity is accepted by the Host(s) or when a Seeker books your Opportunity, we will disclose some of your Personal Information to the Host(s) and any confirmed Seeker(s). However, your billing and payout information will never be shared with another user.

F.    If a Seeker books an Opportunity for a business purpose, and the Seeker is engaged or employed by a company or other organization (either or both a “Seeker Affiliated Organization”) that is enrolled in our Business Program, we may disclose the name of the Host and the address and other Opportunity information to the Seeker Affiliated Organization. If the Seeker or the Seeker Affiliated Organization uses any Third Party for business management, financial reporting and/or travel related crisis management services (collectively, “Business Services”), we may also share Host and Opportunity information with those Third Parties and any service providers of those Third Parties who participate in providing such Business Services.

G.   Notwithstanding that you do not reside in China, some of your Personal Information will be transferred to, stored, used and processed by Canlead China in the following circumstances:

a)    When you create a Listing in China, (i) your name and phone number, (ii) all information relating to the Listing including its address, (iii) booking information relating to the Listing (such as Seeker details as set out in paragraph (b) below, booking dates and payment amounts), and (iv) messages between you and prospective and confirmed Seekers at the Listing.

b)    When you book an Opportunity in China, (i) your name and phone number, (ii) booking dates, (iii) messages between you and the Host, and (iv) the names, nationality(ies), passport/national ID number(s) and passport expiry date(s) of the guest(s).

c)    When you send a message to a Host in relation to that Host’s Listing in China, your first name, profile picture and message content via the Canlead platform.

H.   When a Host accepts your request to book an Opportunity, the Host may elect to use Third-Party services available through the Canlead platform to assist with managing the Opportunity, such as cleaning services and lock providers. The Host may use features on the Canlead platform to share information about the Seeker with that Third-Party service provider for the purposes of coordinating the stay or managing the Opportunity, including check-in and check-out dates, Seeker name, Seeker’s phone number, and the Seeker’s anonymized email address.

I.      If you as a Seeker are associated with a Seeker Affiliated Organization, we may share with it information related to your bookings through the Business Program. Further, if you have linked your Canlead Account to a Seeker Affiliated Organization and indicate that a booking is for business purposes, we may disclose your booking information (which may include your Personal Information) to such organization. Typically this information will include your name, dates of the booking, number of guests, cost of the booking, and the address of the booking. In addition, if your Seeker Affiliated Organization has requested that we provide it with information in the event of a dispute, emergency or similar situation involving your bookings through the Business Program, we may notify such organization of the situation and disclose to it any information, including your Personal Information, that we believe in good faith is necessary to safely and quickly resolve or address the situation. If you or your Seeker Affiliated Organization uses a Third Party for travel management, financial reporting, and/or travel related crisis management services, we may also disclose your booking information, or information related to a dispute, emergency or similar situation involving you, to those Third Parties and any service providers of those Third Parties who participate in providing such services.

J.     When a Seeker stays at your Opportunity or when you stay at a Host’s Opportunity, we may ask you to review the Seeker, Host, or the Opportunity. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Seeker or Host may be public on the Platform.

K.    You may link your account on a Third-Party social networking site to your Canlead Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:

·      some of the information you provide to us from the linking of your accounts may be published on your Canlead Account profile;

·      your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;

·      a link to your public profile on that Third-Party social networking site may be included in your Canlead public profile;

·      other Canlead users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

·      other Canlead users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s);

·      the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

·      the publication and display of information that you provide to Canlead through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.

L.    We may distribute parts of the Platform (including your Listing) for display on sites operated by Canlead’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

M.   Canlead may provide your Personal Information to its Affiliates, including Canlead Payments, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. Canlead Payments may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom Canlead Payments has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your Canlead account.

N.   We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

O.   For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Host Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Hosts and Seekers expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Opportunities and Occupancy Taxes, including, but not limited to, personally identifiable information such as Host or Seeker’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Hosts from Seekers, or allegedly due, contact information and similar information, to the relevant Tax Authority.

P.    You acknowledge, consent and agree that Canlead may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Canlead; (b) to comply with legal process (for example, subpoenas and warrants), including legal process associated with national security and law enforcement; (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy, and the Host Guarantee Terms and Conditions; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Canlead, its users or members of the public.

We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

·      providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or

·      we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Canlead’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).

In instances where Canlead complies with legal requests for user data without notice to the user for the reasons described above, Canlead will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

Q.   We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

6 STATE PRIVACY LAWS

For United Kingdom residents: Canlead Payments will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by law.

7 BUSINESS TRANSFERS BY CANLEAD

If Canlead undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

8 HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR CANLEAD ACCOUNT

You may review, update, correct or delete the Personal Information in your Canlead Account. If you would like to correct your information or cancel your Canlead Account entirely, you can do so by logging in to your Canlead Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Canlead Account is cancelled.

9 SECURING YOUR PERSONAL INFORMATION

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

10 YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by Canlead. Canlead does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located at www.google.com/privacy.html), as may be amended by Google from time to time

11 COOKIE POLICY

Canlead uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

11.1 Disabling Cookies

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the the Adobe website and make changes at the Global Privacy Settings Panel.

11.2 Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your Canlead Account.

12 CONTACTING CANLEAD

If you have any questions about these Privacy Policies or any App Store Sourced Application, please contact Canlead.

Canlead Ltd

London, United Kingdom

Registration Number: 10524761

Email: info@canlead.io