This Privacy Policy describes how 15447054 Canada Inc. dba Matcha (“Matcha”, “we”, “us”, or “our”), processes personal information in relation to your use of the Matcha Platform as defined in our Terms of Service. Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

Changes to our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Matcha Platform after the new Privacy Policy takes effect.

1. Personal Information We Collect

The categories of personal information we collect depend on how you interact with the Matcha Platform, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use the Matcha Platform, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Administration. If you register with Matcha to become a user of our platform (“Member”), we may collect personal information in connection with the application and administration of your account including but not limited to name, email address, phone number, physical address, employment background, username/display name, profile and other pictures, photos of your home, your home’s availability, and other information about you or your home.
• Purchases or Transactions. We may collect personal information and details about your purchases or transactions, including payment information. Any payments made via the Matcha Platform are processed by our third-party payment processor, Stripe. We do not directly collect or store any payment card information entered through the Matcha Platform, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about the Matcha Platform, register for our newsletter, request support, apply for a job, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Interactive Features. We and others who use the Matcha Platform may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using public sharing features of the Matcha Platform will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on the Matcha Platform. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Matcha Platform.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use the Matcha Platform, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of the Matcha Platform, such as pages that you visit before, during and after using the Matcha Platform, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use the Matcha Platform.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on the Matcha Platform, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of the Matcha Platform.
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Matcha Platform that collects information about engagement on the Matcha Platform. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
• Analytics. We may use Technologies and other third-party tools to process analytics information on the Matcha Platform.
• Google Analytics. For more information, please visit Google Analytics Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

C. Personal Information Collected from Other Sources

Third-Party Services and Sources

We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access the Matcha Platform through a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings. We may also ask you to give us consent to access information from your social media accounts, such as LinkedIn, to foster a more meaningful network of peers amongst Members. In addition, we may receive fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. Further, where permitted by applicable laws, we may we may engage with a vendor to conduct a background check for use in our trust and safety, fraud prevention and risk assessment efforts. We may receive your name, date of birth, address, and the results of the background check. Our vendor may use U.S. county, state, and federal criminal databases and reports from U.S. agencies to obtain reports of criminal records, sex offender registrations, and other information about your background.

Other Members or Applicants

Other Members may provide us with personal information about individuals who are associated with their use of the Matcha Platform. For example, a Member may provide us with personal information about another Member or non-Member person who is included in their home reservation. Also, we may ask applicants for the name of the Member or other person who recommended the Matcha Platform to the applicant.

Referrals and Sharing Features

The Matcha Platform may offer various tools and functionalities that allow you to provide personal information about your friends, colleagues, or other acquaintances through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague or acquaintance, such as an email inviting them to use the Matcha Platform. Please only share with us contact information of people with whom you have a trusted relationship (e.g., relative, friend, neighbor, or co-traveler).

2. How We Use Your Personal Information

We use your personal information for a variety of business purposes, including to make the Matcha Platform available, for promoting a safe and trusted environment, and to market the Matcha Platform, as described below.

A. Provide Our Services

We use your information to Provide, improve, and develop the Matcha Platform including, but not limited to:

• Managing your information and accounts;
• Validating your employment based on email authentication;
• Displaying information provided in public Listings by Hosts to promote said Host’s Listing;
• Providing or limiting access to particular features of the Matcha Platform;
• Providing technical support including but not limited to triaging to identify bugs and repairing the Matcha Platform;
• Measuring interest and engagement in the Matcha Platform and new features therein;
• Communicating with you about your membership, account, activities on the Matcha Platform, and policy changes;
• Processing your financial information and payment methods through Stripe for transactions completed over the Matcha Platform;
• Processing applications if you apply for a job we post on the Matcha Platform; and
• Research and development activities (including marketing research).

B. Create and Maintain a Trusted and Safer Environment.

We use your information for various purpose to promote a safe and trusted environment, including but not limited to:

• Verifying or authenticating information provided by you;
• Resolving disputes with our Members, including sharing information with your co-Host(s) or additional Guests about disputes related to your role as a co-Host(s) or additional Guests;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Matcha Platform;
• Enforcing our agreements and policies, including with third parties; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements, as permitted by applicable law, including but not limited to:

• Delivering direct marketing campaigns including but not limited to mail campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking;
• Personalizing, measuring, and improving our advertising; and
• Administering referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Matcha or its third-party partners.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent or at your direction.

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as location and demographic information, information about the device from which you access the Matcha Platform, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

3. How We Disclose Your Personal Information

We disclose your personal information to third parties for a variety of business purposes, including to provide the Matcha Platform, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Members
• Members make certain information publicly available for all members, including but not limited to:
• Listing pages that include information such as the Accommodation’s approximate or precise location description, calendar availability, profile photos, aggregated demand information (like page views over a period of time), and additional information Hosts choose to share.
• Reviews, ratings, and other public feedback.
• We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.
• To help facilitate bookings or other interactions between Members (who may be located in, or use service providers located in, jurisdictions with varying levels of data protection), we may share information in situations including but not limited to when:
• A booking is confirmed, additional information is shared to assist with coordinating the trip, such as profile photo and phone number.
• You as a Host have a confirmed booking, certain information is shared with the Guest (and any additional Guests they invite, if applicable) to coordinate the booking.
• You communicate with a Member, such as your name, profile picture, and message content.
• Service Providers. We may share your personal information with our third-party service providers that help us provide the Matcha Platform. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, ID verification, background checks, and related services.
• Third-Party Services. We may disclose your personal information to Third-Party Services (defined below) you share or interact with.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on the Matcha Platform to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. With Your Consent

We may disclose your personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent or at your direction.

We also disclose your personal information for other purposes as requested by you or as permitted by applicable law.

• De-identified and Aggregated Information. We may disclose personal information to create de-identified and/or aggregated information, such as location and demographic information, information about the device from which you access the Matcha Platform, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

D. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

4. Your Privacy Choice And Rights

Your Privacy Choices

The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted marketing-related email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us and the Matcha Platform, and you will not be able to opt out of those communications (e.g., communications regarding the Matcha Platform or updates to our Terms or this Privacy Policy).
• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Matcha Platform may not work properly.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information. Including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request Restriction of or Object to our processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in Section 9 below. We will process such requests in accordance with applicable laws.

Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed we may retain your personal information as is necessary for our legitimate business interests and for compliance with our legal obligations.

5. Security Of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using the Matcha Platform or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Matcha Platform. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Matcha Platform, by mail, or by sending an email to you.

6. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, Canada, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. Children's Information

The Matcha Platform is not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

8. Other Provisions

Third-Party Services

Certain features and functionalities of the Matcha Platform may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). Any information disclosed to or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We do not provide or control any aspect of the Third-Party Services and are not responsible for any compatibility issues, errors or bugs in the Matcha Platform or Third-Party Services caused in whole or in part by the Third-Party Services or any update or upgrade thereto. We encourage our users to read the privacy policies of each Third-Party Service with which they interact. We do not endorse, screen or approve, and are not responsible for such Third-Party Services. Providing information to or interacting with Third-Party Services is at your own risk.

Supervisory Authority

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

9. Contact Us

Matcha is the controller of personal information that is processed under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at [email protected]