Privacy Policy

Effective date: 2024-10-17

TABLE OF CONTENTS

1. Introduction and Scope
2. Definition of “personal information”
3. Personal Information We Collect
4. How We Use Your Personal Information
5. With Whom We Share Your Personal Information
6. Cross-border Transfers
7. Your Privacy Rights
8. How to Exercise Your Rights
9. Third Party Links
10. Retention
11. Security Safeguards
12. Updates to this Policy
13. Contact Us

Introduction and Scope 

This Privacy Policy (the "Policy") outlines the practices of Stay22 Inc. (hereinafter referred to as "Stay22", "we", "our", or "us") regarding the processing of your personal information, as defined in the Definition of "personal information section below. Specifically, the purpose of this Policy is to explain how and for what purposes Stay22 collects, uses, shares or otherwise processes your personal information and how we safeguard the confidentiality of your personal information when you visit our Website ("Website"), create or log into a Stay22 Hub Account ("Hub Account") as one of our clients ("Clients") to access our data analytics services, visit the websites of our Clients, manage your travel experiences through one of our booking platform partners ("Partners") or communicate with us in person, by phone or by email, including when you apply for a professional opportunity with Stay22. 

Please take the time to familiarize yourself with this Privacy Policy, as it describes your privacy choices and how you can contact us if you have questions or would like to exercise your rights under applicable privacy laws. By providing us with personal information and/or otherwise interacting with us, you agree that your personal information will be processed in accordance with this Policy.

Definition of “personal information”

In this Policy, “personal information” generally means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, mailing address, e-mail address, telephone number, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information, if it is, at all times, reasonably foreseeable in the circumstances that this information irreversibly no longer allows you to be identified directly or indirectly.

Personal Information We Collect

The personal information we collect about you depends on the nature of your interactions with Stay22. Below is a description of the personal information we may collect about you.

• Information we collect directly from our Clients
  • Contact information, including your email, name, phone number, and company name when you start using our services and create a Hub Account.
  • Business information, including information on your area of work (i.e., segment), business URL, and your business’ monthly website traffic.
  • Other information, including any information you may provide us when contacting our customer service team or sharing with us information about a case study involving our services.
  
  
  
• Information we collect from our service providers about our Clients
  • Banking information, including your banking account details to pay you with the assistance of a service provider (i.e., a  third-party payment processor).
  • Tax information, including your social security number and your address to provide you with tax slips when required by applicable law and with the assistance of a service provider (i.e., a third-party payment processor).

• Information we automatically collect on behalf of Clients about the visitors of Clients websites
  • Booking information, including which platforms (such as our Partners) that you use for booking accommodations, flights, and other travel experiences after visiting the website of one of our Clients.  
  • Location information, including the region in which you reside to share such personal information with our Partners, who will, in turn, provide you with booking options relevant to the region in which you reside.

• Information we collect from our Partners about visitors of Client websites
  • Booking information, including details on the travel experiences you manage through our Partners such as whether you booked a flight, accommodation, or other travel experience, the transaction value, date of booking, number of individuals involved, and length of stays. 
  • Location information, including the location of the travel experience bookings that you manage through our Partners. For example, this may include your destination if you book a flight through one of our Partners.  

• Information we collect directly from visitors of our Website
  • Contact information, including your email when you sign-up to receive Stay22 product updates on our Website and your name, phone number (if applicable), and the name of your business when you contact us through our Online Request Form or sign-up to receive Stay22 product updates on our Website.
  • Business information, including information on your area of work (i.e., segment), business URL, and your business’ monthly website traffic when you contact us through our Online Request Form. Note that, as further explained in our Online Request Form, you are not required to provide us with all of this information. If you have any questions about what information is required, contact us using the information provided in the Contact Us section.
  • Professional information, including information found in your CV and cover letter, information on your professional experiences, education history, and the contact information of your referrals if you apply for an opportunity with Stay22 through our Website. We may also receive this information from third parties if you apply for an opportunity with Stay22 through a third-party platform (e.g., LindkedIn or Indeed).

• Information we collect automatically from visitors of our Website
  • We collect information automatically when you visit our Website using technologies such as cookies and pixels. The technical information we collect when you visit our Website includes  (as applicable)  the date and time of your visit, the pages of the Website you visit, and the referring URLs you came from. Please refer to our Cookie Policy to learn more about how we use cookies and how you may change your cookies preferences.
    
    

How We Use Your Personal Information 

We may use your personal information for general business purposes such as providing or delivering our services, managing our Website, preventing or reducing commercial risk, as well as for purposes relating to our information system or network security. More specifically, we may use your personal information for the following general business purposes:

• Providing or delivering our products and services, including our Website and Hub Accounts. We may use Partner personal information as applicable to set up and administer your Hub Account on our Website. We may also use the personal information of visitors of Partner websites on behalf of our Clients to provide Clients with our data analytics services.
  
  
• Managing our Website. We may use your personal information to manage and facilitate the use of our Website when you visit or access it, which may include using cookies and other similar technologies (see our Cookie Policy for more information to learn more about how we use cookies and how you may change your cookie preferences).
  
  
• Communicating with you. If you contact us with a question or inquiry, we may use your personal information to respond to you. We may also communicate with you for business development purposes, to promote our services and offers, send you direct marketing communications about product updates, to facilitate your participation in promotions, and to notify you about changes to our services. You can specifically withdraw your consent to the use of your personal information in connection with us providing you with direct marketing emails  by clicking on the unsubscribe link at the bottom of such emails. 
  
  
• Evaluating your application. We may use the information you provide us as part of your application for a professional opportunity with Stay22 when considering and responding to your application and assessing your suitability for current and future professional opportunities.
  
  
• For other purposes permitted or required by law. We may use personal information without your consent where we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights of Stay22 or to enforce or apply our terms of use and other agreements, or to detect, prevent and investigate suspicious, unauthorized, fraudulent, illegal or unlawful activity.
  
  

With Whom We Share Your Personal Information 

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

• Service providers. We may use service providers to provide certain services on our behalf, such as data hosting and processing, analytics, marketing, transaction processing, and similar services. As a result, these service providers may process or handle personal information on our behalf.

• Business transactions. We may disclose personal information to facilitate or enable any corporate or commercial transaction involving Stay22 to the extent permitted by applicable law. 

Note that within Stay22, our staff may have access, in whole or in part, to your personal information on a need-to-know basis. 

Cross-border Transfers 

Some of our external third-party service providers are based outside of Québec and/or Canada, including in the United States and Europe. Their processing of your personal information will therefore involve a transfer of information outside of Québec and/or Canada. Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

Your Privacy Rights 

Under privacy laws applicable in the region in which you reside, you may have the following rights with respect to your personal information, subject to limited exceptions set out in such laws:

• Right to information: You have the right to ask us about our processing of your personal information, including about the categories of persons who have access to your personal information within Stay22 and the applicable retention period.

• Right to access. You can ask us if we hold any personal information about you, and if so, you can request access to that personal information. Depending on the laws applicable in the region in which you reside, you may have the right to ask us to communicate to you the personal information you have provided us in a structured, commonly used technological format, as well as to a third party upon your request.

• Right to correction. You have the right to ask us to rectify any personal information that you demonstrate to be incorrect or outdated and to complete any information that you demonstrate to be incomplete.
  

• Right to withdraw consent. You may withdraw your consent to our processing of your personal information to the extent permitted by law and our contractual obligations. However, you understand that in such a case, you may no longer be able to benefit from our products and services.

To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section below. Note that you can specifically withdraw your consent to the use of your personal information in connection with us providing you with direct marketing emails by clicking on the unsubscribe link at the bottom of such emails. Clients may also access and correct some of their personal information directly by signing into their Hub Account and may contact us using the information provided in the Contact Us section below to access or correct any other of their personal information.

If we receive a request from an individual to access or update personal information we maintain on behalf of a Client, we will direct that individual to the relevant Client. We will assist our Clients wherever possible in responding to individual access requests.

Third Party Links

Our Website may contain links to other websites that Stay22 does not own or operate. We provide links to third party websites as a convenience to visitors of our Website. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Retention 

We will retain your personal information for as long as necessary to fulfill the purposes for which the information was collected. However, we may retain your personal information for a longer period when required to comply with our legal and regulatory obligations regarding information or record retention.

Security Safeguards 

We protect and safeguard your personal information using physical, electronic and procedural measures appropriate to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, including safeguards to protect your information against loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Specifically, we implement the following measures to protect your personal information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of an item of information and limit their access to that information on a “need-to-know” basis;
• Physical, electronic and procedural safeguards that comply with relevant standards to protect personal information;
• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
• A designated privacy officer to monitor Stay22’s compliance with applicable privacy laws;
• Procedures for receiving, investigating, and responding to complaints or inquiries about Stay22’s information handling practices; and
• Contractual protections to ensure that service providers with whom we share personal information maintain adequate protections and security standards.

If you have reason to believe that personal information has been compromised or accessed, used or disclosure unlawfully, please contact us using the information provided in the Contact Us section. 

Updates to this Policy 

This Policy is current as of the Effective Data set forth above and may be amended from time to time at our sole discretion. We recommend that you periodically review this Policy as it may be updated or revised from time to time. If we make material changes, we will take reasonable steps to notify you of those changes, including by posting the revised Policy on our Website with an adequate notice.

Contact Us 

If you have any questions regarding our processing of your personal information or about this Policy, please contact our Privacy Officer in writing at privacy@stay22.com.