LEXOH
 

PRIVACY POLICY

1. Introduction: Taking parking and privacy seriously

1.1 Lexoh (hereinafter referred to as “Lexoh”, “we”, “us” or “our”) operates a platform and community marketplace that helps people create, list, host, discover, book and use parking spaces around the world, whether through our website or our mobile applications (“Platform”). Lexoh refers to Lexoh Inc. (a business based in Canada and operating globally) and its related entities, including Lexoh Inc. and General Tech Services Inc.

1.2 This Privacy Policy is intended to inform you how we treat personal information that we collect and process about you while you access and use our Platform (Personal Information). If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform to you, and you should stop accessing the Platform and deactivate your Lexoh account. You can find out more about how to deactivate your Lexoh account at support@lexoh.com.

1.3 Where the definition of a term does not appear in this Privacy Policy it shall be given its definition as outlined in our Terms of Service.

2. How do we collect your personal information?

2.1 Information that you give us:

2.1.1 We receive, store and process information that you make available to us when accessing or using our Platform, such as your name, email, telephone number, home address, demographic information (such as postal code, age) photos, car registration and information related to you parking activity. Payment information (such as account or credit card number) is provided directly to our third party payment gateway, Stripe.

2.1.2 We collect information directly from you when you:

  • fill in any form on the Platform, such as when you register or update the details of your user account;
  • interact with a chat widget or pop-up on our website/s, such as providing us with your name, email address or phone number to receive further communications;
  • access or use the Platform, such as to search for, or Host parking spaces, make or accept bookings, pay for parking spaces, enter your bank account number so you can be paid for hosting parking, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;
  • link your account on a third party site (e.g. Facebook) to your Lexoh 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; and
  • communicate with Lexoh.

2.2 Information we collect from your use of the Platform:

We also collect information from you indirectly when you use our Platform so that we can provide effective services and products. We collect information from you indirectly as follows:

  • Mobile Data – When you use our mobile applications we may receive, store and process different types of information about your location, including general information (e.g., IP address, post or 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).
  • 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 Lexoh or logged in to your Lexoh 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, pages viewed and the order of those pages, and the amount of time spent on particular pages.
  • Third Party Social Plugins – Our Platform may use social plugins which are provided and operated by third-party companies, such as Facebook’s Like Button. As a result of this, you may send to the third-party company 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 company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our Platform to your account with them.

3. Cookies

3.1 Lexoh 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.

3.2 Lexoh may place cookies on your device via the Platform.

3.3 We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.

3.4 There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.

3.5 Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

3.6 Web beacons and tracking technologies

The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

3.7 Uses for Lexoh cookies:

Lexoh uses cookies for a number of purposes, such as the following:

  • to enable, facilitate and streamline the functioning of the Platform and Lexoh’s websites across different webpages and browser sessions.
  • to simplify your access to and use of the Platform and Lexoh’s websites and make it more seamless.
  • to monitor and analyze the performance, operation and effectiveness of the Platform and Lexoh’s websites, so that we can improve and optimize the experience.
  • to show and personalize content (which may include advertisements) that is more relevant to you.

3.8 Disabling Cookies:

You can choose to accept or reject cookies by submitting our cookie consent banner when you first visit any of our domains (e.g. lexoh.com), or by visiting our cookie declaration page and clicking “Change your consent”, or “Withdraw your consent”. You can change your cookie consent settings at any time using this method.

3.9 You can opt out of every cookie category except ‘Necessary Cookies’ as Lexoh’s websites require these settings in order to function.

3.10 Please note that some parts of the Platform may not work as intended or may not work at all without cookies.

4. How Lexoh uses and processes the personal information we collect from you

4.1 We use and process your Personal Information for the following general purposes:

  • to enable you to access and use the Platform, and provide relevant information about our products and services;
  • to operate, protect, improve and optimize the Platform, Lexoh’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;
  • to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your parking space listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • with your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information sent on behalf of our business partners that we think you may find interesting. You will be able to unsubscribe or opt-out from receiving these communications by following instructions included in each of the relevant communications;
  • to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Lexoh or our business partners;
  • 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; and
  • to assist you if you have any problems with a Host, Park or Parker.

5. How Lexoh uses and processes user communications

5.1 We may 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.

5.2 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 Lexoh, in its sole discretion, may review, scan, analyze, and store your communications, whether done manually or through automated means.

5.3 The rights to use and analyse customer information (including for marketing offers) is mostly restricted to Lexoh. A Host is not given the explicit right to analyse customer information unless that customer is accessing the park using the Lexoh for Business system in which case customer data is shared with the host for the purpose of research, analytics and reporting.

6. When Lexoh discloses or shares personal information, and to whom

6.1 Your Personal Information may be disclosed to other users of the Platform and the general public as follows:

  • As a Host, your public listing page will include the city and neighbourhood where the parking space is located, photos and images provided by you (including images of property and public profile images), and your responsiveness and performance as a Platform user. Parts of your public listing page may be displayed in other parts of the Platform to other users for marketing purposes. The Platform may also display the parking space’s geographic location on a map, such that a user can see the general area of the parking space.
  • As a Host, 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.
  • As a Host, when you receive a booking, or someone commences parking in your parking space, some of your Personal Information will become visible to the Parker. You agree to be contacted by the Parker or Lexoh via the platform, and when the Parker or Lexoh decides to do so. Your billing information will never be shared with another user.
  • As a Parker, when you submit a request to book a parking space or start parking, some of your Personal Information will become visible to the Host. You agree to be contacted by the Host or Lexoh by phone or via the platform when submitting your request and the Host (or Lexoh) decides to do so. We will not share your phone number unless you have granted specific permission, on a case by case basis.
  • As a Parker, if you are a member of a private group (for example, employees, tenants or other private parking arrangements), your parking activity and use of the Platform relevant to the parking spaces associated with the private group will be shared with the Host and/or organisation admin.
  • As a Parker or Host, 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.
  • If you provide a review as a Parker or a Host, your review may be public on the Platform.

6.2 You may link your account on a third party authentication site to your Lexoh account. When you create this linkage:

  • some of the information you provide to us from the linking of your accounts may be published on your Lexoh account profile;
  • your activities on the Platform may be displayed to your organisation on the Platform and/or that third party site;
  • 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.

6.3 The publication and display of information that you provide to Lexoh through this linkage is subject to your settings and authorizations on the Platform and the third party site.

6.4 We may distribute parts of the Platform (including your listing) for display on sites operated by Lexoh’s business partners, 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.

6.5 We may allow our related entities such as our subsidiaries, 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.

6.6 We may engage third party companies and individuals, who may be located outside of Canada, to provide services to us, including cloud-storage providers, services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed).

6.7 You acknowledge, consent and agree that Lexoh may access, preserve and disclose your account information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against Lexoh; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service; (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 Lexoh, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless prohibited by law or by the government request, or if doing so would be futile or ineffective.

6.8 We may also publish, disclose and use aggregated information and non-personal information for industry analysis, demographic profiling, marketing and advertising, and other business purposes.

6.9 If Lexoh 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.

6.10 We may transfer, store, use and process your information, including any Personal Information, to countries outside of Canada. Laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident. Where we transfer information to service providers and business partners located outside of Canada, we will take such steps as are reasonable in the circumstances to confirm that the organisations are required to protect the information in a way that, overall, provides comparable safeguards to those under this Privacy Policy. By using the Lexoh services and otherwise providing us with your information, you authorise such disclosure.

6.11 Lexoh will not sell your Personal Information to service providers or third party organisations. While we use various service providers to provide our services to you, these service providers are contractually bound to use the information we share only for the purposes of providing their service to us (and not for their own purposes).

7. Your privacy when you access third party websites and resources

7.1 The Platform will contain links to other websites not owned or controlled by Lexoh. Lexoh 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.

7.2 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 and Google’s privacy policy, as may be amended by Google from time to time.

8. Lexoh’s interactive areas

8.1 Lexoh is not liable for any information posted in interactive areas. Lexoh provides interactive areas such as reviews and discussion forums to enhance the user experience and build a healthy community around our website’s products and services. You acknowledge that should you participate in such interactive areas, the information you voluntarily post about yourself and third parties in such areas might be accessed, collected and used by third parties outside of Lexoh.

8.2 WE RECOMMEND THAT YOU DO NOT POST ANY PERSONALLY IDENTIFIABLE INFORMATION SUCH AS YOUR EMAIL ADDRESS IN OUR PUBLIC AREAS.

8.3 You may not post any defamatory, obscene, slanderous, or otherwise illegal material, or any material which infringes any third-party copyrights or other intellectual property rights on any interactive areas. Violators may have their accounts terminated and legal action may be taken against them. Although we employ advanced security technology, it cannot guarantee complete security in personal websites or password-protected areas, and Lexoh will not be held liable for any user’s or other visitor’s disclosure of personal information on Lexoh or any other website or Platform operated by us.

9. Special features and programs

9.1 The Platform may provide a referral service that allows you to invite your friends and contacts to use the Platform. The Platform may allow your friends and contacts to write a reference for you, to be published on the Platform.

9.2 We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Lexoh does not collect or retain the contact information that is used to send them.

9.3 You may also send invitation/request emails via the Platform itself, in which case we will ask you for the email addresses to send these emails to. You can type in the email addresses manually, or you can request Lexoh to import the contacts in your email account address book(s). In both cases, we will use the information sent to us for the sole purpose of sending your friends and contacts a one-time email, inviting him or her to visit the Platform or to write a reference for you. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Lexoh in response to your referral.

9.4 If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.

10. How to change or delete your information or cancel your Lexoh account

10.1 You may review, update, correct or delete the Personal Information in your Lexoh account by logging in to your account. If you would like to cancel your Lexoh account entirely, you can do so by logging in to your account. 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 Lexoh account is cancelled. Even after deleting your account, we may retain your Personal Information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention. We may also retain and use your personal information to the extent necessary to comply with our legal obligations, for example, tax, legal reporting and auditing obligations.

11. Keeping your personal information secure

11.1 We will use best endeavours to protect your Personal Information. We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Information against the unauthorized access, destruction or alteration of your information. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.

12. Your rights to review and update information

12.1 You may request by email copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after the request in writing. There may be a charge to access your personal data (which will not exceed CAD$50). We may also request proof of identification to verify your access request. All requests should be addressed to our Privacy Officer, at support@lexoh.com.

12.2 We endeavour to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, delete or block the relevant information and notify you within 40 days of your request that the relevant action has been taken.

12.3 You may also ask us to delete your personal information that we have collected directly from you. All requests should be addressed to our Privacy Officer, Lexoh Limited at support@lexoh.com. There is no charge for making such a request.

13. Changes to this privacy policy

13.1 We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion.

13.2 We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

13.3 It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform to you, and your only option will be to stop accessing the Platform and deactivate your Lexoh account.

14. Retaining your information

14.1 We only hold your Personal Information for as long as necessary to achieve the purpose we collected it for, and in all cases for such periods as we are required to in order to comply with any relevant legislation or regulations.

15. Contact Lexoh

15.1 Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy or make a complaint about Lexoh’s handling of personal information, please email our Privacy Officer at support@lexoh.com.

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