Privacy Policy

This Privacy Policy describes how SpaceNextDoor Inc. and our subsidiaries and affiliates (collectively, “SpaceNextDoor”, “we”, “us” or “our”) process personal information that we collect through our online services that link to this Privacy Policy (collectively, the “Service”) and in connection with our marketing activities, as well as your choices with respect to your personal information.

SpaceNextDoor is committed to protecting your personal information in compliance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and any applicable provincial privacy legislation.

Canadian residents: Please see the “Canadian Privacy Rights” section below for important information about your rights under applicable Canadian and Ontario privacy laws.

We and our third-party service providers may monitor and record your communications and interactions with us, other Service users, and/or the Service for the purposes described in this Privacy Policy.

By using the Service, you agree to our handling of personal information as described in this Privacy Policy and to our Terms of Service.

Personal Information We Collect

The personal information we collect from you, directly or indirectly, will depend on how you interact with us and with our Service. From time to time, we may collect personal information not specifically listed in this Privacy Policy, which we will use as described in this Privacy Policy or as otherwise explained at or before the time of collection. The sources from which we collect personal information include the following:

Information You Provide to Us

Personal information you may provide to us or our service providers through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, mailing addresses, postal code, and phone number.
• Account data, such as the username and password that you set to establish an online account on the Service, identity document information (e.g., information from a passport or driver’s licence), client type, contact data, and any other information you choose to include with your account, such as your account preferences.
• Biometric data, which includes biometric information and/or identifiers in the form of facial geometry extracted from images of your face in the photos and/or identity documents that you provide to third party identity verification services that we may use from time to time. We use these identity verification services to verify your identity and prevent fraud when you register for the Service. We do not collect or store biometric data. Instead, the third party identity verification services we use collect this biometric data directly from you and use and retain the biometric data and other personal information as described in their privacy policies. You can view the privacy policy of Persona, one of the identity verification services we use, at: https://withpersona.com/legal/privacy-policy. By submitting your registration information or undertaking identity verification, you consent to our collection of identity-document and biometric data described in this bullet and to its transmission to and use by our third-party identity-verification providers for the purposes described in this Privacy Policy, including identity verification, fraud prevention, and screening against applicable sanction or watch lists.
• User content, which includes your comments, feedback, photos, videos, audio, chats, and messages that you post to areas of the Service visible to other Service users or in messages to other Service users.
• Booking confirmations, such as the confirmations Renters are required to give as part of a booking request under the Terms of Service, including confirming that the items to be stored are not Prohibited Items, flagging whether any items fall within designated “Protected Property” categories, and identifying any person or entity holding a lien or other security interest in the items. Where you submit information about a third party (such as a lien holder), you confirm that you have authority to do so and that you have informed that third party of how their information will be used and disclosed by us in accordance with this Privacy Policy.
• Payment data, which includes the payment card data, contact details, and in certain cases, date of birth, required to process payments made through the Service, as well as transaction history. Your payment transactions are processed by third party payment processors, such as Stripe, which collect your personal information as described below under “How we share your personal information.”
• Communications data, such as your communications with us or the Service and data about those communications and interactions. When you communicate with us through social media, this will include your social media handle. When you communicate with us via text messages, this may include your cell phone number, your mobile carrier’s name, and the date, time, and content of your messages.
• Promotions data, including information you share when you choose to enter a contest, promotion, sweepstakes, rewards program, or complete a survey.

Third-Party Sources

We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Data providers, such as information services and data licensors.
• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Third-party services, such as social media services, that you use to log into your Service account or to which you connect to share content. This data may include your username, profile picture, and other information associated with your account on that third-party service.

Automatic Collection

When you access or interact with the Service or our communications, we, our service providers, and our advertising partners may automatically log, monitor, and record information about you, your computer or mobile device, and your interaction over time with the Service. This information includes:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, and radio/network information (e.g., Wi-Fi, Bluetooth, LTE, 3G), as well as general location information (e.g., city, province) that can be derived from your IP address.
• Usage data, such as pages or screens you viewed, your search terms, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, access times and duration of access, whether you have opened our emails or clicked links within them, and other functional information on Service performance (like diagnostics and crash logs).
• Precise geolocation of your device when you grant the Service access to it in your device’s settings. Mapping and location features on the Service are provided using Mapbox, whose privacy practices are described at: https://www.mapbox.com/legal/privacy.
• Other device data that we collect from your device when you grant the Service access to it, such as audio collected from your device’s microphone to enable voice commands; motion data collected from your device’s gyroscope, accelerometer, or other sensors; and photos or video accessed from your device’s photos or camera.

Cookies and Similar Technologies

We, our service providers, and our advertising partners use the following technologies to facilitate some of the automatic collection of personal information described above:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of tracking user activity and patterns, helping the visitor navigate between pages efficiently, remembering preferences and whether a visitor is logged in, and improving the visitor’s browsing experience. You can learn more about cookies and how to control them at www.allaboutcookies.org.
• Pixels (also known as web beacons or clear GIFs), which are embedded in code and/or invisibly as image files within webpages or HTML formatted emails and used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Chat technologies provided by third parties that operate the chat features that you can use to communicate with us through the Service. These third parties may access and use the data described in the automatic collection section above, and monitor and record your chats, for the purposes described in this Privacy Policy.
• Session replay, a technology that uses third-party software code to record users’ interactions with the Service in a manner that allows us to watch and analyze visual reconstructions of them. The replays include users’ clicks/taps, mouse movements, scrolls, and keystrokes/touches during those sessions.
• Software development kits (SDKs), which are used to incorporate third party computer code into our mobile app that allows our third party service providers or advertising partners to collect data directly from our app for a variety of purposes, including to provide us with analytics, integrate with social media, add features or functionality to our app, or to facilitate and measure the effectiveness of interest-based advertising.
• Embedded scripts, which use software code temporarily downloaded to your device to collect information about your interactions with the Service such as the links you click on.
• Other Technologies. We may also use device identifiers, local storage (including HTML 5), html modifiers, and different types of caching to help us understand the devices and users who access the Service.

How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service Delivery and Operations

We may use your personal information to:

• provide, operate, and improve the Service and our business and develop new products or services;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• administer and communicate with you about events, promotions, or contests in which you participate;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service and improve our customer support capabilities, including to perform quality assurance monitoring of support calls and to train support personnel.
• monitor and review on-platform communications. Members are required by the Terms of Service to conduct all substantive Booking communications through the SpaceNextDoor messaging tools. We may monitor, store, and review these communications for the purposes of customer support, dispute resolution, fraud detection, audit, regulatory compliance, and enforcement of the Terms. We do not monitor private off-platform communications between Members.

Marketing and Advertising

We, our service providers, and our third-party advertising partners may collect and use your personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications about our or our partners’ products and services via mail, email or (as permitted by applicable Canadian law, including CASL) text messages, and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the opt-out of marketing section below.
• Offers. We may offer or promote our or our partners’ products and services on our Service based on the personal information we collect about you.
• Interest-based advertising. Our third-party advertising partners may use cookies and other technologies to collect information about your interaction with the Service, our communications, and other online services over time and with different browsers and devices, and use that information to serve online ads that they think will interest you and measure their effectiveness. We may also share user contact data with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
• User content. We may use limited user content, such as listing details and photographs users provide, for editorial content and to advertise our products and services to the public.

Research and Development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes. We do not attempt to re-identify de-identified information derived from personal information, except that we may do so to test whether our de-identification processes comply with applicable law.

Compliance and Protection

We may use your personal information to:

• comply with applicable Canadian and Ontario laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
• verify your identity and authority to use the Service. We may require you to provide government-issued identification, proof of address, evidence of ownership of or authority to license a property you have listed, and other documentation as a condition of registering an Account, listing a Space, or submitting a booking request, and we may transmit this information to our third-party identity-verification providers (such as Persona) for verification, in accordance with the Terms of Service. You consent to the collection, use, and disclosure of your personal information for this purpose.
• screen for fraud indicators and sanction or watch-list matches. We may screen registration information, payment information, and other personal information against fraud indicators and applicable sanction or watch lists (which may include lists maintained by Canadian and international authorities) for the purposes of preventing fraud, complying with applicable law, and protecting the safety of the Service and its users.
• Screening Checks between users. We may facilitate identity, credit history, property ownership, or criminal history Screening Checks between Members in accordance with the Terms of Service. We may collect and retain the fact that a Screening Check has been conducted, and limited results, but generally do not collect or retain the underlying records, which are provided to the requesting Member by the screening provider under that provider’s terms.
• enforce remedies for Default. Where a Renter is in Default under the Terms of Service, we may collect, use, and disclose personal information as necessary to enforce remedies, including the contractual lien on Stored Items, the abandonment procedures, and any cooperation with law enforcement or regulatory authorities. This may include processing personal information incidentally observed in the course of inventorying or disposing of Stored Items.

Artificial Intelligence

We, our service providers and the third parties we work with may use artificial intelligence (AI) and machine learning technologies, including generative AI, to facilitate the processing of personal information described in this Privacy Policy.

How We Share Your Personal Information

Except as otherwise specified in this Privacy Policy, we may share the categories of personal information listed above with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

• Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as mail delivery, hosting, information technology, customer support, email delivery, marketing, advertising, identity verification, payment processing, chat functionality, generative artificial intelligence, consumer research and website analytics).
• Identity verification providers. Companies that help us verify your identity when you register for the Service. These companies extract facial geometry from images of your face in photos and/or identity documents that you provide, as well as other personal information, and analyze it to verify identity and prevent fraud. You can review the privacy policy of Persona, one of the identity verification services we use, at: https://withpersona.com/legal/privacy-policy.
• Hosts and Renters. We may share personal information between Hosts and Renters to facilitate the booking process and Service. For example, we share the Host’s and Renter’s contact data with one another upon a confirmed Booking and as needed to facilitate resolution of disputes between them.
• Other users and the public. To advertise a Host’s Listings and promote customer safety, we make certain information available in public Listings on the Service, which may include the Host’s first name and first letter of the Host’s last name, the Host’s rating, description of the rented Space, general description of themselves, the general area in which the rented Space is located, verified ID status, verified Host status, and the Host’s rating and statistics.
• Payment processors. When you make purchases through the Service, your transactions are processed by third party payment processors, such as Stripe. These payment processors may collect your name, phone number, email address, mailing address, billing address, payment card information, and other information needed to process your payment. Stripe’s Privacy Policy is available at https://stripe.com/privacy.
• Host Protection claims. If a Host submits a case for reimbursement under the Host Protection program described in Section 12 of the Terms of Service, we collect and use the information submitted in support of that case — including the written description of the loss, supporting documentation, and the photographic documentation required under the Terms of Service — to evaluate and administer the claim. The Host Protection is self-funded by SpaceNextDoor and is not backed by or shared with a third-party insurer. Where SpaceNextDoor exercises subrogation rights against a party responsible for a loss, or where a Host’s claim relates to insurance the Host separately holds, we may share limited information with that party or insurer as necessary for that purpose.
• Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. Their use of your personal information is subject to their own privacy policies.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us to do so or with your consent.
• CAPTCHA providers. To enhance the security of our Service, we may use CAPTCHA features that require users to complete a task to authenticate to the Service. Third party providers of these CAPTCHA services may collect device data and usage data as described above.
• Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above, or as otherwise permitted by applicable Canadian law.
• Business transferees. Parties (and their advisors) to business transactions and prospective transactions involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of SpaceNextDoor (including, in connection with bankruptcy, insolvency, receivership or similar proceedings) where the transaction involves the transfer of personal information.

Your Choices

Privacy Rights

Canadian residents can exercise privacy rights with respect to the personal information we hold, as described in the Canadian Privacy Rights section below.

Access or Update Your Information

If you have registered for an account with us through the Service, you may review and update certain account information and preferences by logging into the account.

Opt-Out of Marketing Communications

You may request to opt-out of our marketing emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us with your request. If you receive text messages from us, you may opt-out of receiving further text messages from us by replying STOP to our message. Under CASL, we will honour opt-out requests within ten (10) business days as required by law.

Cookies

Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser settings. Please note that if you set your browser to disable cookies, certain features of the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can learn more about Google Analytics and how to opt-out of being tracked by Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Pixels

Most browsers and devices allow you to configure your device to prevent pixel images from loading. To do this, follow the instructions in your browser or device settings.

Precise Geolocation and Other Device Data

You can disable our access to your device’s precise geolocation, microphone, camera, other sensors, and photos/videos in your mobile device settings.

Advertising Choices

You may be able to limit use of your personal information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
  • Network Advertising Initiative
  • Digital Advertising Alliance of Canada (DAAC)
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Linked Third-Party Platforms

If you choose to connect your social media account or other third-party platform to the Service, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third-party.

Delete Your Account

To request to delete your online Service account, please contact us at support@spacenextdoor.co. Following an account deletion request, we delete the user’s account and associated data, unless they must be retained for the compliance and protection purposes described above, or because of an outstanding credit or an unresolved claim or dispute.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third-party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security and Retention

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

We generally retain personal information to fulfill the purposes for which we collected it, including to comply with applicable legal, tax, accounting, or reporting requirements; to establish or defend legal claims; and for fraud prevention purposes. When we no longer require the personal information, we will either delete or anonymize it or, if this is not practicable (for example, because your personal information has been stored in backup archives), isolate it from further processing.

Identity-verification documentation (including identity-document images and any associated biometric data extracted by our third-party providers) is retained only for as long as necessary to complete the verification process and to support any later fraud investigation, regulatory compliance, or legal proceedings. SpaceNextDoor itself generally retains only the result of the verification (such as pass or fail and applicable risk indicators); the underlying identity-document images and biometric data are handled by our third-party providers under their own retention policies, which you can review at the privacy-policy links provided above.

Data Transfers Within Canada and Internationally

SpaceNextDoor is headquartered in Canada. We may use service providers that operate in Canada, the United States, and other countries. Your personal information may be transferred to locations outside Canada where privacy laws may not provide equivalent protections to those in Canada.

Where we transfer personal information outside of Canada, we take steps to ensure that your personal information receives an adequate level of protection by implementing appropriate contractual and technical safeguards.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child under 18 from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by applicable Canadian law, we will comply with applicable legal requirements to delete the information.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service and/or through other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

If you have any questions, comments, or complaints concerning this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

You also have the right to contact the Office of the Privacy Commissioner of Canada (OPC) if you have concerns about how we handle your personal information:

https://www.priv.gc.ca/en/report-a-concern/
Toll-free: 1-800-282-1376

If you are an Ontario resident, you may also contact the Information and Privacy Commissioner of Ontario (IPC):

https://www.ipc.on.ca/en/privacy-individuals/making-a-privacy-complaint

Canadian Privacy Rights

Scope

This section applies to all Canadian residents. Our collection, use, and disclosure of your personal information is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and any applicable provincial privacy legislation. For purposes of this section, “personal information” has the meaning given to it under applicable Canadian privacy law.

Your Privacy Rights Under Canadian Law

Subject to applicable law and certain exceptions, you have the following rights with respect to your personal information:

• Right to Know/Access. You have the right to request access to the personal information we hold about you, to know the purposes for which it has been used, and to know to whom it has been disclosed. Under PIPEDA, we will respond to your access request within 30 days (with the possibility of an extension in certain circumstances). See: PIPEDA, s. 4.9.
• Right to Correction. You have the right to challenge the accuracy and completeness of your personal information and to have it amended where appropriate. See: PIPEDA, s. 4.9.5.
• Right to Withdraw Consent. Subject to legal and contractual restrictions and reasonable notice, you have the right to withdraw your consent to the collection, use, or disclosure of your personal information. Withdrawal of consent may affect our ability to provide certain services to you.
• Right to File a Complaint. You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at https://www.priv.gc.ca/en/report-a-concern/ if you believe your privacy rights have been violated.
• Right to Data Portability (Quebec). Quebec residents have the right under Law 25 to receive their personal information in a structured, commonly used technological format and to request that it be communicated to a third party, where technologically feasible.
• Right to Object to Automated Decision-Making (Quebec). Quebec residents have the right to be informed when a decision is made exclusively through automated means that produces legal or similarly significant effects, and to request that the decision be reviewed by a human.

How to Exercise Your Rights

To exercise any of the privacy rights described above, please submit a request to:

support@spacenextdoor.co

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We may need to verify your identity before processing your request. We will respond to access and correction requests within 30 days as required under PIPEDA, or as otherwise required by applicable law.

Sensitive Information

We treat the following categories of information with heightened sensitivity, as they are considered particularly sensitive under Canadian privacy law: biometric data, precise geolocation, financial information (including payment card data), and account credentials. We collect and use this sensitive information only with appropriate consent and for the purposes described in this Privacy Policy.

Profiling and Automated Decisions

We do not use personal information to profile you in furtherance of decisions that have legal or similarly significant effects on you.

Purpose Limitation

We collect your personal information only for the purposes identified in this Privacy Policy or at the time of collection, and we use and disclose it only for those purposes or with your consent, except as otherwise required or permitted by law. This is consistent with our obligations under PIPEDA, Principle 4.2.

Accountability

SpaceNextDoor is responsible for personal information under its control and has designated a Privacy Officer who is accountable for our compliance with PIPEDA. To contact our Privacy Officer, see the “How to Contact Us” section above. This is consistent with our obligations under PIPEDA, Principle 4.1.