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Lane Platform End User Privacy Statement

Last revised: March 25, 2020

PLEASE REVIEW THIS PRIVACY STATEMENT CAREFULLY. BY SUBMITTING YOUR PERSONAL INFORMATION TO US, BY SIGNING UP FOR AN ACCOUNT, OR BY USING THE PLATFORM OR SERVICES, YOU CONSENT TO OUR COLLECTING, USING AND DISCLOSING YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT, AS REVISED FROM TIME TO TIME.

Lane Technologies Inc. and its affiliates and subsidiaries (collectively, “we”, “us”, “our” and“Lane”) are committed to protecting your privacy and safeguarding your personal information.

We offer an online workplace and tenant experience platform (the “Platform”) that enables landlords, property managers, tenants, merchants, and service providers to interact with end users. You might access our Platform through a mobile app or web portal named for your landlord, your property manager, or your employer, or through a mobile app or web portal named for Lane. After you open an account on our Platform, you are able to subscribe for channels offered on our Platform, such as channels offered by your landlord, your property manager, your employer, or others. For example, your landlord’s channel might provide you with information about events at or near the building where you work.

The purpose of this privacy statement is to inform you about our privacy practices relating to your use of our Platform and the services that we or others may provide to you through or in connection with our Platform (collectively the “Services”), including how we collect, use and disclose your personal information when you use our Platform or the Services or interact with others through our Platform or the Services.

When you use our Platform and the Services, you will also interact with others, such as your landlord, your property manager, your employer, merchants, and service providers. The others with whom you interact may also collect, use and disclose your personal information.

This privacy statement only describes how Lane collects, uses and discloses your personal information. To understand how others with whom you interact collect, use and disclose your personal information, you must review their privacy statements.

Meaning of Personal Information

“Personal information” means information about an identifiable individual. This information may include, but is not limited to, your name, mailing address, e-mail address, and telephone number.

Personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work electronic address.

Personal information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.

If you choose to submit your personal information to us, to sign up for an account, or to use our Platform or the Services, we will assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy statement.

If we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide access to our Platform or the Services.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this privacy statement.

Information We Collect

We collect information about your use of our Platform and the Services, including the information described in this part of our privacy statement.

When you sign up for an account or make changes to your account settings, we collect your name, password, email address, building name and location, and employer name. We may collect additional information to identify you, to communicate with you, and to validate your identity (if needed). For example, if you request SMS notifications, then we will collect your phone number so that we can provide those notifications.  We also collect any additional information that you provide to personalize your account.

We keep records of the Platform channels and the Services to which you subscribe. The act of subscribing to a Platform channel may communicate personal information to us. For example, if you subscribe to a landlord channel, then that may tell us the location of the building where you work. If you subscribe to a tenant channel, then that may tell us the name of your employer. If you subscribe to certain Services, that may tell us about your use of those Services.

When others communicate with you through our Platform or the Services, and when you communicate with others through our Platform or the Services, we may keep records of the fact that a communication was made and we may keep records of the contents of some or all of those communications. For example, if your landlord sends a notice to all end users at a building advising of an upcoming event at the building, then we may keep a record of the fact that a notice was sent and we may keep a record of the content of the notice. If you send a communication to your landlord requesting some maintenance in your building, then we may keep a record of the fact that a communication was made and we may keep a record of the content of the communication.

We collect information about how you use our Platform and the Services, such as the types of content you view or engage with, the features you use, the actions you take, the Platform Channels and Services you interact with, and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Platform and the Services, and what content you view on our Platform and the Services.

If you order goods or services through our Platform or the Services, then we may record the fact that goods or services were ordered and we may keep more detailed records about the order. For example, if you order pizza from a merchant in or close to your building, then we may record the fact that an order was placed, and we may keep more detailed records about the order.

If you use our Platform or the Services to pay for good or services that you order through the Platform, then our payment service provider will collect your payment card information to process your payment for those goods or services. (If you make a payment through our Platform using a payment card, such as a credit card or debit card, you are connected directly to our online payment service provider and your payment card information is collected and processed by that payment service provider.)

If you elect to use the wallet feature in our Platform, then our payment service provider will collect your payment card information to allow you to pay for goods and services using the wallet feature.

Our payment service provider is currently Stripe.  For more information on how Stripe collects, uses and discloses your personal information, see the Stripe Privacy Policy.

We may collect certain technical and device information about your use of our Platform and the Services. Such information may include your Internet protocol (IP) address, information about your device, browser and operating system, the date and time of your visit, your location, searches you conduct, pages you visit, and other log data. If you use a mobile app to access our Platform and the Services, we may collect your mobile device identification and operating system.

If you enable location-based services, then we may use your GPS location to provide location based information to you as part of the Services.  We do not store GPS data or use it for any other purposes.

If you otherwise interact with us, whether in person, by phone, email, chat, social media or otherwise, we may collect information that you provide to us during these interactions.

How We Use Your Information

We may use your personal information and other information for purposes such as:

to provide you with access to our Platform and the Services, to support your use of our Platform and the Services, and to support the use of our Platform and the Services by others who interact with you through our Platform or the Services (such as your landlord, your property manager, your employer, or third party service providers);

to manage your account on our Platform;

to verify your identity, and to confirm your eligibility for certain Platform channels and Services;

to contact you relating to our Platform and the Services, and to request your feedback;

to monitor and improve our Platform and the Services, and to develop new products and services;

to analyze the needs and activities of our customers to help us better serve them;

to conduct research and analysis related to our Platform and the Services, our business, and our other products and services;

to respond to your inquiries and other requests;

to collect opinions and comments in regard to our Platform and the Services;

to provide you with information that we think may interest you, including in regards to our Platform and the Services and our other products and services; and

to investigate legal claims and enforce the Platform terms of use.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

Within our Platform, you will receive advertising of third party products and services. For example, your landlord or your property manager might send you a notification of a sale at a store in the building where you work, or you might receive advertising for other partner services, such as wellness services. This type of advertising is an integral part of our Platform.

We do not send advertising of third party products or services to the email address you provide to us, or by SMS or text to the phone number you provide to us.

How We Share Your Personal Information

When you communicate with others through our Platform or the Services, we will provide the communication to them.

We may provide your name and user ID to the providers of the Platform channels and Services to which you subscribe. For example, we may provide your name to your landlord or your property manager, and your landlord or your property manager may use your name to verify that you are eligible for the Platform channel to which you have subscribed.

If you order goods or services through our Platform or the Services, then we will provide the relevant information to the providers of those goods and services.

If you use our Platform or the Services to pay for good or services that you order through the Platform, then we will provide the relevant information about your order to our payment service provider, and our payment service provider will collect your payment card information to process your payment for those goods or services.

We do not share your password, your email address, or your phone number with the providers of the Platform channels and Services to which you subscribe. For example, we do not provide your password, your email address, or your phone number to your landlord or your property manager. Any communications by your landlord or your property manager to you will be through our Platform, unless you separately provide your email address or your phone number to your landlord or your property manager.

To understand how others with whom you interact through our Platform or the Services collect, use and disclose your personal information, you must review their privacy statements.

We may share, with third parties, aggregated, statistical, or anonymous information that does not identify you.

We rely on third party service providers to perform a variety of services on our behalf, such as payment card processers, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers. If we provide your information to service providers, then we require that the service providers maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided. When our service providers no longer need your personal information for those limited purposes, we require that they dispose of the personal information. In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries or service providers; (f) to protect our rights, privacy, safety or property, or those of our affiliates, you or others; or (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measures outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interactions with us or through the Platform are no longer secure (for example, if you feel that the security of any information that you provided to us or the Platform has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

Accessing and Updating Your Personal Information

You can update your personal information through the account management features within our Platform. We will not update your personal information, unless you advise us that an update is necessary and you are not able to update the personal information through those account management features. We will take steps to ensure that your personal information is kept as accurate and complete as reasonably necessary.

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law. You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

We currently store and process information in Canada and in the United States. In the future, we may also process and store information in other jurisdictions.

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

Third Party Privacy Statements

This privacy statement does not address, and we are not responsible for, the privacy, information, or other practices of any third parties with whom you interact using our Platform or the Services, including any landlord, property manager, tenant, merchant or service provider, and including any other third party operating any site, application or service that may be introduced, included or integrated into our Platform or the Services. We encourage you to read the privacy policy of every person with whom you interact using our Platform or the Services.

Children’s Information

Our Platform and the Services are not intended for children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. Children under the age of 16 should not use our Platform or the Services and should not provide us with their personal information.

Opting Out of Marketing Emails

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our Platform and the Services, or other matters.

Notification Settings

As part of our Platform, you may receive notifications sent to you outside or inside our Platform which may include alerts, badges, banners and sounds (“Notifications”). If you agree to allow Notifications, then our Platform will generate Notifications on your mobile device. You may control the Notifications in your device’s or our Platform’s settings. Your carrier may prohibit or restrict certain Notifications and certain Notifications may be incompatible with your carrier or mobile device. Contact your carrier with questions regarding these issues. You may discontinue Notifications in your mobile device’s or our Platform’s settings or by deleting the mobile application from your device. We may collect information related to your use of Notifications.

Privacy Statement Updates

This privacy statement is current as of the “updated” date which appears at the top of this page. We may modify this privacy statement from time to time. When changes are made to this privacy statement they will become immediately effective when published in a revised privacy statement posted on our website unless otherwise noted. We may also communicate the changes through our Platform or by other means. By submitting your personal information to us, by using your account, or by using our Platform or the Services after we publish or communicate a notice about the changes to this privacy statement, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy statement.

Contact Us

All comments, questions, concerns, or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer as follows:

Mailing address:

Attn: Privacy Officer

Lane Technologies Inc.

33 Yonge St, Suite 1302

Toronto, ON M5E 0A9

By e-mail:

privacy@joinlane.com

Additional Information for Individuals Subject to the GDPR

This part of this privacy statement provides additional information for individuals who reside in a jurisdiction governed by the European Union’s General Data Protection Regulation (“GDPR”).

Personal Data

Under the GDPR, personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”

The term ‘personal information’ used in this privacy statement is approximately equivalent to the term ‘personal data’ under the GDPR.

Data Controller

Under the GDPR, a ‘data controller’ is a person which, alone or jointly with others, determines the purposes and means of the processing of personal data. In respect of personal data collected by us in relation to our Platform and the Services, we are a data controller.

When you use our Platform and the Services, you will also interact with others, such as your landlord, your property manager, your employer, merchants, and service providers. The others with whom you interact may also collect, use and disclose your personal data. When those others collect your personal data, they are also data controllers. This privacy statement only describes how Lane collects, uses and discloses your personal information. To understand how others with whom you interact collect, use and disclose your personal information, you must review their privacy statements.

Legal Basis

Generally, you have given us consent to the processing of your personal data for the purposes for which it is processed. In some circumstances, we process personal data because it is necessary for our legitimate interests.

Your Rights as a Data Subject

Under the GDPR, you may be entitled to additional rights, including: (a) the right to withdraw consent to processing at any time, where consent is the basis of processing; (b) the right to request from the data controller access to and rectification or erasure of personal data, under certain conditions; (c) the right to request from the data controller restriction of the processing of personal data or to object to data processing, under certain conditions; (d) the right to request from the data controller, data portability concerning personal data that you provided to the data controller, under certain conditions; (e) the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; and (f) the right to lodge a complaint with data protection authorities.

Additional information about your rights under the GDPR is available at the European Commission’s page on Data Protection.

Transfers of Personal Data

If you reside in a jurisdiction governed by the GDPR, we will not transfer your personal data to another jurisdiction unless permitted to do so under the GDPR. Your personal data may be transferred to our locations in Canada, and the European Commission has determined that Canada has adequate safeguards under the GDPR. Your personal data may be transferred to our service providers located in Canada or the United States. We only use US service providers who are participants in the EU – US Privacy Shield, or who have entered into standard contractual clauses with us, or who otherwise qualify under the GDPR to receive transfers of personal data. If you would like more information about our service providers, please contact us using the methods listed above under “Contact Us”.

When we disclose your personal data to third parties, we take reasonable measures to ensure that the rules set out in this privacy statement are complied with and that these third parties provide sufficient guarantees to implement appropriate technical and organisational measures to protect your personal data.