PRIVACY POLICY
Last modified February 20, 2024.
Our mission is crystal clear: to be the ultimate Multi Listing Service for shared-accommodation and settlement services, dedicated to international students who are embarking on their educational journey to call Canada their cherished home. To be your trustworthy partner, we strive to make clear how we use your information and protect your human right to privacy.
This Privacy Policy describes how Keywa Newcomers Network Ltd and its affiliates (“we,” “us,” or “Keywa”), process personal information that we collect through the Keywa Platform.
1. DEFINITIONS
Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).
Service providers refer to those who list a service on the Keywa Platform, including car, real property, or any services.
Service buyers refer to those who buy a service from a service provider.
Service providers and service buyers can be called as users on the platform.
2. PERSONAL INFORMATION WE COLLECT
We collect personal information about you when you use the Keywa Platform. Without it, you may not be able to transact with other users on the platform. This information may include:
• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, profile photo, occupation, language, and applicable licenses or degrees.
• Identity Verification: Such as images of your government-issued ID (as permitted by applicable laws) or other verification information
We DO NOT collect your payment information such as bank account or payment account information. The payment service will be provided by a third-party under their terms and conditions.
You can choose to provide us with additional personal information. This information may include:
• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums or blogs, post your introductory and/or tutorial videos, participate in promotions, communicate with our customer care team and other Members, or share your experience with us.
When you use the Keywa Platform, we automatically collect personal information. This information may include:
• Geo-location Information. Such as precise or approximate location determined from your IP address.
• Usage Information. Such as the pages or content you view, searches for services you have made, and other actions on the Keywa Platform.
• Log Data and Device Information. Such as details about how you’ve used the Keywa Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Keywa Platform. We may collect this information even if you haven’t created a Keywa account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
Keywa Platform does not provide any payment services. All payment actions will be made through Third-Party Payment Services. A third party providing payment services will collect your payment information, such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.
We collect personal information from other sources, such as:
• Third-Party Services. If you link, connect, or log in to the Keywa Platform with a third-party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• If you are invited to the Keywa Platform, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references. We may receive information about you and your activities on and off the Keywa Platform, or about your experiences and interactions from our partners.
3. HOW WE USE INFORMATION WE COLLECT
We use personal information to:
• enable you to access the Keywa Platform,
• enable you to communicate with other Members,
• perform analytics, debug and conduct research,
• provide customer service,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information such as your friends, we may process this information to facilitate your referral invitations, to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Keywa Platform, your search and transactions history, your profile information and preferences, and other content you submit.
We use personal information to:
• detect and prevent fraud, spam, and other harmful activity,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources,
• resolve disputes with our Members,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.4)
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Keywa Platform, your profile information and other content you submit to Keywa, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Keywa Platform if such processes detect activity that we think poses a safety or other risk to Keywa, our community, or third parties. If you would like to challenge the decisions based on the automated process, please contact us via the Contact Information section below.
We may use personal information to:
• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys or other promotional activities or events sponsored or managed by Keywa or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.
4.. SHARING & DISCLOSURE
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Keywa account or participating in promotional activities by Keywa partners or third parties.
Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Keywa or otherwise promote our products and services.
To help facilitate transactions or other interactions between Members, we may need to share certain information such as:
• When a service request is made by a user or dispute is submitted, certain information may be shared between users, including profile, name, cancellation history, review information, dispute outcome (when applicable) and other information you choose to share and submit.
• When a service request is confirmed, additional information is shared to assist with coordinating the transaction, like profile photo and phone number. When you as a service provider on the platform have a confirmed service, certain information is shared with the service buyer to coordinate the transaction, such as your chat box on Keywa.
You can make certain information publicly visible to others, such as: • Your public profile page, which includes your profile photo, full name, description, and city. • Your pages that include information such as calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share. • Reviews, ratings and other public feedback. • Content in a community or discussion forum, blog or social media post.
Information you share publicly on the Keywa Platform may be indexed through third-party search engines.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Keywa, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our agreements with Members, or (v) to protect the rights, property or personal safety of Keywa, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, user’s tax information may be shared with tax authorities or other governmental agencies.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Keywa, our Members, or expose Keywa to a claim of obstruction of justice.
For jurisdictions where Keywa facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose users’ information about transactions, such as names, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by users, and contact information.
In jurisdictions where Keywa facilitates or requires a registration, notification, permit, or license application of a service provider with a local governmental authority through Keywa in accordance with local law, we may share information of participating service providers with the relevant authority, both during the application process and, periodically thereafter, such as the service provider’s full name and contact details, tax identification number, occupations, and the number of transactions.
We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Keywa Services through third-party platforms and software tools, (vi) provide customer service or advertising, or (vi) facilitate non-profit and charitable activities consistent with Keywa’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.
If Keywa undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
5. OTHER IMPORTANT INFORMATION
We may review, scan, or analyze your communications on the Keywa Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes.
We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools.
We will not review, scan, or analyze your messaging communications to send third party marketing messages to you and we will not sell reviews or analyses of these communications.
You can link your Keywa account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends”. When you direct the data sharing by creating this link:
• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Keywa Platform may be displayed to your Friends on the Keywa Platform and/or that third-party service,
• a link to your public profile on that third-party service may be included in your Keywa public profile,
• other Keywa users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Keywa users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Keywa Platform through this linkage are subject to your settings and authorizations on the Keywa Platform and the third-party service.
Parts of Keywa may link to third-party services, not owned or controlled by Keywa, such as payment services. The use of these services is subject to the privacy policies of those providers. Keywa does not own or control these third parties and when you interact with them you are providing your information to them.
6. YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law.
You can access and update some of your personal information through your Account settings. If you connected your Keywa Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Keywa Account for fraud or safety reasons, we may retain information from that Keywa Account to prevent that Member from opening a new Keywa Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Keywa may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Keywa, even after your Keywa Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
7. SECURITY
While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
8. CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Keywa Platform will be subject to the revised Privacy Policy.
9. CONTACT INFORMATION AND RESPONSIBLE KEYWA ENTITIES
For questions or complaints about this Privacy Policy or Keywa’s handling of personal information, please contact support@keywacanada.com