Privacy Policy

Effective: November 10, 2018

1. KOPA PRIVACY POLICY

   Kopa (hereinafter referred to as “Kopa”, “we”, “us” or “our”) operates a platform and community marketplace that helps hosts and renters form offline experiences and connect directly with one another, where they can create, list, discover and book accommodations anywhere in North America, on our website (“Platform”).

   This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform.

2. DEFINITIONS

   Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Accommodation”, “Content”, “Services” etc.), it shall be given its definition as outlined in our Terms of Service.

   “Affiliates” means employers related by common ownership or control. They can be financial and non-financial employers.

   “Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

   “Data Controller” means Kopa, the employer responsible for the use and processing of Personal Information.

   “Third Parties” means employers or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial employers, or persons other than you and Kopa.

   “Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

   “Members” means users registered on the Kopa platform..

3. WHAT TYPES OF INFORMATION DOES KOPA GATHER ABOUT ITS USERS?
   1. Information that you give us

      We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

      • fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information. The required data for Members includes:
      • Renter Members: first name, last name, email address, graduation date, and program
      • Host Members: first name, last name, email address, and city
      • Intern Members through Kopa for Employers: Renter Member data along with phone number, profile image, and gender
      • Intern Members through Kopa for Employers (added by employers): first name, last name, email address, internship start, internship end, position, department, and office address.
      • Employer Members: first name, last name, email address, company name, company logo, and company address
      • access or use the Platform, such as to search for or post Accommodations, make or accept bookings, pay for Accommodations, 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 Kopa 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;
      • communicate with Kopa; and
      • share information with another Member within the platform through your profile or booking requests.
   2. Information we get from your use of our Platform

      We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

      • Mobile Data

      When you use certain features of the Platform, we may receive, store and process different types of information about your location, including general information (e.g. IP address, 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). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

      • 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 Kopa or logged in to your Kopa 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, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

      • Cookies and other Tracking Technologies

      Kopa uses cookies and other similar technologies, such as device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

      While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser. We track your activities if you click on advertisements for Kopa services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

      We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.

      • Third-Party social plugins

      Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

      As a result of this, you may send to the Third-Party 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, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

      Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.

4. HOW KOPA USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
   1. For all users we use, store and process information about you for the following general purposes: 
      • to enable you to access and use the Platform;
      • to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Booking process;
      • to operate, protect, improve and optimize the Platform, Kopa’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
      • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
      • to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Kopa, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you sign in to your Kopa Account;
      • to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Kopa or our Third Party business partners; and
      • 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.
      For hosts we also use, store and process information about you for the following general purposes: 
      • to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
   2. How Kopa Uses and Processes User Communications

      We may, either directly or through Third-Parties we engage to provide services to us, 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. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent actors from asking Renters to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. 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 Kopa, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

5. WHEN KOPA DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM

   IMPORTANT: When you use the Platform, your data may be sent to the United States, Canada and possibly other countries.

   Your Personal Information may be disclosed as follows: 

   1. 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 or other features on the Platform that are visible to the general public.
   2. As a Host, your public Listing page will always include some minimum information such as the city and neighborhood where the Accommodation is located, your listing description, your calendar availability, your public profile photo, and any additional information you share with other Members. Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Accommodation’s approximate geographic location on a map, such that a user can see the general area of the Accommodation.
   3. 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. We do not control the practices of Third-Party search engines.
   4. As a Renter, when you submit a request to book an Accommodation, your full name, and other Personal Information you agree to pass through to the Host will become visible to the Host of any Listing you Book or request to Book. We may also disclose parts of your public profile; and any additional information you share with other Members.
   5. When your request to book an Accommodation is accepted by the Host or when a Renter books your Accommodation, we will disclose some of your Personal Information to the Host and the confirmed Renter. However, your billing and payout information will never be shared with another user. If a Renter books an Accommodation for an internship, and the Renter is engaged or employed by a employer or other organization requests confirmation of the accommodation, we may disclose the name of the Host and the address and other Accommodation information to the Renter’s organization.
   6. When you stay at an Accommodation, we may ask you to review the Host, or the Accommodation. If you choose to provide a review, your review may be public on the Platform.
   7. You may link your account on a Third-Party social networking site to your Kopa Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:  
      • some of the information you provide to us from the linking of your accounts may be published on your Kopa Account profile;
      • your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;
      • a link to your public profile on that Third-arty social networking site may be included in your Kopa public profile;
      • other Kopa users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
      • other Kopa 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 site(s);
      • 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; and
      • the publication and display of information that you provide to Kopa through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.
   8. As a host, We may distribute parts of the Platform (including your Listing) for display on sites operated by Kopa’s business partners and affiliates, 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.
   9. We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (using Stripe or Modern Treasury). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
   10. For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Host Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Hosts and Renters expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes, including, but not limited to, personally identifiable information such as Host or Renter’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Hosts from Renters, or allegedly due, contact information and similar information, to the relevant Tax Authority.
   11. You acknowledge, consent and agree that Watson Holmes may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Watson Holmes; (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 Watson Holmes, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
       • providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
       • we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Kopa’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
       In instances where Kopa complies with legal requests for user data without notice to the user for the reasons described above, Kopa will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
   12. We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
6. KOPA DATA RETENTION POLICY

   We only keep your information for as long as we need it: (a) to provide you with a service; (b) for the purposes outlined in this policy; (c) to improve our services; and (d) for any legal and audit purposes. We will securely delete your information when it is no longer required for these purposes, in line with our company policies.

   When deleting your profile, we will securely delete all personal data with exception to:

   • listing reviews and user to user messages which will become anonymized.
   • listings which will become deactivated in order to allow retrieval in cases of accidental account deletion.
   • anonymized analytics for the purposes of improving our services.
7. HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR DELETE YOUR KOPA ACCOUNT

   You may review, update, correct or delete the Personal Information in your Kopa Account. If you would like to correct your information or delete your Kopa Account entirely, you can do so from your Account Settings.

8. BUSINESS TRANSFERS BY KOPA

   If Kopa 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.

9. SECURING YOUR PERSONAL INFORMATION

   We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

10. YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

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

    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.

11. SPECIAL FEATURES AND PROGRAMS
    1. Referral service and requesting references

       The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform.

       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 Kopa does not collect or retain the contact information that is used to send them.

       You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Kopa in response to your referral.

    2. Meetups

       The Platform may allow registered account holders to organize, search for or participate in offline events (“Meetups”) in selected cities.

       If you organize a Meetup or indicate that you will attend one, this information, together with some of your public information (such as your profile photo and public profile page) and any messages that you post about that Meetup, will be visible to users who browse the event. Events are only accessible to authenticated Members of the platform. However, Kopa will never disclose where you are staying to another meetup user.

12. CHANGES TO THIS PRIVACY POLICY

    We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. 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. We will also update the “Last Updated” date at the top of this Privacy Policy. 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.

    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 and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Kopa Account. You can find out more about how to deactivate your Kopa Account.

13. GOT FEEDBACK?

    Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at [email protected]. For all other questions or concerns, please contact us.

14. COOKIE POLICY

    Kopa 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.

    Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

    1. Kopa cookies and Third Party cookies

       Kopa may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

       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.

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

       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.

    2. Other 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. Uses for Kopa cookies

       Kopa uses cookies and similar tracking technologies for a number of purposes, such as the following: 

       • to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.
       • to simplify your access to and use of the Platform and make it more seamless.
       • to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
       • to show you content (which may include advertisements) that is more relevant to you.
       • for fraud detection and prevention.
    4. Uses for Third-Party cookies

       Our partners’ cookies are intended to obtain information to help them provide services to Kopa. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise Kopa listings or services to you on the Platform and Third-arty websites, or to help us detect or prevent fraud or conduct risk assessments.

       In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services.

    5. Disabling Cookies

       Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform.

    6. Changes to this Cookie Policy

       We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

       It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your Kopa Account.