Plextell Privacy Policy

This Privacy Policy applies to personal information collected through:

• the Plextell website;
• Plextell accounts;
• Host Listings;
• booking and application processes;
• identity-verification processes;
• payments and payouts;
• communications;
• customer support;
• trust-and-safety activities; and
• other services that link to this Privacy Policy.

This Privacy Policy does not govern the independent privacy practices of third parties.

Plextell is responsible for personal information under its control.

We designate a person responsible for privacy compliance.

Privacy questions, access requests and complaints may be directed to:

• Privacy Officer
• HIVRONIX, Inc.
• Email: support@30andliving.com

The information we collect depends on how you use Plextell.

A. Account and Contact Information

We may collect:

• full name;
• email address;
• telephone number;
• account credentials;
• preferred language;
• profile information;
• country or region;
• account role;
• communication preferences; and
• other information you provide when creating or maintaining an account.

B. Identity Verification Information

Where verification is required, we or our verification providers may collect:

• date of birth;
• government-issued identification type;
• issuing country;
• document number or portions of it;
• identification images;
• photograph;
• selfie;
• liveness-verification information;
• verification status;
• verification results; and
• fraud or authenticity indicators.

We seek to collect and retain only identity-verification information reasonably necessary for verification, fraud prevention, security and legal compliance.

Where a third-party identity provider performs verification, that provider may process information directly under its own privacy terms and our contractual arrangements.

C. Host Information

For Hosts, we may collect:

• property address;
• property photographs;
• property description;
• ownership or management information;
• proof of authority to list;
• rental availability;
• pricing;
• house rules;
• tax information where required;
• payout information;
• business information; and
• information necessary to administer Listings.

D. Renter and Booking Information

We may collect:

• desired location;
• requested dates;
• booking history;
• number of occupants;
• booking requests;
• accommodation preferences;
• Stay Agreements;
• payment status;
• cancellation information;
• move-in or move-out information; and
• other information associated with a booking.

Where a Host requests lawful screening information through the Platform, additional information may be collected as disclosed at the time.

E. Payment and Transaction Information

We may collect:

• transaction amount;
• currency;
• payment status;
• billing information;
• payment-provider identifiers;
• payout information;
• refunds;
• chargebacks;
• transaction history; and
• tax-related information where required.

Complete payment-card information may be collected directly by a third-party payment processor rather than stored by Plextell.

F. Communications

We may collect communications you send through or concerning Plextell, including:

• Host-Renter messages;
• emails;
• support requests;
• complaints;
• dispute information;
• surveys; and
• communications with our team.

G. Device and Technical Information

When you use the Platform, we may automatically receive:

• IP address;
• device type;
• browser type;
• operating system;
• language;
• approximate location derived from IP;
• device identifiers;
• referring URL;
• pages viewed;
• session information;
• timestamps;
• cookie identifiers;
• crash information; and
• security logs.

H. Fraud, Security and Trust Information

We may collect or generate information relating to:

• suspicious login activity;
• identity inconsistencies;
• account abuse;
• fraudulent payments;
• prohibited conduct;
• property complaints;
• safety incidents;
• chargeback history; and
• actions taken to protect the Platform.

I. Information From Third Parties

We may receive information from:

• identity-verification providers;
• payment providers;
• fraud-prevention providers;
• Hosts;
• Renters;
• referral partners;
• service providers;
• public sources; and
• governmental or law-enforcement authorities where lawful.

We use personal information for purposes that a reasonable person would consider appropriate in the circumstances, including to:

Provide the Platform

• create accounts;
• authenticate users;
• maintain profiles;
• display Listings;
• process booking requests;
• enable Host-Renter communications;
• create transaction records; and
• provide customer support.

Process Transactions

• authorize payments;
• facilitate payouts;
• process refunds;
• manage chargebacks;
• issue transaction records; and
• administer fees and taxes.

Verify Users

• verify identity;
• verify contact information;
• verify authority to list a property;
• detect falsified documents; and
• reduce impersonation and fraud.

Protect Users and Plextell

• identify suspicious activity;
• prevent fraud;
• investigate complaints;
• enforce our Terms;
• secure accounts;
• resolve disputes; and
• protect legal rights.

Improve the Platform

• understand how people use Plextell;
• troubleshoot errors;
• analyze Platform performance;
• improve search and user experience;
• develop new features; and
• conduct internal research and analytics.

Communicate With You

• send booking confirmations;
• send verification notices;
• send security alerts;
• send payment notices;
• provide service updates;
• respond to requests; and
• provide other transactional communications.

Marketing

Where permitted by law and where appropriate consent has been obtained, we may:

• send newsletters;
• announce new locations or features;
• send offers;
• personalize marketing; and
• measure marketing effectiveness.

Legal and Regulatory Purposes

We may process information to:

• comply with legal obligations;
• respond to lawful orders;
• maintain required business records;
• establish or defend legal claims;
• investigate prohibited conduct;
• comply with tax requirements; and
• cooperate with regulators or authorities where required.

Where consent is required, we seek meaningful consent appropriate to the sensitivity of the information and the circumstances.

Some information is necessary to provide a requested service.

For example, we may not be able to provide a verified Host or Renter account without information reasonably necessary to perform verification.

You may withdraw consent to optional processing, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent does not affect processing that was lawfully completed before consent was withdrawn.

A marketplace requires certain information to be shared between parties.

Depending on the stage of a transaction, a Host may receive information such as:

• Renter name;
• profile information;
• verification status;
• booking request;
• requested dates;
• number of occupants;
• messages; and
• information reasonably necessary to evaluate or administer a booking.

A Renter may receive information such as:

• Host name;
• profile;
• verification status;
• Listing information;
• property information;
• house rules;
• contact information where appropriate; and
• information necessary to enter into or administer a Stay Agreement.

We do not authorize Hosts or Renters to use information obtained through Plextell for unrelated marketing, harassment, discrimination or other unauthorized purposes.

We may disclose information to service providers that help us operate Plextell.

These may include providers of:

• cloud hosting;
• database infrastructure;
• payment processing;
• identity verification;
• fraud detection;
• cybersecurity;
• communications;
• email delivery;
• SMS delivery;
• customer support;
• electronic signatures;
• document storage;
• maps;
• analytics;
• accounting;
• legal services; and
• other business infrastructure.

Service providers receive only information reasonably necessary for the services they perform and are subject to applicable contractual and legal obligations.

Payment information may be processed by third-party payment processors.

Payment processors may independently collect information necessary to:

• authenticate payment methods;
• prevent fraud;
• process payments;
• complete payouts;
• conduct legally required verification; and
• comply with financial laws.

Their processing may also be governed by their privacy policies.

We may use specialized verification providers to verify identity documents or other information.

Information transmitted to a verification provider may include:

• government-issued identification;
• document images;
• selfies;
• liveness information;
• name;
• date of birth; and
• technical information needed to detect fraud.

Where possible, Plextell may receive a verification result or status instead of retaining full verification materials indefinitely.

We may disclose personal information where we reasonably believe disclosure is necessary and permitted or required by law to:

• comply with a subpoena, warrant, court order or other lawful process;
• respond to a governmental authority;
• investigate fraud or illegal conduct;
• protect the safety of a person;
• enforce our agreements;
• establish, exercise or defend legal claims; or
• protect the rights or property of Plextell or others.

We will evaluate governmental requests in accordance with applicable law.

If Plextell participates in a merger, financing, acquisition, corporate reorganization, sale of assets or similar transaction, personal information may be disclosed as permitted by applicable law.

Any successor handling the information will be required to process it in accordance with applicable legal obligations.

Plextell does not operate a business whose purpose is selling users’ personal information to unrelated third parties for their independent use.

If our practices change in a manner that legally constitutes a sale or sharing requiring additional notice or choice, we will provide the controls required by applicable law.

Plextell may use cookies, local storage, pixels and similar technologies.

These technologies may be used for:

• authentication;
• security;
• remembering preferences;
• maintaining sessions;
• fraud prevention;
• analytics;
• performance;
• feature functionality; and
• marketing where permitted.

Where required by law, non-essential cookies will be subject to appropriate consent controls.

Your browser may allow you to block or remove cookies. Some Platform functions may not work properly if essential cookies are disabled.

We may use analytics services to understand how users interact with the Platform.

Analytics information may include:

• pages visited;
• interactions;
• approximate location;
• device information;
• referral source;
• session length; and
• technical events.

We use this information to improve performance, design and functionality.

Plextell distinguishes between service communications and marketing communications.

Service communications may include:

• verification notices;
• security alerts;
• booking information;
• agreements;
• payment notices;
• support messages; and
• important policy information.

These may be necessary to operate your account.

Marketing communications may be sent only where permitted by applicable law.

For commercial electronic messages subject to Canada’s Anti-Spam Legislation, Plextell will use the applicable consent basis, identify the sender as required and provide an unsubscribe mechanism.

You can unsubscribe from marketing emails using the link contained in the message or by contacting us.

We will process unsubscribe requests within the period required by applicable law.

We retain personal information only for as long as reasonably necessary for identified purposes and applicable legal requirements.

Retention periods vary depending on the information.

Relevant factors include:

• whether your account remains active;
• ongoing bookings;
• payment-processing requirements;
• tax and accounting requirements;
• dispute limitation periods;
• fraud-prevention needs;
• safety investigations;
• legal obligations; and
• regulatory recordkeeping requirements.

When information is no longer reasonably required, we will delete, anonymize or securely dispose of it, subject to applicable law.

Verification materials may be subject to shorter retention periods where full document retention is unnecessary.

You may request deletion or closure of your Plextell account.

Closing an account does not necessarily result in immediate deletion of all information.

We may retain information where reasonably required for:

• an existing Stay Agreement;
• transaction records;
• fraud prevention;
• chargebacks;
• tax obligations;
• legal claims;
• safety investigations;
• regulatory compliance; or
• other lawful purposes.

Information no longer required will be deleted or anonymized in accordance with our retention practices.

Plextell uses administrative, technical and organizational safeguards designed to protect personal information against:

• loss;
• theft;
• unauthorized access;
• unauthorized disclosure;
• misuse;
• alteration; and
• destruction.

Safeguards may include:

• access controls;
• authentication controls;
• encryption where appropriate;
• logging;
• monitoring;
• secure infrastructure;
• vendor management;
• incident-response procedures; and
• access limitations based on business need.

No internet or storage system is completely secure, and we cannot guarantee absolute security.

Plextell maintains procedures for evaluating and responding to security incidents involving personal information.

Where Canadian privacy law requires notification of a breach presenting a real risk of significant harm, we will make required reports and notifications.

We will also maintain records of security breaches for the period required by applicable law.

Plextell and its service providers may process or store personal information outside the province or country where you live.

As a result, information may be subject to the laws of the jurisdiction where it is processed and may be accessible to courts, governments, law-enforcement or national-security authorities in accordance with those laws.

Plextell remains responsible for personal information under its control as required by applicable law and uses contractual or other measures appropriate to service-provider arrangements.

You may contact our Privacy Officer for additional information about our use of service providers outside Canada.

Subject to applicable exceptions, you may request access to personal information that Plextell holds about you.

We may need to verify your identity before responding.

Where required by law, we will also provide information about the use or disclosure of your personal information.

Certain information may be withheld where permitted or required by law, including information that would reveal another person’s personal information or legally privileged information.

You may request correction of personal information that you believe is inaccurate or incomplete.

Some account information may be changed directly through your account.

Where information cannot be changed directly, you may contact us.

Where processing is based on consent, you may withdraw that consent, subject to:

• legal restrictions;
• contractual requirements;
• reasonable notice; and
• information that is necessary to provide requested services.

We will explain material consequences of withdrawal where appropriate.

If you have concerns about our privacy practices, please contact our Privacy Officer first.

We will investigate privacy complaints and respond appropriately.

Canadian individuals may also have the right to raise a complaint with the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.

Plextell may use technological tools to identify:

• suspicious account creation;
• unusual transactions;
• identity inconsistencies;
• payment fraud;
• account compromise; or
• other Platform abuse.

These tools may flag an account for additional verification or manual review.

Where applicable law provides rights concerning automated decision-making, Plextell will provide required information and mechanisms.

Information collected through Plextell must not be used by Hosts to engage in unlawful housing discrimination.

Hosts are responsible for ensuring that screening and housing decisions comply with applicable human-rights law.

Plextell may restrict access to information where appropriate to reduce misuse and discriminatory decision-making.

Plextell is not directed toward children.

We do not knowingly permit individuals who lack legal capacity to enter Platform transactions unless the transaction is handled in a manner specifically permitted by applicable law.

If you believe a child has submitted personal information improperly, contact us at support@30andliving.com.

The Platform may contain links to third-party websites or services.

Their privacy practices are governed by their own policies.

We encourage users to review those policies before submitting information.

Depending on your use of the Platform and applicable law, you may be able to:

• update account details;
• modify communication preferences;
• unsubscribe from marketing;
• request access;
• request correction;
• withdraw certain consent;
• request account closure; and
• raise a privacy complaint.

Contact support@30andliving.com for assistance.

Users located outside Canada may have additional rights under local privacy legislation.

Where a law applicable to Plextell grants rights beyond those described in this Privacy Policy, Plextell will honour those rights as legally required.

Plextell may provide jurisdiction-specific supplemental privacy notices where necessary.

We may update this Privacy Policy when our:

• products;
• technology;
• service providers;
• information practices; or
• legal obligations

change.

The date at the top identifies the latest version.

Where required, we will provide additional notice or obtain additional consent for material changes.

Questions about this Privacy Policy or our handling of personal information may be directed to:

• Privacy Officer
• HIVRONIX, Inc.
• Operating as Plextell
• support@30andliving.com

General support inquiries may be sent to the same address.