Introduction
Sparrow Living Inc. (“Sparrow”, “us”, “we” or “Company”) respects your privacy and is committed to protecting it by complying with this policy.
This policy describes:
- How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
- Describes the types of information we may collect from you or that you may provide when you visit the website sparrowliving.co (our “Website”).
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect, use, or disclose about you:
- On our Website or using its functionality.
- In email, text, and other electronic messages between you and our Website.
- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website; and
- When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using our Website, you indicate that you understand, accept, and consent to the practices described in this policy.
This policy may change from time to time. Your continued use of our Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.
Privacy laws generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
We collect personal information in order to respond to inquiries and provide homesharing services.
This information includes:
- Correspondence Information: As part of our customer services experience, we collect correspondence information that is provided to us through our website, phone calls, surveys, contests, promotions, and legal agreements.
- Account Information: Depending on which services you use, this may include your first name, last name, phone number, postal address, email address, date of birth, and profile photo, and other similar information when associated with you.
- Screening Information: If you seek to enter into a homesharing agreement, we will perform various types of background checks such as a public court record search, adverse media scan, searching fraud watchlists, collecting information about known affiliations, search lists of global sanctions and enforcement, public safety check, sex offender registry check, global clearance check, public profile scan and niche data sanctions and enforcement. We may ask you to share or upload government-issued identification (as permitted by applicable laws) to support with identity verification.
- Payment Information: If you enter a homesharing agreement, we will collect information used to process payments such as payment amounts, credit card number, bank account or payment account information.
- Statistical Information: We may also use digital technologies to collect non-personal information about your online activities over time and across third-party websites or other online services (behavioural tracking) including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain parts of our Website, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number. To learn more or to opt-out of behavioural tracking, please contact our team at help@sparrowliving.co.
- Technical Information: This includes your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
- Support Information: You may also provide us with information when you respond to surveys, communicate with our support centre about a support question or post a question in our public forums. When you communicate with us via form, email, phone, or otherwise, we may store a copy of our communications (including any call recordings as permitted by applicable law).
- Job Applicant Information: If you apply for a job with us then you may provide us with information such as your name, contact information, resume or CV, and work authorization verification as part of the application process.
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Website.
- Usage Information: We collect information about your usage of our Website. For example, we collect information about the actions that you perform on our Website, in other words, who did what and when. We also collect information about what happens when you use our Website (e.g., page views, searches and interactions with us) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Website services to you, get insights on how people use our Website so we can make our services better, and understand and make predictions about user needs.
- Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people use our Website from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions.
- Information from Cookies & Other Technologies: A cookie is a string of information that our Website stores on your computer, and that your browser provides to our Website each time you return. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Our Website uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Website services.
We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Due to the nature of our services, the removal of your personal information from our platform will affect your ability to enter a homesharing agreement. We will only use your personal information in accordance with this policy unless otherwise required by applicable law.
We collect personal information from you when you create an account, apply to share a home, communicate with us using our web forms to make a request or ask a question, or otherwise submit personal information to us with your communication.
This includes:
- Direct Interactions: We collect personal information provided to us through website forms, phone calls, emails or other forms of correspondence with our company.
- Automated Interactions: Our platform uses automated technologies, such as cookies or web beacons, to collect information about your interactions including usage details and IP addresses. Please see sections 3.1 and 3.2 below for more information.
- Accounts & Profiles: You may also provide information for us to publish or display on public Website areas such as your account profile or home listing.
Although we limit access to certain information and provide privacy settings for your account, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your information. Therefore, we cannot and do not guarantee that unauthorized persons will not view your profile.
Automated Data Collection
The information we collect automatically is statistical data and does not include personal information. We may maintain it or associate it with personal information provided by you during our direct interactions or collect from third parties. This information helps us to improve our Website and to deliver a better and more personalized service, including:
- Estimating our audience size and usage patterns.
- Storing information about your preferences, allowing us to customize our Website according to your individual interests.
- Providing greater accuracy in your matches and searches.
- Recognizing you when you return to our Website.
How We Collect Automated Data
Automated technologies collect non-personal information about your website usage, behaviours and interactions. The technologies we use for this automatic data collection may include:
Browser Cookies
A cookie is a small file placed on the hard drive of your computer. If you have registered an account with us, these cookies (1) may let us know who you are, (2) may be necessary to access your account information stored on our computers and (3) will provide us and our service providers with information that we will use to personalize our website in accordance with your preferences.
You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies
Certain features of our Website may use local stored objects (or Flash cookies to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
Web Beacons
Pages of our Website and our emails may contain small electronic files known as web beacons, also referred to as clear gifs, pixel tags, and single-pixel gifs, that permit the Company to understand customer behaviors. For example, web beacons may count the number of users who have visited those pages, opened an email or accessed certain website content.
Google Analytics & Mixpanel
We use Google Analytics and Mixpanel as our third-party platforms to help us analyze how users use our website and services. These platforms provide us with non-personal information including but not limited to the pages you visit, number of sessions, time on page, and the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by our company to evaluate your use of the Services.
We use your personal information to provide our services and manage our business operations.
This may include:
- To fulfill the intended or described purposes for which you provided the information;
- To provide you with information, product and services as requested and to provide such products and services, including payment and mediation services;
- To match you with another home sharer;
- To present and improve our Website and its contents;
- To create, authenticate and administer your account;
- To communicate with you about your account or services being used;
- To contact you about customer service issues;
- To notify you of any changes or updates to our Website, products or services;
- To detect and prevent fraud and other unauthorized or illegal activities;
- To protect the security or integrity of our Website and our business;
- To carry out our obligations and enforce our rights arising from any obligation you have to us;
- To provide you with resident liability insurance through third parties;
- In any other way we may describe when you provide the information;
- For any other purpose with your consent.
We may obtain your consent to use your contact information to send you marketing or promotional communications by mail, email or telephone. This may include marketing related to our products and services from our affiliates and partners. If you would like to verify the personal information we have collected or opt out of communications, please contact help@sparrowliving.co and we will take the necessary steps to remove your profile and contact information from our mailing lists. Please note that you may continue to receive certain transactional or informational communications from us in conjunction with active services you are using.
Advertising
We use cookies and other tracking technologies, such as Google Analytics, to help us deliver personalized communications and advertising through devices such as desktop computers, tablets and mobile phones. These tracking tools allow us to:
- Help serve interest-based advertising to potential customers
- Track marketing content and interactions
- Optimize our advertising and content delivery
- Report on traffic to our Website and social media channels
- Inform our services and product development
Advertising and communication may be delivered directly from the company or through third-party ad networks and ad services. These third parties may serve tailored marketing to you using their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We do not have access to third-party cookies or governance of how they may be used outside of our platform. As such, third-party cookies and tracking technologies are not covered as part of this Policy.
If you would like to understand how to manage cookies or opt out of targeted advertising, you can visit the Network Advertising Initiative’s (NAI) Consumer Opt-Out Website and/or the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Website for assistance. You can also opt out of Google Analytics for Display Advertising or customize Google Display Network ads by visiting the Google Ads Settings page. These services are provided by third parties and will not be covered as part of this Policy. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
In some cases, you may still receive or encounter advertising from our company on your devices, even after you opt out of targeted advertising. The advertisements may be delivered through integrated advertising services but would not be served to you based on your actions, behaviours, interests or interactions. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the company may assume that you meet its target criteria.
Links to Third Party Websites
You may be able to access third-party websites through links available on our Website. These links are provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites is at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Policy.
Children Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18.
If you are under 18, do not use or provide any information on our Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at help@sparrowliving.co.
We may share or disclose your personal information as described in this Policy with our business partners or service providers for the following reasons:
- To enable services from select third parties including but not limited to insurance, background checks, payment processing, or advertising.
- To receive business operations support from our affiliates.
- To respond to your requests or facilitate services at your direction.
- To protect or defend the rights, safety, or property of the company, its affiliates, employees, users and/or the public, including to defend or enforce our Privacy Policy, our Terms of Use, or any other contractual arrangement.
- To comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
- In connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- As part of a contractor, service provider, and other third party agreement to support our business.
- To share amongst parties interested in connecting and homesharing with each other through our website, application or services.
As part of our agreements, we require our business partners, service providers and contractors to keep your personal information secure. Our third-party affiliates may not use or disclose personal information for any purpose other than to perform their designated functions. From time to time, we may share aggregate/anonymous information about use of the Services, such as by creating reports on usage trends. The sharing of such data is unrestricted.
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Data Security
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
This includes:
- Storing all information you provide to us behind firewalls on our secure server.
- Encrypting transactions using a SSL technology and processing payments through a PCI DSS compliant Level 1 Service Provider.
- Limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Data Storage
Your personal information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. Contact information and preferences can be updated as needed in the platform through your profile settings. You may request to access, update and correct inaccuracies to personal information we have in our control by emailing or writing to us at the contact information set out below.
We may also request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. Please keep us informed if your personal information changes. Please note that we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. Personal information may be required to access our services and removal of this information will impact your ability to participate in a homesharing arrangements. If you would still like to withdraw your consent, you can contact us at help@sparrowliving.co and we will work with you to remove your personal information from our platform.
Changes to Our Privacy Policy
We include the date the privacy policy was last revised at the top of the page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Questions or Complaints
If you have a question or complaint about our personal information handling practices, please contact us by email at help@sparrowliving.co or by mail at the following address:
Sparrow Living Inc.
Attn: Oren Singer, President & CEO
PO Box 599 Toronto C
M6J 3P6
Toronto ON