Privacy Policy

1.Who is responsible for your information

Lodge N Key Inc. ("LNK", "we", "us", or "our") operates Lodge N Key and is responsible for personal information under its control. We designate a Privacy Officer to oversee our privacy program, service-provider safeguards, privacy requests, incident response, and complaints.

2.Information we collect

The information LNK collects depends on how you use the platform and which features are enabled. We limit collection to information reasonably necessary for identified onboarding, verification, compliance, security, support, marketplace, and transaction purposes.

• Account and contact information, such as name, email address, telephone number, authentication identifiers, account role, notification preferences, and support history.
• Partner and business information, such as legal name, date of birth, business or management role, authorized signer information, mailing and billing addresses, onboarding-call availability, Revenue Share status, and payout or tax onboarding information when those functions are enabled.
• Partner identity information, including document type, issuing country or region, expiry date, document images, review status and notes, verification result, and encrypted copies of supported government-issued photo ID submitted through the current direct-review process. An approved verification provider may later collect or return limited verification information under the notice provided before that process is used.
• Property and listing information, including property address, the responsible legal accommodation supplier and representative authority, ownership or authority evidence, insurance, required municipal licence or registration material, verification records, photos, listing content, accessibility information, safety information, availability, compliance history, and the property coverage recorded for Founding benefits.
• Property-visit information, including requested times, onsite contact and access instructions, visual observations, verification notes, safety and accessibility observations, incident information, and photographs or video reasonably needed to document the areas, features, condition, or evidence being reviewed.
• Transaction and payment information when booking or payout features are enabled. Payment-card and bank details may be collected directly by payment providers rather than stored by LNK.
• Technical, security, and usage information, such as IP address, user agent, device or session identifiers, timestamps, authentication events, operational logs, upload and media-processing metrics, security events, and audit records.
• Communications and evidence submitted through support, messaging, appointment, review, dispute, claim, privacy, or compliance workflows.

3.Purposes for collection and use

LNK identifies the purposes for personal-information collection at or before collection and uses information for those purposes or for another purpose permitted by law.

• Create and secure accounts, authenticate users, verify email addresses, administer access controls, and maintain reliable acceptance and audit evidence.
• Assess Partner applications; verify identity, age, authority, and contracting information; detect altered or fraudulent documents; and make approval, restriction, renewal, or offboarding decisions.
• Review properties and listings, schedule and conduct property visits, compare submitted information with observed conditions, document listing standards, request remediation, and maintain verification history.
• Operate listings, communications, support, fraud prevention, security monitoring, auditability, incident response, legal holds, and policy enforcement. Once public use is enabled under the Terms of Service, publish and promote authorized public listing content to market the listing or LNK through the channels described there. Prepared listings remain private during the controlled Partner-only phase; private identity, compliance, and verification evidence is excluded from advertising unless particular content is separately and lawfully authorized for public use.
• When enabled, process booking, payment, refund, deposit, payout, tax, Revenue Share, Traveler-verification, and dispute workflows.
• Send essential account, security, verification, agreement, appointment, booking, payment, renewal, and compliance communications, plus optional communications where consent or another lawful basis applies.
• Improve reliability and performance using operational measurements and aggregated or de-identified information where appropriate.
• Meet legal, tax, regulatory, court, law-enforcement, insurance, audit, and recordkeeping obligations and establish, exercise, or defend legal claims.

4.Consent, necessary processing, and choices

Where consent is the appropriate basis, LNK seeks meaningful consent having regard to the sensitivity of the information and the reasonable expectations of the individual. Information that is necessary to assess or maintain Partner eligibility is not used for unrelated purposes merely because it was supplied during onboarding.

• Before an identity-document upload, LNK presents a just-in-time explanation and requires an express confirmation covering the document collected, verification purpose, authorized review, service-provider processing, cross-border processing, retention periods, safeguards, and consequences of refusing or withdrawing consent.
• You may decline a requested identity upload or verification process. LNK may then be unable to complete or maintain the verification and approve or continue the relevant service. Where an appropriate alternative verification method is available, LNK may offer it. LNK does not collect more sensitive information than reasonably necessary merely because refusal would prevent approval.
• You may withdraw consent to a consent-based use on reasonable notice, subject to legal, contractual, security, fraud-prevention, recordkeeping, or dispute restrictions. Withdrawal does not make prior lawful processing unlawful and may prevent LNK from continuing a service that reasonably requires the information.
• Optional marketing or general update preferences do not disable essential transactional, security, verification, agreement, appointment, booking, payment, renewal, or compliance notices.
• We do not require consent to unrelated collection, use, or disclosure as a condition of a requested service unless permitted by law. Acceptance or acknowledgement of this Privacy Policy is not blanket consent to undisclosed purposes, biometrics, background checks, behavioural advertising, or future sensitive processing. Separate meaningful consent is obtained where required.

5.Partner identity-document handling

Partner identity files are private, are never displayed on a public profile or listing, and are protected through application-layer encryption, malware scanning, access controls, private object storage, and durable access and lifecycle auditing. Administrative access is limited to authorized verification, security, privacy, legal, and support purposes and is recorded.

• LNK uses the document to confirm the applicant's identity, age and document validity, compare the identity with the application and authorized signer information, identify fraud or material inconsistency, conduct re-verification, and maintain evidence of the decision.
• LNK does not sell identity information, use it for behavioural advertising, or intentionally expose it to another Partner or Traveler.
• Approved Partner identity raw files are scheduled for deletion 30 days after approval.
• Rejected or withdrawn Partner identity raw files are scheduled for deletion 90 days after the final decision.
• A replaced Partner identity raw file is scheduled for deletion 30 days after replacement.
• Partner identity metadata and audit history are retained for the life of the Partner account plus two years, subject to legal hold and lawful retention requirements.
• For an incomplete application with no meaningful applicant activity for 90 days, LNK ordinarily sends notice and allows 30 days to resume or explain a continuing need. If there is no response, the application is treated as withdrawn and the 90-day raw-file deletion period begins. An extension must have a documented verification or legal purpose and a review date; a pending status alone is not a basis for indefinite raw-ID retention.
• These raw-file periods govern the current LNK-controlled direct-review process. Before introducing an outside identity provider, LNK will explain who collects and retains the files, what LNK receives, relevant processing locations, retention, and any materially different checks. A provider's involvement does not silently extend LNK's own retention period or permit unrelated reuse.

6.Property documents and verification visits

LNK uses property documents and visit records to assess authority, insurance, regulatory and listing readiness, safety and accessibility representations, property condition, and compliance with Listing Quality Standards. Visit records are not public unless they are separately selected and authorized as public listing content.

• The Partner must have authority to provide onsite contact details and access instructions and must notify or obtain authorization from owners, occupants, staff, or other affected individuals as required before the visit.
• LNK reviewers are instructed to avoid intentionally capturing identity documents, financial records, computer screens, personal correspondence, medication, intimate items, or people who are not reasonably necessary to the verification record. Partners should secure or remove such items before the visit.
• If a person is incidentally captured or personal information is unnecessarily recorded, the Partner or affected person may contact the Privacy Officer so LNK can assess restriction, correction, redaction, or deletion consistent with verification, legal, and recordkeeping needs.
• Current property-compliance files are retained while active and reasonably relied upon. Replaced, rejected, or expired raw compliance files are retained for two years from that event. If a current file ceases to be relied upon because a property is withdrawn or the relationship ends, the two-year period starts on that date. Unnecessary incidental personal information may be removed sooner.
• Property verification metadata, visit evidence, and related audit history are ordinarily retained for six years from the relevant visit, decision, or recorded event. Evidence still reasonably needed to support an active verification may be retained while relied upon, with a recorded reason and periodic review. A shorter period applies where the purpose no longer justifies retention; a longer documented legal hold or lawful requirement may apply.
• Pending property submissions are reviewed for inactivity under the incomplete-application process above. Once withdrawn, their compliance documents follow the two-year period unless a shorter period is sufficient, and private identity files continue to follow their shorter identity schedule.

7.Traveler verification when enabled

The adult who makes a booking must complete the verification identified for the enabled booking process and must stay at the property. Other adult guests are not automatically required to complete the booking adult's verification. A separately approved business or third-party booking process may impose different, clearly identified requirements on the booker and staying adult before confirmation. LNK may request further information reasonably necessary to address a specific lawful safety, identity, fraud, or compliance concern.

• Before collecting Traveler government identification, a selfie or liveness recording, biometric information, or background-check information, LNK will identify the actual information, purpose, provider, disclosures, relevant processing locations, retention, consequences of refusal, safeguards, and required consent or other lawful authority. This policy does not represent that all those checks currently occur or authorize their introduction without that notice and any required consent.
• A Traveler is shown as having completed an LNK verification step only after that process is enabled and completed for the account. The meaning and scope of a label must match the actual check.
• Verification is a risk-control measure and does not guarantee identity, future conduct, safety, creditworthiness, or suitability. A change in provider or method may require renewed verification, with updated notices and consent where required.

8.Service providers and disclosures

LNK uses service providers to support authentication, cloud hosting, databases, private storage, email, mapping, malware scanning, security, media processing, payment services, and other platform operations. We disclose personal information only as reasonably necessary for the service, a transaction, safety, legal compliance, or another identified purpose.

• LNK remains accountable for personal information transferred to a service provider for processing and uses contractual, technical, or organizational safeguards appropriate to the circumstances.
• Service-provider personnel may access information only where needed to provide, secure, troubleshoot, or support their service under applicable restrictions.
• Information may also be disclosed where required or permitted by law, including to courts, regulators, law-enforcement authorities, tax authorities, insurers, professional advisers, emergency services, or counterparties to a corporate transaction subject to appropriate safeguards.
• For an enabled booking, LNK discloses to the responsible accommodation supplier or its authorized operator the contact, guest, booking, and relevant issue information reasonably needed to deliver the stay and address safety, support, claims, and legal obligations. Raw identity files are not routinely shared with a Partner. Public listings and reviews contain only information designated for public use; sensitive access details are limited to people who need them.
• Partners are responsible for their own handling of information they receive for accommodation operations, subject to law and the Partner Terms. LNK prohibits unrelated marketing, unauthorized disclosure, and unnecessary retention of Traveler information.
• LNK does not sell personal information to advertisers. Public listing promotion under the content licence does not authorize advertising providers to use private identity or account records.

9.Cross-border processing

LNK and its service providers may process or store personal information in Canada, the United States, and other jurisdictions. Information in another jurisdiction may be subject to the laws and lawful access powers of that jurisdiction. LNK remains accountable for information transferred to a service provider for processing under applicable Canadian privacy law.

10.Cookies, sessions, and analytics

LNK uses cookies, local storage, session technologies, and similar mechanisms that are necessary for authentication, security, privacy preferences, and reliable operation. Necessary technologies remain available because the requested service cannot operate reliably without them. Optional first-party marketing analytics is disabled by default and begins only after the visitor selects Accept analytics. A visitor may instead select Necessary only or change the choice at any time through Privacy preferences.

• The optional first-party analytics stream records defined funnel events and times, approved page categories, coarse device category, a random identifier stored for the browser session, the referring site's origin, and approved non-personal campaign codes. LNK applies field restrictions and controls intended to prevent names, contact details, access tokens, private application or property references, and free-form user input from being recorded in this stream. Unknown page paths and campaign values are omitted; referring paths, query strings and fragments are not recorded. The random session identifier supports session-level measurement and is not a guarantee that the data is anonymous. Operational and security records are handled separately as described in this policy.
• The analytics record has no fields for account IDs, names, email addresses, free-form content, cookies, request IP addresses or user-agent strings. LNK does not deliberately add those values to its approved measurement fields. LNK does not use this stream for behavioural advertising or cross-site profiling.
• The privacy choice is stored in local storage. Selecting Necessary only or withdrawing analytics consent clears the analytics session identifier and prevents new optional events. LNK also respects enabled Global Privacy Control and browser Do Not Track signals for this stream.
• At this release, LNK does not use third-party advertising pixels or behavioural advertising trackers. Permission to advertise listing content does not change this analytics practice. Before materially expanding analytics fields, purposes, retention, or providers, LNK will update its assessment and disclosures, identify an appropriate retention period, and obtain any required consent before new optional collection begins.

11.Retention, deletion, and legal holds

LNK keeps personal information only as long as reasonably necessary for the identified purposes, legal obligations, dispute handling, fraud prevention, security, auditability, and legitimate business requirements. The sensitive-document and property-verification periods above apply unless a legal hold or other lawful requirement changes the ordinary schedule.

• When a retention period expires and no legal hold or other lawful reason applies, LNK deletes, securely destroys, or de-identifies the information according to the applicable lifecycle process.
• A documented legal, fraud, security, insurance, privacy, or dispute hold suspends ordinary deletion only for the records and period reasonably required and is released when no longer needed.
• Backup or disaster-recovery copies may persist until the relevant backup cycle expires. If data is restored from backup, the applicable retention and deletion rules continue to apply.
• Routine scheduled deletion of a sensitive raw file does not require an individual deletion email where the retention rule has already been disclosed.

12.Security safeguards

LNK uses administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including least-privilege access controls, encryption for sensitive verification files, malware scanning, private object storage, audit logging, secret and encryption-key management, deployment controls, monitoring, retention jobs, and staff procedures. LNK may update its technical implementations and service providers as technology, operations and risks evolve, while maintaining safeguards appropriate to the sensitivity of the information and providing any required notice or consent. This flexibility does not waive the stated substantive protections or permit LNK to describe a discontinued safeguard as still operating. A routine implementation change that does not materially change privacy practices, protections or user obligations does not alone require general agreement reacceptance. No system can guarantee absolute security, and users must also protect their credentials and devices.

13.Security incidents and breach response

LNK investigates suspected security incidents and documents breaches of security safeguards involving personal information under its control. Where a breach creates a real risk of significant harm and applicable law requires reporting or notification, LNK will report to the appropriate regulator and notify affected individuals as soon as feasible, with information reasonably necessary to understand and reduce the risk. LNK also notifies another organization where required to reduce or mitigate harm.

• LNK retains records of every breach of security safeguards involving personal information under its control for at least 24 months after determining that the breach occurred, and longer where a lawful requirement or documented hold applies. A breach need not meet the reporting threshold to require a record.
• A user or Partner should promptly report suspected unauthorized access, lost verification material, or misuse of platform personal information to [email protected]. Contractual confidentiality does not prevent a legally required report or notification.

14.Access, correction, complaints, and consent withdrawal

Subject to applicable law, you may ask whether LNK holds personal information about you, request access to it, ask that inaccurate or incomplete information be corrected, or ask to withdraw a consent. LNK may need to verify your identity and may withhold information where law permits or requires it.

• Requests and privacy complaints may be sent to the Privacy Officer at [email protected]. LNK will acknowledge and investigate privacy complaints and ordinarily respond to an access request within 30 days. Where a lawful extension is needed, LNK will give the required notice, reason, timing, and complaint information. A refusal or permitted limitation will be explained to the extent required by law.
• You may also write to: Privacy Officer, Lodge N Key Inc., 350 Bay St, Suite 1300B, Toronto, Ontario M5H 2S6, Canada.
• If a concern is not resolved, you may have the right to contact the Office of the Privacy Commissioner of Canada or another privacy regulator with jurisdiction.

15.Children and Partner eligibility

A Partner applicant, authorized signer, and booking Traveler must be at least 18 years old and have the legal capacity required for the transaction. LNK is not designed for children to create independent accounts or enter accommodation transactions. A booking adult may provide limited information about accompanying children where necessary for occupancy, safety, or a lawful accommodation requirement and must have authority to do so. LNK does not routinely require government ID from accompanying children. If LNK learns that required parental or guardian consent was not obtained, it will take reasonable corrective steps in accordance with law.

16.Policy changes and contact

LNK may update this Privacy Policy prospectively to reflect changes in law, services, providers, or actual privacy practices. LNK will identify the version and effective date and provide notice appropriate to the significance of the change. Material changes to required processing must be reflected in the applicable acceptance flow before affected new activity. A materially new purpose, sensitive collection, or disclosure receives separate meaningful notice and consent where required; general policy reacceptance is not a substitute. The Terms of Service do not authorize retrospective use of previously collected information for an incompatible undisclosed purpose.

Contact: Privacy Officer, Lodge N Key Inc., [email protected], 350 Bay St, Suite 1300B, Toronto, Ontario M5H 2S6, Canada.