51Vancouver – PRIVACY POLICY

INTRODUCTION

Welcome to 51Vancouver!

51Vancouver. (" we", " our" or " us") values your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information (as defined in the "The Information We Collect and How We Collect It" section below) you provide to us.

The use of 51Vancouver (through the 51Vancouver mobile app, http://www.51Vancouver.com or any third party platforms through which 51Vancouver is provided) may involve the collection and use of your Information. It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using 51Vancouver, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Privacy Officer via email at info@51vancouver.com.

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to 51Vancouver, including any services associated with 51Vancouver that incorporates this Privacy Policy by reference (for example, the 51Vancouver Official Account Admin Platform). Those 51Vancouver-related services may have further privacy-related terms that you must agree to as part of your use of those services.

This Privacy Policy is incorporated into and forms part of the 51Vancouver Terms of Service that you have agreed to in order to use 51Vancouver. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the 51Vancouver Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through 51Vancouver; or (ii) by other companies and organizations who advertise their services on 51Vancouver.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy. Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you via 51Vancouver (including via direct messaging or public notification on the 51Vancouver website), other direct communication to you, or other means prior to the change becoming effective.

By continuing to use 51Vancouver after any changes to this Privacy Policy, with or without notice from us, you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing 51Vancouver, we collect, store and use the following Information relating to you:

" Information" is Personal Information and Non-Personal Information;

" Personal Information " is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

• information you make available to us when you open a 51Vancouver account, such as your name, telephone number, email address;
• any information included in your publicly visible 51Vancouver profile, which may include your profile ID, name and photo;
• information you make available to us via your use of 51Vancouver – for example, via 51Vancouver Moments;
• information made available by another user about you via their use of 51Vancouver – for example, any Shared Information that others using 51Vancouver make available about you via 51Vancouver Moments and communications they make to you and others using 51Vancouver; and
• information we collect as you use 51Vancouver, such as certain Location Data and Log Data.

" Location Data " is information that we collect regarding your location (when you use a location-enabled service), including:

• the location of your device when you use 51Vancouver, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device;
• the IP address of the device or internet service you use to access 51Vancouver; and
• other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and Shared Information that you or others post which indicates your location.

" Log Data" is technical information that is automatically collected by us when you use 51Vancouver, whether through the use of cookies, log files, scripts (as explained in more detail in the "Tracking Technologies" section below) or otherwise, including:

• technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access 51Vancouver, your IP address and your device's version and identification number;
• information about what you have searched for and looked at while using 51Vancouver, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using 51Vancouver;
• information about communications you have made using 51Vancouver, such as the people you've communicated with and the time, data and duration of your communications; and
• metadata, which means information related to items you have made available through 51Vancouver, such as the date, time or location that a shared photograph or video was taken or posted.

" Non-Personal Information " is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymised or pseudonymised form.

" Shared Information " is information about you or relating to you that is voluntarily shared on 51Vancouver. Shared Information may include postings that you make on 51Vancouver (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device's camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

• to provide 51Vancouver (and the features within 51Vancouver) to you – for example, to display content based on your location;
• for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of 51Vancouver;
• to provide you with advertising and direct marketing that is more relevant to you (as discussed in more detail below under the " Direct Marketing" section below);
• to better understand how you access and use 51Vancouver, in order for us to improve 51Vancouver and respond to customer desires and preferences, including for us to provide language and location customisation, personalised help and instructions, or other responses to your and other customers' usage of 51Vancouver;
• to help us develop our new services and improve our existing services;
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with 51Vancouver when your account is subscribed to an official account; and
• to allow you to participate in voluntary surveys about our products and services. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys; we will prohibit them from using your Personal Information for any purpose other than to complete the survey.

Use of Personal Information on our other services

In order to provide our users across all of our services with a better experience, to improve 51Vancouver and our other services, or otherwise where you have consented, Personal Information collected through 51Vancouver may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner).

Personal Information within Your Content

If any of your Personal Information comprises Your Content (as defined in the 51Vancouver Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the "Your Content" section of the 51Vancouver Terms of Service.

DIRECT MARKETING

We may also use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties.

Such products and services (of ours or third parties) include the following:

• our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners, including messaging services, online media services, interactive entertainment services, social networking services, internet search services, location and mapping services, application software and services, data management software and services, on-line advertising services and other social media, entertainment, e-commerce, information and communications software and services (" Internet Services"); and
• third party providers of Internet Services and products and services relating to dining, food and beverages, sports, music, film, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewellery, cosmetics, personal health and hygiene, electronics, collectibles, housewares, appliances, home decoration and furnishings, pets, automobiles, hotels, transport and travel, banking, insurance and financial services, loyalty and reward programs and other products and services that we think may be relevant to you.

We will honour your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact our Privacy Officer or follow the relevant instructions on our marketing communications. Please note that following such request, you may still receive advertisements that are not direct marketing.

Please note that we will not share your Personal Information with advertisers unless you have given us your consent to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you.

SHARING OF YOUR PERSONAL INFORMATION

By agreeing to this Privacy Policy, you consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section. Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

Sharing for the provision of 51Vancouver

We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:

• providing 51Vancouver to you;
• assisting us in carrying out the purposes set out under the " How We Use Your Information" section above;
• carrying out our obligations and enforcing our rights under the 51Vancouver Terms of Service or this Privacy Policy; and/or
• helping us understand and improve 51Vancouver.

Sharing for marketing purposes

In addition, we allow third party marketing partners (such as 51Vancouver official accounts, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use 51Vancouver.

We also provide your Personal Information to third party marketing partners where you have asked us to do so or where it is required in order for us to provide 51Vancouver to you.

Other terms relating to the sharing of your Personal Information

Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or may re-organise our group structure. In these circumstances, your Information may be transferred within our group and/or to a third party who will continue to operate 51Vancouver or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

Any of the above-referenced third parties in this "Sharing of your Personal Information" section may be located, and use and store your Personal Information, outside of your jurisdiction for the above purposes, including in jurisdictions where there may not be in place data protection laws that are substantially similar to or serve the same purpose as the laws of your jurisdiction.

We may also be required to retain, preserve or disclose your Personal Information under the circumstances set out in the "Period of use of your Personal Information" section below.

A WORD ABOUT SHARED INFORMATION

51Vancouver enables Shared Information to be shared publicly with your 51Vancouver contacts, all users of 51Vancouver and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.

In addition, we may also provide other 51Vancouver-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within 51Vancouver – for example, "plug-ins" (which create a direct link between two websites) and "widgets" (which are interactive mini-programs that provide third party services within 51Vancouver). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.

Please consider carefully what you post and communicate through 51Vancouver. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in some of 51Vancouver.

UPDATING OR AMENDING YOUR PERSONAL INFORMATION

If you would like to update or amend your Personal Information within 51Vancouver, you may do so at first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the "Clear Location" option within 51Vancouver.

If you wish to make further changes to your Personal Information; request access to, or deletion of, your Personal Information from 51Vancouver; or to request the removal of an unauthorised 51Vancouver account, please contact our Privacy Officer. We will respond to your request within a reasonable timeframe.

In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may require disproportionate technical effort or extremely impractical (e.g. any requests that relate to our backup systems), or are prohibited by law.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use 51Vancouver, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend 51Vancouver for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to 51Vancouver, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within 51Vancouver, please consider whether it is appropriate to do so.

You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

THIRD PARTY SERVICES ON 51Vancouver

51Vancouver may link you to social media or other features or services (including websites, plug-ins and widgets) provided by a third party. For example:

• you may share content on, or login to, 51Vancouver using services provided by third parties. These third party services will authenticate your identity and provide you with the option to share certain Personal Information with us. They may also give you the option to post information from your third party service account to 51Vancouver as Shared Information (or vice versa).
• you may link your 51Vancouver contact list to your contact lists on your device and/or in your account on third party services, in order to search for and connect with contacts on those contact lists who also have a 51Vancouver account. In consenting to such linking, we will use your username and password for the relevant third party service only for the purpose of such contact list linking (and will delete such information immediately after such purpose is completed);
• you may login to 51Vancouver using other sign-in services such as an Open ID provider. These sign-in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and
• we may (whether in advertisements or otherwise within 51Vancouver) provide you with links or features that allow you to access third party services or websites (or access within 51Vancouver content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party within 51Vancouver.

These third party social media or other services may be hosted by the relevant third party or us. Please note that such third parties who provide such services may be able to collect your Information and Personal Information (including your Log Data), and may set cookies on your computer to enable such features to function properly.

Your use of any such third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party's own terms of services and privacy policies and not the 51Vancouver Terms of Service or this Privacy Policy, so please review those third party terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

AGE RESTRICTIONS

Children under the age of 13 are not allowed to use 51Vancouver. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access or disclosure of Information.

Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access 51Vancouver may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

We will generally only retain your Personal Information for so long as is necessary to fulfil the purposes for which it was collected, as set out under the "How We Use Your Information" section above. However, in the following circumstances, we may be required to retain, preserve or disclose your Personal Information for a longer period of time:

• in order to comply with applicable laws or regulations;
• in order to comply with a court order, subpoena or other legal process;
• in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere);
• where we believe it is reasonably necessary to comply with applicable laws or regulations; or
• in order to enforce the 51Vancouver Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of 51Vancouver.

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Privacy Officer, or where we offer this option in 51Vancouver, you may also log into your account with us and make the appropriate changes. We will use reasonable efforts to respond to all such requests made to our Privacy Officer within 60 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through 51Vancouver, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using 51Vancouver may put your Personal Information in the hands of third parties that we cannot control.

TRACKING TECHNOLOGIES

We may, from time to time, use cookies, log files , scripts, tags and other tracking technologies to collect, use and store Information about you or relating to you. This section describes how we use such tracking technologies.

Why do we use tracking technologies?

To help us better understand and provide 51Vancouver to you and our users

Tracking technologies enable us to better understand and provide 51Vancouver to you – for example, tracking technologies help us collect the following Information:

• we require your authentication information in order to provide 51Vancouver to you;
• our mapping and location-based services (such as " Shake" and "People Nearby" ) may require Information about your location; and
• we require certain other Information about our users in order to provide 51Vancouver and to develop new features for 51Vancouver.

To help us deliver relevant and safe advertising to you

Advertising helps keep 51Vancouver and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:

• more effective for advertisers – for example, by delivering them further information regarding who has viewed their advertisements;
• more safe for you – for example, by ensuring that you do not receive repeated or fraudulent advertisements or prohibited content within such advertisements; and
• more relevant to you – for example, by delivering advertisements based on which official 51Vancouver channels you may have followed or based on your location.

What are tracking technologies?

The "tracking technologies" that we use within 51Vancouver include the following:

• A cookie is a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content.
• Certain information is automatically gathered and stored in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
• JavaScript is a scripting language used to produce more interactive and dynamic websites. JavaScript can create cookies, read cookies, and delete cookies.
• Anonymous identifiers are used to deliver advertisements in services where cookies may not be available (for example, in mobile applications).

How do we use tracking technologies?

Tracking technologies used in partnership with third parties

We, our affiliate companies and our third party partners may from time to time use tracking technologies to collect and use certain Information. These third party partners who assist us in such collection and use include the following:

• Our analytics partners helps us better understand 51Vancouver generally – for example, to collect website and app usage statistics and to gather demographic information about our user base as a whole, as well as to analyse any relevant trends.
• Our marketing partners (including analytics partners, advertisers and 51Vancouver official account partners) help us deliver better and more relevant advertising to you.
• Our customer support service partners help us deliver better responses to any queries from you and to deliver a better 51Vancouver experience to our users.
• Our service partners help us administer and deliver certain features within 51Vancouver – for instance, hosting, language translation and mapping services.

We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis.

Our own tracking technologies

In addition, we also use our own tracking technologies to personalise your experience on 51Vancouver and for various other purposes, including:

• remembering you. For example, cookies can help us identify you as a registered user of our services or keep the preferences or information that you have previously provided; and
• analysing how you use our services. We can use tracking technologies to understand what users are doing on our services, or which pages or sections are most popular.

Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyse how you and others use our services and to serve advertising.

General terms in relation to tracking technologies

It is important to note that third party tracking technologies are subject to the relevant third party's own privacy policies and not our Privacy Policy. We are not responsible for any tracking technologies used by third parties.

If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by contacting us. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for 51Vancouver via a third party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered 51Vancouver. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.

How you can control tracking technologies

You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal 51Vancouver experience and some or all of 51Vancouver's features may not function properly.

Specific types of cookies

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Category of cookies use	Description
Authentication	These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region.
Security	We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
Functionality	We use such cookies to perform and improve the functions of our services. In particular, we use these cookies to help us collect information about how our users are interacting with 51Vancouver – for example, your most recent searches and the profiles that you most frequently visit on 51Vancouver.
Analysis and Research	We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions. For example, these cookies helps us better understand the demographics of the 51Vancouver user base, which in turn helps us consider what new 51Vancouver features may be the most relevant for our users.
Advertising	We use cookies to: deliver advertising on 51Vancouver,with the aim of delivering more relevant advertising to all of our users – for example, you may receive advertisements based on your general location derived from your IP address or from your previous 51Vancouver searches; and to help us and advertisers collect statistics regarding the delivered advertisements, such as how many users have viewed, clicked on and/or made purchases through such advertisements.

If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact our Privacy Officer. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us via email.

Last modified: 2018-5-20