Privacy Policy

1. About This Privacy Policy

koinē is operated by HyperLocal Technologies Corp., doing business as hyperlocal (“hyperlocal,” “we,” “us,” or “our”), a company based in British Columbia, Canada.

koinē helps people create, discover, join, coordinate, and attend real-world gatherings.

A gathering created, discovered, joined, coordinated, or attended through the Service may be referred to as a “koinē” or a “Hang.” These terms have the same meaning throughout this Privacy Policy.

koinē is integrated with hyperlocal OS, the underlying technology and participation infrastructure operated by HyperLocal Technologies Corp. hyperlocal OS supports koinē and may connect koinē with authorized hyperlocal products, hosts, Hubs, venues, communities, businesses, schools, faith communities, and other organizations.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you use:

• the koinē website;
• the koinē web or mobile application;
• koinē invitations, communications, and notifications;
• discovery, check-in, attendance, payment, and support features;
• hyperlocal OS as it relates to your use of koinē; and
• related hyperlocal products or services that link to or expressly adopt this Privacy Policy.

Together, these products, features, and services are referred to as the “Service.”

Because koinē is designed to support real-world participation, certain features may involve participant lists, commitments, invitations, communications, location information, check-ins, attendance records, payments, participation history, and reliability-related information.

By using the Service, you acknowledge the practices described in this Privacy Policy.

2. Key Privacy Information

The following points summarize important aspects of how we handle personal information:

• Information collected through koinē may be stored, organized, and processed through hyperlocal OS.
• Your profile, participation status, or attendance status may be visible to hosts or other participants, depending on the koinē and its settings.
• With your permission, location information may be used for nearby discovery, navigation, or attendance verification.
• We may maintain records of commitments, cancellations, check-ins, attendance, and repeat participation.
• Hosts, Hubs, venues, and organizations receive only the information reasonably required for the relevant koinē or authorized service.
• We may use aggregated or de-identified information to provide participation insights and improve hyperlocal products.
• We do not sell personal information to data brokers or unrelated third parties for money.
• koinē may be accessed by children and young people. Where we know that a user is under 18, we treat their information as sensitive and may apply additional protections.
• We do not currently require a person to provide their age merely to receive an invitation to a koinē. As a result, we may not always know that a user or invited guest is under 18.
• We will provide additional notice or obtain consent where required before using identifiable information for a materially different cross-product purpose.
• You may request access, correction, deletion, or review of an attendance record by contacting koine@thehyperlocal.app.

3. Personal Information We Collect

The personal information we collect depends on how you interact with koinē and which features you use.

3.1 Account and Profile Information

When you create or manage an account, we may collect:

• your name;
• username or display name;
• email address;
• phone number, where provided;
• profile photo;
• biography or profile description;
• interests, activities, communities, affiliations, or preferences you choose to provide;
• city, neighbourhood, or general location;
• age, birth year, date of birth, or age range where reasonably necessary;
• authentication and login information;
• notification preferences;
• privacy and account settings;
• connected-account information; and
• other information you choose to add to your account.

Some profile information may be visible to other users. What is visible may depend on your settings, the koinēs you join, and the features you use.

3.2 Invitation and Guest Information

A person may invite you to a koinē before you create a koinē account.

When someone invites you or adds you as a guest, we may receive:

• your name;
• email address;
• phone number;
• relationship to the inviting user;
• guest status;
• invitation response;
• participation status; and
• other information the inviter provides about the invitation.

We use this information to:

• deliver the invitation;
• show the inviter whether an invitation was accepted or declined;
• manage participation, capacity, or guest lists;
• communicate information about the koinē; and
• protect the Service from misuse.

The person providing your information is responsible for having an appropriate reason and authority to share it.

If you receive an invitation but do not want us to retain your contact information, you may contact koine@thehyperlocal.app.

Receiving an invitation does not automatically create a full public profile.

3.3 koinē and Participation Information

When you create, host, discover, join, save, share, or attend a koinē, we may collect:

• the title and description of the koinē;
• its category, date, time, duration, and location;
• whether it is public, private, invite-only, recurring, paid, or otherwise restricted;
• host and co-host information;
• participant, guest, and attendee lists;
• invitations and responses;
• whether you joined, committed, declined, cancelled, withdrew, or checked in;
• capacity and waitlist information;
• guest information;
• participation requirements;
• answers to questions asked by a host;
• accessibility or accommodation information you choose to provide;
• attendance and participation history;
• cancellation and no-show information;
• reports, reviews, or feedback relating to the koinē;
• recurring-group information; and
• information needed to operate multi-step or connected koinēs.

Depending on the nature and settings of the koinē, your name, profile photo, participation status, or attendance status may be visible to:

• the host;
• co-hosts;
• other participants;
• invited users;
• an authorized Hub or venue;
• an authorized organization; or
• other users of the Service.

3.4 Check-In and Attendance Information

koinē may provide tools that allow participants, hosts, Hubs, venues, organizations, or hyperlocal to confirm attendance.

Depending on the feature, we may collect:

• QR code scans;
• check-in or access codes;
• the date and time of a check-in;
• the relevant koinē and location;
• host-confirmed attendance;
• venue- or Hub-confirmed attendance;
• organization-confirmed attendance;
• approximate or precise device location, where permission has been granted;
• confirmation that a device was within an expected geographic area;
• payment or admission eligibility;
• disputed, corrected, or manually adjusted attendance;
• cancellation and no-show information; and
• technical information used to identify fraudulent, duplicate, shared, or manipulated check-ins.

We may use attendance information to:

• confirm access;
• administer deposits or payments;
• maintain participation history;
• operate recurring communities;
• resolve attendance disputes;
• reduce fraud;
• help hosts understand participation;
• support safety investigations; and
• generate reliability-related information where clearly disclosed.

Attendance information may not tell the complete story about a person or a specific absence. You may request review of information that you believe is inaccurate.

3.5 Location Information

With your permission, koinē may collect or process location information to:

• show koinēs near you;
• organize discovery results by distance;
• recommend locally relevant opportunities;
• provide maps or directions;
• verify that a check-in occurred near the expected location;
• prevent fraudulent attendance records; or
• provide another location-based feature you request.

Location information may include:

• approximate location based on your IP address;
• a city, neighbourhood, or region you provide;
• device-derived approximate location; or
• precise device location when you grant permission.

We do not display your device-derived precise location to other users.

The meeting location entered for a koinē may, however, be displayed to users according to the koinē’s privacy and access settings.

Unless we clearly tell you otherwise and obtain any required permission, koinē does not continuously track your precise location while you are not actively using a location-based feature.

You may control location permissions through your device or browser settings. Disabling location may prevent nearby discovery, location verification, or check-in features from working properly.

3.6 Messages and Communications

When you communicate through koinē, we may collect:

• direct messages;
• group messages;
• koinē discussions;
• host announcements;
• comments and responses;
• invitation messages;
• photos, videos, links, or files sent through the Service;
• communications with support;
• reports involving another user or koinē; and
• communication metadata, such as sender, recipient, date, and time.

We do not routinely review private messages.

We may access, preserve, or review communications where reasonably necessary to:

• provide the requested communication feature;
• respond to a support request;
• investigate a report;
• address fraud, harassment, abuse, exploitation, or safety concerns;
• enforce our Terms and Conditions;
• protect the rights or safety of users and others; or
• comply with applicable law.

3.7 Photos, Videos, and Other User Content

We may collect content that you upload, post, send, or otherwise make available through the Service, including:

• profile photos;
• koinē cover images;
• event photos or videos;
• comments;
• descriptions;
• reviews;
• messages;
• links;
• documents; and
• other user-generated content.

You should only upload content that you are authorized to share.

Content posted to a public profile or public koinē may be visible to a broad audience and may be copied or shared by other users.

3.8 Payment and Transaction Information

Where the Service offers paid koinēs, deposits, refunds, tickets, subscriptions, group payments, host payouts, or other paid features, we may collect:

• transaction amount and currency;
• payment status;
• transaction identifiers;
• billing name and contact information;
• payment method type;
• purchase history;
• deposit status;
• refund, cancellation, or dispute information;
• host payout information;
• tax-related information where required; and
• information needed to prevent fraud or process a transaction.

Payments may be processed by a third-party payment provider.

Unless clearly stated otherwise, hyperlocal does not directly store complete payment-card numbers. Payment providers process payment information under their own terms and privacy policies.

3.9 Device, Usage, and Technical Information

When you access the Service, we or our service providers may automatically collect:

• IP address;
• device type;
• browser type;
• operating system;
• application version;
• language and time-zone settings;
• device or application identifiers;
• login and session information;
• pages or screens viewed;
• buttons, links, and features used;
• searches and discovery activity;
• referral information;
• crash reports;
• application-performance information;
• security logs;
• cookies and similar-technology information; and
• signals used to identify unauthorized activity, fraud, or technical problems.

3.10 Support, Safety, and Verification Information

When you contact support, report a concern, dispute an attendance record, appeal an account decision, or request assistance, we may collect:

• your name and contact information;
• the contents of your request;
• information about the relevant users or koinēs;
• screenshots or supporting documents;
• transaction information;
• identity-verification information where reasonably necessary;
• incident or safety information;
• records of our investigation and response; and
• information needed to resolve the matter.

Please do not send:

• your password;
• complete payment-card numbers;
• banking passwords;
• government identification;
• medical records; or
• other highly sensitive information,

unless we specifically request it and it is reasonably necessary to address your request.

3.11 Information From Other People and Organizations

We may receive information about you from:

• someone who invites you to a koinē;
• a host who adds you as a guest;
• a parent or guardian;
• a host or participant who confirms or disputes your attendance;
• a user who reports an interaction involving you;
• a Hub, venue, community, school, business, faith community, or organizational partner;
• an authentication provider;
• a payment processor;
• an analytics, security, or fraud-prevention provider;
• another authorized hyperlocal application; or
• a third-party service you choose to connect.

A person who provides information about someone else is responsible for having an appropriate reason and authority to share that information.

3.12 AI Draft Information

koinē can turn a short description into a draft plan. This feature is optional, and every koinē can be built by hand instead.

When you ask koinē to draft a plan, we collect:

• the text you type or dictate to describe the get-together;
• the photo you attach, if you attach one; and
• your device’s current date, time, and time zone, so that relative descriptions such as “friday” resolve correctly.

Dictated text is transcribed by Apple’s speech recognition. We ask for on-device transcription and receive it on devices that support it; where a device does not, Apple performs the transcription on its servers under Apple’s own privacy policy.

This information is sent to a third-party artificial intelligence service to generate the draft. Section 10.9 explains exactly what is sent, who receives it, and how we ask for your permission before sending anything.

4. Sensitive Information and Sensitive Inferences

Participation in certain koinēs may reveal or suggest sensitive information.

For example, joining or attending a particular koinē could suggest information about a person’s:

• religion or faith community;
• health or disability;
• political or social interests;
• cultural or community affiliations;
• sexual orientation or gender-related interests;
• financial circumstances;
• family relationships; or
• other personal characteristics.

We do not assume that participation in a koinē definitively establishes any sensitive personal characteristic.

We will limit our use and disclosure of sensitive information to purposes that are reasonably necessary, clearly disclosed, authorized, or otherwise permitted by law.

We do not sell sensitive information or sensitive inferences to data brokers.

We will not knowingly use a young person’s sensitive participation information for unrelated behavioural advertising or commercial profiling.

5. Integration With hyperlocal OS

koinē is part of the broader hyperlocal technology ecosystem operated by HyperLocal Technologies Corp.

Information collected through koinē may be stored, organized, processed, and connected through hyperlocal OS.

hyperlocal OS may be used to:

• operate accounts, profiles, authentication, and security;
• connect koinē features and services;
• manage koinēs, commitments, waitlists, payments, check-ins, and attendance;
• maintain participation history across authorized hyperlocal services;
• support hosts, Hubs, venues, communities, businesses, schools, and organizational partners;
• provide customer support;
• resolve disputes;
• identify duplicate or fraudulent accounts;
• detect manipulated attendance or payment activity;
• generate participation analytics;
• personalize discovery and recommendations;
• develop and improve koinē, hyperlocal OS, and other hyperlocal services; and
• enable authorized hyperlocal applications to work together.

Information integrated with hyperlocal OS may include:

• account and profile information;
• interests and preferences;
• invitations;
• koinēs created, joined, hosted, or attended;
• commitments, cancellations, check-ins, and attendance history;
• participation and reliability-related information;
• messages and support records;
• payment and transaction information;
• device and usage information; and
• other information described in this Privacy Policy.

Processing information through hyperlocal OS does not mean that every host, venue, organization, business, or future hyperlocal application automatically receives access to all of your information.

Access is limited according to:

• the purpose of the feature;
• your permissions and settings;
• the relevant koinē or organization;
• the role of the recipient;
• contractual and technical access controls;
• this Privacy Policy; and
• applicable law.

6. Shared hyperlocal Accounts and Connected Applications

Where offered, your koinē account may form part of a shared hyperlocal account that allows you to access other products or applications operated by HyperLocal Technologies Corp.

A shared account may allow information such as your:

• identity;
• login credentials;
• profile information;
• account settings;
• interests;
• participation history;
• verified attendance; and
• safety or account-integrity information

to be recognized across authorized hyperlocal services.

This may provide a connected experience without requiring you to create a separate account for every hyperlocal application.

6.1 Essential Cross-Product Uses

Certain uses may be necessary to operate a shared account or protect the hyperlocal ecosystem, including:

• authentication;
• account security;
• fraud prevention;
• account recovery;
• customer support;
• enforcement of serious safety or account restrictions; and
• maintenance of accurate shared-account information.

6.2 Optional or New Cross-Product Uses

Where an integration with another hyperlocal product is optional, we may provide settings, notices, or an authorization process that allows you to decide whether to connect the relevant account or information.

We will provide additional notice or obtain consent where required before identifiable information is used for a materially different purpose that:

• is not reasonably necessary to provide koinē;
• is not reasonably expected from your use of the Service;
• involves a new category of sensitive information;
• introduces a materially different recipient; or
• substantially changes how the information affects your experience.

We will not automatically provide every future hyperlocal application with unrestricted access to your complete koinē participation history.

7. How We Use Personal Information

We may use personal information to:

• create and manage accounts;
• authenticate users;
• operate and maintain koinē and hyperlocal OS;
• provide shared hyperlocal accounts where available;
• deliver and manage invitations;
• help users create, discover, join, host, and attend koinēs;
• display profiles, hosts, participants, guests, and attendee information;
• manage commitments, waitlists, cancellations, and capacity;
• enable communication between hosts and participants;
• send reminders, updates, and check-in instructions;
• verify attendance, location, access, or payment eligibility;
• maintain participation and attendance records;
• create participation histories or reliability-related indicators;
• support recurring groups and communities;
• process payments, deposits, refunds, fees, and payouts;
• personalize discovery and recommendations;
• provide customer support;
• investigate reports, disputes, fraud, abuse, harassment, exploitation, and safety concerns;
• detect fraudulent or manipulated check-ins;
• prevent unauthorized account access;
• maintain the security and integrity of the Service;
• enforce our Terms and Conditions and community requirements;
• prevent misuse and unlawful activity;
• improve, test, analyze, and develop our products;
• understand how people interact with koinē;
• measure the effectiveness and reliability of features;
• provide participation insights to authorized hosts, Hubs, venues, or organizations;
• send service-related communications;
• send promotional communications where permitted;
• administer surveys, tests, or research;
• maintain financial, accounting, tax, and compliance records;
• establish, exercise, or defend legal claims;
• comply with legal obligations; and
• carry out another purpose disclosed when the information is collected.

We will not use personal information for a materially different purpose without providing appropriate notice and obtaining consent where required.

8. Consent and Your Choices

We collect, use, and disclose personal information with consent or as otherwise permitted or required by applicable law.

Consent may be:

• express, such as when you enable precise location or connect another service;
• implied from your actions and the reasonable expectations associated with a feature; or
• provided through an authorized parent, guardian, or representative where appropriate.

The appropriate form of consent may depend on:

• the sensitivity of the information;
• the purpose for which it is being used;
• the reasonable expectations of the user;
• the age and maturity of the user;
• the risks associated with the feature; and
• applicable law.

You may withdraw consent for certain activities by:

• changing your account settings;
• changing device or browser permissions;
• disconnecting an optional integration;
• unsubscribing from promotional communications;
• choosing not to use an optional feature; or
• contacting us at koine@thehyperlocal.app.

Withdrawing consent does not affect processing that occurred before your withdrawal.

Some information is necessary to operate koinē, hyperlocal OS, or a shared account. If you decline or withdraw consent for essential processing, certain features may become unavailable or we may be unable to continue providing the Service.

9. Children and Young People

koinē is a mixed-audience service that may be used by adults, teenagers, families, schools, faith communities, community organizations, sports groups, and other communities.

The Service is not designed exclusively for children. However, we recognize that people under 18 may be invited to, participate in, or create koinēs.

For this Privacy Policy, a “Young User” means a person we know or reasonably believe is under 18.

Personal information relating to Young Users is treated as sensitive. We consider the user’s age and maturity, the sensitivity of the information, the nature of the feature, and the risks associated with the relevant koinē.

9.1 We May Not Always Know a User’s Age

koinē does not currently require every person to provide a date of birth merely to:

• create a koinē;
• receive an invitation;
• be added as a guest; or
• view certain information about a koinē.

As a result, we may not always know that a user or invited guest is under 18.

A user, parent, guardian, host, or organization may inform us that a participant is a Young User.

We may ask for an age, birth year, date of birth, or age range where reasonably necessary to:

• provide age-appropriate safeguards;
• determine an appropriate consent process;
• restrict access to an age-restricted koinē;
• protect a Young User;
• administer payment or contractual features;
• comply with legal requirements; or
• determine whether a parent or guardian should be involved.

We aim to collect only the minimum age-related information reasonably necessary.

Users should not misrepresent their age to avoid protections or restrictions.

9.2 Young Users Under 13

Privacy regulators generally consider younger children less likely to fully understand the consequences of their privacy choices.

Where we know or reasonably believe that a user is under 13, we may:

• seek consent or involvement from a parent or legal guardian where appropriate or required;
• limit the information collected;
• restrict public-profile features;
• restrict messaging, payments, location, or cross-product features;
• prevent the account from being activated;
• remove information that is not reasonably necessary; or
• take another reasonable step to protect the child.

Where parent or guardian involvement is needed, we may use privacy-conscious methods such as:

• a linked guardian account;
• email confirmation;
• an in-app authorization;
• confirmation through an authorized organization; or
• another reasonable method.

We will avoid requesting government identification or other highly sensitive documents unless reasonably necessary.

If appropriate parent or guardian involvement cannot be obtained, we may be unable to provide some or all of the Service.

9.3 Young Users Aged 13 to 17

Young Users between 13 and 17 may be able to make certain privacy choices themselves where they can reasonably understand:

• what information is being collected;
• why it is being collected;
• how it will be used;
• who may see or receive it;
• the risks involved; and
• the choices available to them.

Depending on the circumstances, we may require or encourage involvement from a parent or guardian.

Parent or guardian involvement may be particularly appropriate for features involving:

• payments or financial commitments;
• deposits;
• precise location;
• overnight activities;
• travel;
• elevated physical or safety risks;
• age-restricted venues;
• recurring participation arranged by an organization;
• disclosure of sensitive personal information; or
• another increased privacy or safety risk.

9.4 Privacy Protections for Known Young Users

Where we know or reasonably believe a user is under 18, we may apply additional protections, such as:

• limiting public profile visibility;
• limiting search or discovery visibility;
• restricting who can view participation or attendance;
• restricting unsolicited messages from unknown users;
• limiting the display of exact locations before participation is approved;
• limiting precise-location collection;
• limiting participation or reliability indicators;
• limiting cross-product information use;
• limiting personalized marketing;
• shortening retention periods where appropriate;
• providing simpler reporting and deletion options; and
• requiring parent, guardian, host, or organization involvement for certain features.

The availability of these protections may depend on the information available to us and the technical capabilities of the Service.

9.5 Location Information Relating to Young Users

We do not intend to continuously track the precise location of Young Users.

Where location is used for discovery, navigation, safety, or check-in, we aim to:

• collect only the level of accuracy reasonably required;
• collect it only while the relevant feature is being used;
• avoid making device-derived precise location visible to other users;
• avoid retaining precise location longer than reasonably necessary; and
• provide an alternative where reasonably available.

The listed meeting location of a koinē may still be visible to an authorized participant where necessary to attend.

Hosts should not publicly post a Young User’s home address, school schedule, daily routine, or another location that could create an unreasonable safety risk.

9.6 Attendance and Participation Information Relating to Young Users

We may maintain records showing that a Young User:

• received or accepted an invitation;
• joined a koinē;
• committed to attend;
• cancelled;
• checked in;
• attended; or
• participated repeatedly.

We will limit the public display of known Young Users’ attendance histories and reliability-related indicators where reasonably possible.

Attendance information relating to a Young User may be available to:

• the Young User;
• the relevant host or co-host;
• a parent or guardian where appropriate;
• an authorized school, community, faith, sports, or youth organization;
• a venue where necessary for admission or safety;
• hyperlocal and its service providers where necessary to operate or protect the Service; or
• another person where authorized or required by law.

We will not knowingly use a Young User’s attendance history to unfairly shame or commercially exploit them.

A Young User, parent, or guardian may request review of inaccurate attendance information.

9.7 hyperlocal OS and Young Users

Information relating to Young Users may be processed through hyperlocal OS where reasonably necessary to:

• operate koinē;
• maintain account security;
• deliver invitations;
• provide check-in and participation features;
• prevent fraud or misuse;
• provide support;
• manage appropriate parent or guardian involvement;
• comply with legal obligations; or
• protect users.

We will not provide every hyperlocal application, host, Hub, venue, or organizational customer with unrestricted access to a Young User’s personal information.

We will not knowingly use identifiable information relating to a Young User for:

• sale to data brokers;
• unrelated third-party marketing;
• unrelated behavioural advertising;
• indiscriminate surveillance; or
• materially different cross-product purposes without appropriate notice and consent.

Aggregated or de-identified information may be used to understand participation and improve hyperlocal services where it cannot reasonably identify a Young User.

9.8 Hosts and Organizations Involving Young Users

Hosts and organizations that create or manage koinēs involving Young Users are expected to:

• clearly identify the intended age group where appropriate;
• obtain any permission or consent they are responsible for obtaining;
• select appropriate visibility settings;
• protect participant lists and contact information;
• limit communications to appropriate purposes;
• avoid publicly identifying Young Users without appropriate permission;
• avoid posting sensitive location or schedule information;
• provide appropriate supervision;
• comply with applicable safeguarding obligations; and
• use information obtained through koinē only for purposes connected to the relevant gathering or program.

The ability to create or manage a koinē does not mean that hyperlocal has screened, licensed, approved, or supervised the host.

9.9 Parent and Guardian Requests

A parent or guardian may contact us to:

• provide or withdraw consent;
• request access to information relating to a Young User;
• request correction or deletion;
• report an unsafe interaction;
• manage a linked account where available; or
• ask a privacy question.

A parent or guardian’s access is not automatically unlimited.

When responding, we may consider:

• the age and maturity of the Young User;
• the nature and sensitivity of the information;
• the Young User’s own privacy rights;
• the relationship and authority of the requester;
• the best interests and safety of the Young User; and
• applicable law.

We may need to verify the requester’s identity and authority before disclosing or changing information.

9.10 Learning That a User Is a Child or Young Person

If we learn that personal information relating to a Young User was collected without the consent or protections appropriate in the circumstances, we may:

• restrict the account;
• seek parent or guardian involvement;
• remove public information;
• disable certain features;
• correct privacy settings;
• delete information that is not reasonably required; or
• take another action appropriate to protect the user.

Questions involving Young Users may be sent to koine@thehyperlocal.app using a subject line such as:

• Youth Privacy Question
• Parent or Guardian Request
• Report a Concern About a Young User
• Delete a Young User’s Information

10. How We Disclose Personal Information

We may disclose personal information in the circumstances described below.

10.1 Other Users

We may display information to other users where necessary to provide the Service, including:

• your display name;
• profile photo;
• biography;
• interests or communities you make visible;
• koinēs you create or host;
• your status as a host, participant, attendee, or guest;
• whether you joined, committed, withdrew, or checked in;
• shared messages, comments, or content;
• attendance or participation indicators, where offered; and
• reviews or feedback submitted for public display.

The information visible to other users depends on the feature, privacy settings, and nature of the koinē.

10.2 Hosts and Co-Hosts

When you join or request to join a koinē, its host or co-hosts may receive information needed to manage it, including:

• your name and profile information;
• participation status;
• check-in or attendance status;
• payment or deposit status;
• answers to participation questions;
• guest information;
• accessibility or accommodation information you choose to provide; and
• messages you send to the host.

Hosts must use participant information only for legitimate purposes connected to the relevant koinē.

Hosts may not:

• sell participant information;
• use it for unrelated purposes;
• disclose it unnecessarily; or
• add participants to unrelated marketing lists without appropriate permission.

10.3 Hubs, Venues, Communities, and Organizations

Where a koinē is connected to a Hub, venue, community, business, school, faith community, or other organization, we may disclose information reasonably necessary to:

• manage registration;
• confirm payment or access;
• administer capacity or waitlists;
• confirm attendance;
• maintain venue security;
• provide accommodations;
• operate the relevant program;
• understand participation in its own koinēs; or
• address safety and support concerns.

Depending on the service and permissions involved, this may include:

• your name and profile information;
• registration status;
• payment or access status;
• check-in and attendance status;
• answers to relevant participation questions; and
• repeat participation with that specific host, Hub, venue, or organization.

We will not provide an organization with unrestricted access to your complete account or participation history unless:

• it is reasonably necessary to provide a service you requested;
• the disclosure and purpose have been clearly explained;
• you authorized the disclosure;
• the information has been aggregated or de-identified; or
• the disclosure is otherwise permitted or required by law.

An organization may also collect personal information directly from you under its own privacy policy.

10.4 Other hyperlocal Applications

We may disclose or make information available to another application operated by HyperLocal Technologies Corp. where:

• the applications share essential account infrastructure;
• the integration is reasonably necessary to provide a connected service;
• you choose to connect the applications;
• the cross-product use has been clearly disclosed;
• the information is aggregated or de-identified; or
• the use is otherwise permitted by law.

Where required, we will provide additional notice or request consent before identifiable koinē information is used for a materially different purpose in another application.

10.5 Service Providers

We may use service providers to support:

• cloud hosting and storage;
• authentication;
• email, text, and push notifications;
• payment processing;
• mapping and location features;
• analytics;
• performance monitoring;
• fraud detection;
• security;
• customer support;
• content moderation;
• data processing; and
• professional services.

These providers may access personal information only as reasonably necessary to provide services to us or as otherwise permitted under their agreements and applicable law.

The service providers koinē currently relies on, and what each receives, are:

• Supabase for database hosting, authentication, file storage, and server functions. It holds the account and koinē information described in section 3;
• Google for the Gemini artificial intelligence service that generates draft plans, described in section 10.9, and for the Places service that matches suggested places to real venues;
• Telnyx for delivering your one-time sign-in code by text message. It receives your phone number; and
• Apple for Sign in with Apple and for delivering push notifications.

Each provider receives only the information it needs to perform its function, is bound by its own terms of service and data processing terms to protect that information and to use it only to provide the service to us, and affords protections equivalent to those described in this Privacy Policy. We do not authorize any of them to use your information for their own purposes.

10.6 Legal, Safety, and Enforcement Purposes

We may preserve, use, or disclose information where we reasonably believe it is necessary to:

• comply with applicable law;
• respond to a court order, warrant, subpoena, or lawful process;
• respond to a lawful government or law-enforcement request;
• prevent or investigate fraud, abuse, exploitation, unlawful activity, or security threats;
• protect the rights, safety, or property of hyperlocal, our users, or others;
• respond to an emergency involving a risk of death, injury, or serious harm;
• investigate or enforce our agreements and policies; or
• establish, exercise, or defend a legal claim.

10.7 Business Transactions

If hyperlocal is involved in a financing, investment, merger, acquisition, reorganization, sale of assets, insolvency, or similar transaction, information may be disclosed to advisers and transaction participants.

We will use reasonable measures to require information disclosed in connection with a proposed transaction to be handled confidentially and used only for legitimate transaction-related purposes.

10.8 At Your Direction

We may disclose information when:

• you direct us to do so;
• you share content outside the Service;
• you connect another service or application;
• you invite someone to participate;
• you authorize a partner integration; or
• you otherwise provide consent.

10.9 Artificial Intelligence Features

koinē’s draft feature is powered by Gemini, an artificial intelligence service operated by Google. It is optional, and every koinē can be built by hand instead.

The first time you ask koinē to draft a plan, the app tells you what will be sent and asks for your permission. Nothing is sent to Google unless you agree. If you decline, the request is discarded, and you are asked again the next time rather than being opted in silently.

When you agree, this is what is sent to Google for that request:

• the text you typed or dictated to describe your plan;
• the photo you attached, if you attached one; and
• your device’s current date, time, and time zone.

Your name, your phone number, your email address, your account identifier, your location, and the contents of your koinēs are not sent to the artificial intelligence service.

Google returns a suggested title, description, times, and venue ideas, which you can edit or discard before anything is published. We do not use your material to train any artificial intelligence model. We use Google’s paid Gemini API service, under which Google does not use the prompts we send or the responses it returns to improve its products.

Separately, if you have granted location permission, your approximate coordinates and the venue names in your draft are sent to the Google Places service so that suggested places can be matched to real venues. That is a mapping lookup rather than an artificial intelligence service, and the artificial intelligence service never receives your coordinates.

You can stop using the draft feature at any time and continue using the rest of koinē. Nothing is sent to Google unless you start a draft.

11. Hosts, Hubs, and Participation Insights

hyperlocal OS may provide hosts, Hubs, venues, communities, businesses, schools, or organizations with information that helps them understand and operate their own koinēs.

This may include:

• registration totals;
• capacity and waitlist information;
• attendance rates;
• repeat participation;
• cancellation and no-show patterns;
• time-based participation trends;
• general participant interests;
• engagement with that host or organization; and
• aggregated demographic or geographic trends where appropriate.

Where reasonably possible, organizational insights will be provided in aggregated or de-identified form.

Identifiable information will be limited to what is reasonably needed for:

• registration;
• admission;
• attendance;
• payment;
• participant communication;
• safety;
• support; or
• another clearly disclosed purpose.

12. Aggregated and De-Identified Information

We may aggregate or de-identify information collected through koinē and processed through hyperlocal OS.

We may use this information to:

• understand participation patterns;
• measure attendance and repeat engagement;
• improve discovery and recommendations;
• help hosts and Hubs improve their offerings;
• support community and local-economy insights;
• develop and improve hyperlocal products;
• conduct research;
• produce reports; and
• perform statistical and business analysis.

We may disclose aggregated or de-identified information where it cannot reasonably be used to identify you.

We will not attempt to re-identify de-identified information except where reasonably necessary to:

• test our safeguards;
• protect the Service;
• investigate misuse;
• correct a technical issue; or
• comply with law.

13. We Do Not Sell Personal Information

HyperLocal Technologies Corp. does not sell personal information to data brokers or unrelated third parties for money.

We do not permit hosts, Hubs, venues, or organizations to sell participant information obtained through koinē.

We may use service providers to process information on our behalf to operate, secure, analyze, and improve the Service.

We may also provide aggregated or de-identified insights that cannot reasonably identify an individual.

14. Public, Private, and Invite-Only koinēs

Hosts may choose different visibility settings for a koinē.

14.1 Public koinēs

Information associated with a public koinē may be visible to a broad audience, including:

• its title and description;
• the host;
• the date and time;
• its general location;
• participant counts;
• participant or attendee information;
• public comments;
• photos; and
• public updates.

14.2 Private or Invite-Only koinēs

Private or invite-only settings may restrict who can discover, view, or join a koinē.

Participants should not assume that everything shared within a private koinē will remain confidential. Other participants may copy, photograph, record, or redistribute information outside the Service.

Hosts are responsible for selecting appropriate visibility settings and communicating privacy expectations.

15. Attendance and Reliability Information

koinē is designed to support real-world participation and follow-through.

We may maintain records of:

• commitments;
• cancellations;
• withdrawals;
• waitlist activity;
• QR code or location-based check-ins;
• host-confirmed attendance;
• venue-confirmed attendance;
• disputed or corrected attendance;
• no-shows; and
• recurring or repeated participation.

Where clearly disclosed, attendance information or summarized reliability-related indicators may be shown to:

• hosts;
• co-hosts;
• participants;
• potential participants;
• relevant Hubs or venues;
• relevant organizations; or
• users of another authorized hyperlocal service.

Reliability-related information provides context. It does not guarantee a person’s:

• identity;
• character;
• safety;
• suitability;
• future attendance; or
• future conduct.

We may use automated systems to organize or summarize attendance information, detect suspicious check-ins, prevent fraud, make recommendations, or support moderation.

We do not intend to make decisions that produce legal or similarly significant effects about a user solely through automated processing.

You may request review of an attendance record or participation indicator that you believe is inaccurate.

16. Marketing and Notifications

We may send service-related communications, including:

• account-verification messages;
• security alerts;
• invitations;
• participation confirmations;
• host updates;
• cancellations;
• waitlist updates;
• payment receipts;
• check-in instructions;
• reminders;
• support responses; and
• important policy or product notices.

These messages may be necessary to operate the Service and may not always include an unsubscribe option.

We may also send promotional emails, text messages, or notifications where you have consented or where otherwise permitted by law.

You may stop promotional messages by:

• selecting an unsubscribe link;
• adjusting notification settings;
• following instructions in a text message; or
• contacting us.

Stopping promotional messages will not prevent essential account, security, transaction, invitation, or service communications.

We will not knowingly use a Young User’s sensitive participation history for unrelated behavioural advertising.

17. Cookies and Similar Technologies

We and our service providers may use:

• cookies;
• local or browser storage;
• pixels;
• software development kits;
• session identifiers; and
• similar technologies.

These technologies may be used to:

• keep you signed in;
• remember settings;
• maintain security;
• prevent fraud;
• understand how the Service is used;
• diagnose technical issues;
• improve performance;
• improve features; and
• measure communications or campaigns.

You may be able to manage cookies through browser or device settings. Disabling certain technologies may affect the availability or performance of the Service.

18. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

Retention periods depend on:

• the type and sensitivity of the information;
• how long your account remains active;
• the purpose for which the information was collected;
• whether it is connected to an invitation, payment, or attendance record;
• the operation of a shared hyperlocal account;
• the age of the user where known;
• safety and fraud-prevention requirements;
• legal, accounting, and tax requirements;
• active disputes or investigations; and
• whether the information is needed to establish or defend a legal claim.

When personal information is no longer reasonably required, we will take reasonable steps to:

• delete it;
• anonymize it; or
• securely isolate it.

Information may remain in restricted backups for a limited period before those backups are overwritten.

We may retain aggregated or de-identified information that can no longer reasonably be associated with you.

19. Account and Information Deletion

You may request deletion of your koinē account or other personal information:

• through an in-app deletion feature, where available; or
• by emailing koine@thehyperlocal.app from the email address associated with your account.

Use the subject line:

Delete My koinē Account

We may need to verify your identity before processing the request.

Deleting the application from your device does not delete your account.

19.1 Shared hyperlocal Accounts

If your koinē account forms part of a shared hyperlocal account, we will explain whether your request will:

• delete only your koinē profile;
• disconnect koinē from the shared account; or
• delete the entire shared hyperlocal account.

We may ask you to confirm which action you want.

19.2 Young User Deletion Requests

A Young User may request correction or deletion of information they have shared.

A parent or guardian may also make a request where appropriate.

We will consider the:

• age and maturity of the Young User;
• sensitivity of the information;
• authority of the requester;
• Young User’s own privacy interests;
• safety of the Young User; and
• requirements of applicable law.

19.3 Information That May Be Retained

Following deletion, we may retain limited information where necessary to:

• comply with legal, tax, or accounting obligations;
• complete or document payments and refunds;
• prevent fraud or repeated misuse;
• maintain safety and enforcement records;
• investigate reports;
• resolve disputes;
• protect users; or
• establish, exercise, or defend legal claims.

Messages or content you shared may remain where:

• another user retains a copy;
• the information forms part of a shared conversation;
• it is necessary to preserve the integrity of a koinē record;
• it was shared outside the Service; or
• retention is otherwise reasonably necessary or legally required.

Where appropriate, we may remove identifying information while retaining a limited record.

20. Access, Correction, and Privacy Requests

Subject to applicable law, you may request:

• access to personal information under our control;
• information about how your information has been used;
• information about certain disclosures;
• correction of inaccurate or incomplete information;
• withdrawal of certain consents;
• disconnection of an optional integration;
• deletion of your account or information;
• review of an attendance record;
• review of a participation indicator; or
• review of a privacy-related decision.

You may be able to update certain information directly through your account.

To submit a request, email:

koine@thehyperlocal.app

Use the subject line:

Privacy Request

Include:

• your name;
• the email address connected to your account;
• the nature of your request; and
• enough information for us to identify the relevant records.

We may request additional information to verify your identity or authority.

We may refuse or limit access where permitted or required by law, including where disclosure would:

• reveal another person’s personal information;
• compromise security;
• disclose confidential commercial information;
• interfere with an investigation; or
• violate another legal restriction.

Where appropriate, we will explain the reason for the limitation.

21. Accuracy of Information

We take reasonable steps to maintain accurate personal information where accuracy is important to the purpose for which it is used.

You are responsible for keeping your account information reasonably current.

You may update certain information through your account or contact us if you believe information under our control is inaccurate.

Attendance information may be based on:

• QR code scans;
• location confirmation;
• host confirmation;
• venue or organization confirmation;
• payment or access records; or
• other available information.

When an attendance record is disputed, we may review information from multiple sources before correcting it.

22. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against:

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

These safeguards may include:

• account authentication;
• role-based access controls;
• encryption in transit and, where appropriate, at rest;
• secure software-development practices;
• monitoring and logging;
• restricted employee and contractor access;
• service-provider security requirements;
• backup procedures; and
• incident-response processes.

The sensitivity of information, including information relating to Young Users, location, messages, payments, and attendance, may affect the safeguards applied.

No online service, transmission method, or storage system can be guaranteed to be completely secure.

You are responsible for:

• protecting your password;
• controlling access to your device;
• signing out of shared devices;
• not sharing check-in or login credentials; and
• notifying us promptly if you suspect unauthorized activity.

Where required by law, we will notify affected individuals and applicable authorities of a security breach that meets applicable notification requirements.

23. International and Cross-Border Processing

HyperLocal Technologies Corp. is based in Canada.

Some service providers may process or store information in:

• another Canadian province;
• the United States; or
• another country.

Information processed outside your province or country may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies, or government authorities under applicable law.

We use contractual, organizational, and technical measures designed to protect information processed by service providers.

24. Third-Party Services

The Service may include links or connections to:

• mapping providers;
• payment processors;
• venues;
• ticket providers;
• transportation services;
• social platforms;
• external websites; or
• other third-party services.

We do not control the privacy, security, availability, or content of third-party services.

Your use of a third-party service is governed by that service’s own terms and privacy policy.

The presence of a link or integration does not mean hyperlocal endorses the third party or its privacy practices.

25. Changes to This Privacy Policy

We may update this Privacy Policy as koinē, hyperlocal OS, and connected hyperlocal services evolve.

When we update it, we will:

• post the revised version;
• update the “Last Updated” date; and
• provide additional notice where a change is material or where required by law.

We may request renewed consent where required, including where:

• information will be used for a materially new purpose;
• a new category of sensitive information will be collected;
• information will be disclosed to a materially different type of recipient;
• a new cross-product integration substantially changes identifiable information use; or
• a change materially affects Young Users.

Your continued use of the Service after an updated policy takes effect means the revised policy will apply to future collection, use, and disclosure, subject to applicable consent requirements.

26. Privacy Officer and Contact Information

HyperLocal Technologies Corp. has designated a Privacy Officer responsible for overseeing privacy compliance.

Questions, requests, or complaints may be sent to:

Privacy Officer
HyperLocal Technologies Corp.
Vancouver, British Columbia
Canada

Email: koine@thehyperlocal.app

Suggested subject lines include:

• Privacy Question
• Privacy Request
• Privacy Complaint
• Delete My koinē Account
• Attendance Review
• Disconnect My hyperlocal Account
• Youth Privacy Question
• Parent or Guardian Request

We will review privacy concerns and respond within a reasonable period and within any timelines required by applicable law.

If you are not satisfied with our response, you may have the right to contact the privacy regulator responsible for your jurisdiction.