Privacy Policy

This Privacy Policy applies to Popover AI Ltd. ("Popover", "we", "us" or "our") online services, including but not limited to the Popover desktop travel planning platform ("Platform"), Popover's travel planning mobile application ("App"), Popover's websites available at popover.ca and popoverai.com, including all subdomains ("Website"), and any other online services or products provided to you by Popover (collectively, "Service") and details how we access, collect, use, and disclose data, including personal data, about you (together, "you" or "your").

1. Description of the Service

Popover provides you with an AI-integrated travel planning platform with tools that help you discover, create, and enact your travel plans. In order to provide the Service to you and for our other business purposes, we may collect, use and disclose certain personal data (personal information). This Privacy Policy describes how we access, collect and use personal data regarding our users, including you.

2. How We Obtain Personal Data

The Service involves accessing, collecting and processing personal data, which is information about you or that can be used to identify you. We may obtain your personal data when you choose to provide it directly to us, such as when you register an account on the Service, or indirectly, when you use certain aspects of the Service, such as the App or Website. Your provision of personal data to Popover is governed by this Privacy Policy and our Terms of Service ("Terms"), which you must agree to in order to use the Service.

If you have any questions or concerns about the collection, use or disclosure of your personal data that are not addressed by this Privacy Policy, please contact Popover at your convenience using the contact information found below. Subject to our legal, contractual and technical requirements, you may choose not to provide Popover with certain data or request the deletion of certain data we have collected about you, however, exercising such rights may impact the Service features available to you.

3. Personal Data We Collect

We collect your personal data when you first use the Service and over time as you continue accessing the Service. The following is a description of the personal data that we may access, collect, use and process in connection with the Service:

• third-party user IDs and profile information associated with your account on the Service, such as your Google or Apple profile information, if you choose to register an account or login using your Google, Apple or other third-party account;
• certain information such as your full name, email address, telephone number, contact data and contact preferences, if you choose to provide it when communicating with us, including by consenting to any of our marketing, promotional or other communications;
• your payment data, if you make purchases on the Service, which is processed solely by Popover's authorized third-party payment processors such as RevenueCat;
• your Gmail account data, if you opt-in and authorize Popover to access such data when using the Service. Additional details on the use of your Gmail are detailed in Section 7 below;
• cookies and similar tracking technologies to track activities on the Service;
• any other information you choose to provide to us while using the Service or contacting us, including responses to feedback, help-desk requests, surveys and comments; and
• basic derivative and usage data, including geolocation data, information about your computer, phone, mobile device, web-connected devices or other devices used to connect to the Service including but not limited to, operating system information, your computer's Internet Protocol address (i.e. IP address), browser type, browser version, operations performed on the device, time and date of Service use, time spent on Service, other diagnostic date and/or unique tokens and identifiers that may identify you over time and across different websites including unique device identifiers.

Popover may also collect anonymous data that does not identify you, including but not limited to responses to anonymous surveys and feedback requests, metrics and other types of statistical data, which could be derived from your use of the Service and analytical data concerning the Service. We may also aggregate, anonymize and/or de-identify the personal data we have collected about you for the same purposes. We have implemented commercially reasonable security measures to properly encrypt, anonymize and/or de-identify such data and we do not attempt to re-identify any previously anonymized or de-identified data.

4. Processing of Personal Data

We process personal data primarily for our legitimate business purposes, such as providing the Service to you, to understand your needs and to improve the quality of the Service and analyze the information and data Popover collects. These uses include, but are not limited to:

• facilitating account creation, authentication and management of your user accounts;
• providing the Service to you, including tailoring the Service to your needs based on the data that you provide;
• understanding your needs to improve the quality and reliability of the Service, including providing customer support and feedback, providing additional support, analyzing functionality and technical issues, tracking use of the Service and generating internal reports and data models that we use to improve the Service;
• contacting you for various reasons, including when providing customer support for the Service and sending administrative information to you;
• requesting feedback when necessary and contacting you about your use of the Services;
• sending promotional and marketing communications to you, if this is in accordance with your marketing contact preferences. You can opt out of our marketing or promotional emails at any time by accessing the unsubscribe link in such emails or contacting us using the information below;
• delivering targeted information and personalized advertising content tailored to your interests, location and more, based upon your use of the Service;
• identifying how you use our Services and understanding how the Services are being used so we can improve them;
• determining the effectiveness of our marketing and promotional campaigns;
• saving or protecting an individual's vital interest, such as to prevent harm;
• investigating improper or suspicious activity in or on the Service; and
• posting testimonials to our Website. Prior to posting testimonials, we will notify you of the content of the testimonial. If you wish to update or delete your testimonial, please contact us at support@popover.ca with the subject line "Popover Testimonial" and include your name, testimonial location and contact information.

We may disclose personal data to our parent companies, affiliates, subsidiaries, business partners, advisors, employees and contractors for the same purposes described above and only where such parties are subject to adequate confidentiality and non-disclosure terms requiring the utmost protection of your personal data.

5. Cookies and Digital Tracking Technologies

The Service uses tracking technologies, such as cookies, to collect personal data, such as IP addresses and device information. Based on this data, third parties may be able to resolve your identity across multiple devices. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Unless restricted by law, regulation or contractual requirements, we may send communications and marketing information to email addresses associated with the information collected by our cookies and other tracking technologies, which you may opt out of at any time. Note that certain essential Service features may rely on tracking technologies and by declining to accept cookies or by changing certain settings on your device, you may not have access to these features or the Service itself.

6. Third-Party Services

Except for those third-parties processing your personal data on behalf of Popover, this Privacy Policy only applies to personal data that Popover collects, processes and discloses and does not apply to the access, collection, processing and disclosure of personal data by third parties through third-party services, which may be more extensive than as set forth in this Privacy Policy, and that may be embedded and/or integrated into the Service. In many cases, third parties may collect personal data about online activities over time and across different websites and services. Popover strongly recommends that you carefully read and consent to each third-party privacy policy before using the Service.

Third-parties that may be embedded into the Service include: Google, OpenAI, Anthropic, Apple, Unsplash, Vercel, RevenueCat, Amadeus, AirLabs and Convex. Popover may provide your personal data to these third parties to perform work that is necessary for Popover to provide the Service and its features to you.

Please contact us directly using the information found below if you would like to learn more about third-party data practices.

7. Gmail Data

Certain features of the Service provide you with the ability to connect your Gmail account to the Platform or App to organize travel itineraries and customize your experience. If you opt-in to the connection of your Gmail account, we will receive limited access to your Gmail account to scan for travel-related communications. When you connect your Gmail account to the Service, we process and receive your information as follows:

• we receive notifications of emails sent to your Gmail account;
• our artificial intelligence systems and providers scan the email data to determine whether any communications relate to travel activities, including flight tickets, hotel bookings and related travel or tourist activities; and
• when our systems indicate an email is related to travel, relevant information about such plans are sent to Popover's servers to structure an itinerary on your account in the Service.

We do not otherwise store or process your Gmail data except as described herein and limit our use to only what is necessary to provide you with the Service. Popover does not store any direct email body content when using your Gmail data. When processing your Gmail information, we do not directly use such data for targeted advertising and do not share the data with our employees, contractors, advisors or other individuals except with your consent, where needed to maintain the security of the Service or where required for legal purposes. In certain instances, we may anonymize, aggregate or de-identify your Gmail data for our internal statistical purposes.

Popover's use of your Gmail data is conducted in accordance with the Google API Services User Data Policy.

8. Obtaining, Rectifying and Controlling Personal Data

You may contact Popover to obtain a copy of any personal data we collect about you, the production of which may be subject to a fee, as permitted by applicable law. You may also contact Popover to correct inaccurate personal data or to complete incomplete personal data.

In addition to correcting or completing personal data, you may be able to opt-out of some or all of the ways in which we process your personal data, or request the deletion of certain personal data, except where we are required to retain your personal data in order to:

• perform our contractual obligations, such as complying with our Terms or certain other legal obligations;
• protect your interests or those of another person; and/or
• protect our legitimate interests or the legitimate interests of a third-party.

To review, update or delete the personal data Popover has collected about you, you may contact us using the contact information found below.

9. Data Storage and Retention

While Popover is a Canadian company, the data provided through the Service may be stored and processed by third parties in countries around the world. By using the Services and agreeing to this Privacy Policy you authorize Popover and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

Popover complies with international personal data transfer laws in applicable jurisdictions. For residents of the EEA, we comply with Articles 44-49 of the European Union's General Data Protection Regulation ("GDRP") and UK laws equivalent to those required under the GDPR for UK data subjects. Currently, transfers of personal data to Canadian commercial organizations from residents of the EU are covered by an adequacy decision as described in Article 45 of the GDPR.

Popover will only keep your personal data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.

When we have no ongoing legitimate business need to process your personal data and/or your relationship with Popover comes to an end, we will promptly return, delete or anonymize any personal data Popover has on file, in line with our legal obligations. Where returning, deleting or anonymizing your personal data is not possible, Popover will securely store your personal data and isolate it from any further processing until deletion is possible. Any personal data that has been requested to be returned, deleted or anonymized and is stored on a data backup will be held only temporarily and automatically purged after set expiration periods. Please email support@popover.ca to request deletion of any personal data of yours that Popover holds.

You may change certain information in your account or terminate your account with Popover at any time by logging into your account settings and updating your account. Upon your request to terminate your account, we will deactivate or delete your account and information from our databases. However, we may retain some information for applicable periods in order to restore your account, prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

10. Do Not Track Disclosure

Do Not Track ("DNT") is a web or device setting that allows you to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug-in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards, and it is possible that there may never be any DNT technology standards. As a result, Popover does not respond to DNT requests.

11. Children

Popover complies with the U.S. Children's Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. The Service is not directed to children under the age of 18 and Popover does not knowingly solicit data from or market to children under the age of 18. If we learn that we inadvertently collected personal data from a child under the age of 18, we will deactivate the account and take reasonable measures to promptly delete the data from our records. If you are a parent or guardian of a child who you believe provided Popover with personal data without your consent, please contact us at support@popover.ca.

If you are otherwise below the age of consent in your country, Popover shall comply with applicable consent gathering standards required by law in your jurisdiction.

12. California "Shine the Light" Right

If you are a California resident, California Civil Code 1798.83 grants you the right to request disclosure of the categories of personal data we control and have provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below.

Please note that you may only make this request once per year.

13. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale and sharing of your personal data to third parties. Currently, Popover does not sell your personal data to third parties and as such no opt-out of the sale of such personal data is necessary. Although Popover does not sell your personal data to third parties without consent, Popover does provide a right to opt out of third-party sharing to all our users. Note that certain essential Service features may rely on third-party sharing and by exercising your right to opt-out you may not have access to these features. If you have any other questions about our privacy practices, please email us at support@popover.ca.

14. Change of Ownership or Business Transition

In the event of, or in preparation for, a change of ownership or control of Popover or a business transition such as the sale of some or all Popover's assets, we may disclose and/or transfer your personal data to third parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

15. Security

We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process. Despite our safeguards and security, no electronic transmission over the Internet or information storage technology can be guaranteed to be fully secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Transmission of personal data to and from our Services is at your own risk. You should only access the Services within a secure environment.

16. Contact Preferences

Popover communicates with you through the Service itself but may also communicate with you through your email address or other digital methods to conduct the Service and to respond to support requests or comments. If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with "unsubscribe" in the email title or body. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

17. Updates

Popover reserves the right, in its sole discretion, to modify this Privacy Policy at any time (each an "Update") and shall make each Update available on our Website, indicated by an updated "Revised" date. You are deemed to accept an Update by continuing to use the Service. Unless Popover states otherwise, an Update is automatically effective 30 days after posting on the Website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of Popover and such Update is made only to correct a typographical, formatting or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the Website.

18. Contact Us

If you have any requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Privacy Officer or our Privacy Team at legal@popover.ca or by physical mail at: