1. Introduction and Scope

This Privacy Policy (“Policy”) explains how KAAKO Technology Inc. (“KAAKO”, “we”, “us”, or “our”) collects, uses, discloses, and safeguards personal information of individuals (“you”, “your”, or “Users”) who access or use our mobile applications, websites, and related online services (collectively, the “Services”).

This Policy applies to both:

KAAKO – User App (the “User App”), used by diners to search, book, review, and discover restaurants offering time-based discounts; and
KAAKO – Restaurant Dashboard (the “Partner App”), used by restaurant operators (“Partners”) to manage their business listings, timeslots, and bookings.

In addition to booking, browsing, and discount-related features, the Services also include user-generated content (“UGC”) features, including (but not limited to):

Reviews and ratings
Q&A (Questions & Answers) submissions
User-submitted deal information (e.g., happy hour details, menu updates, corrections)

These features allow users to submit and share information publicly. This Policy explains how such content is collected, displayed, moderated, and retained, and how associated personal information is handled.

KAAKO Technology Inc. is incorporated in the Province of British Columbia, Canada. We are committed to protecting your privacy and handling your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the British Columbia Personal Information Protection Act (PIPA).

This Policy forms part of our Terms of Service and should be read together with our Fair Use Policy. By accessing or using our Services, you acknowledge and consent to the practices described herein.

2. Information We Collect

We collect personal, business, and technical information to operate, improve, and secure our Services. The specific categories of information collected depend on whether you use the KAAKO User App (“User App”) or the KAAKO Restaurant Dashboard (“Partner App”).

2.1 Information Collected from Users (Diners)

When you register for, access, or use the User App, we may collect the following types of information:

Account Information – name, email address, phone number, login credentials, preferred language, and optional profile photo. You may also choose to provide additional details such as date of birth, gender, preferred cuisine types, or allergy / dietary preferences to personalize your experience. Providing these details is optional and not required to create an account.

Users may choose to sign in using third-party authentication providers such as Google Sign-In or Apple Sign-In. When you use these options, KAAKO receives certain information from your chosen provider — such as your name, email address, profile photo, and a unique authentication identifier — in accordance with that provider’s privacy policy. We use this information solely to create and manage your KAAKO account and to verify your identity. KAAKO does not receive your password or other credential details from these providers.

Booking and Transaction Data – restaurant name, booking date and time, applied discount, booking status, referral codes, coupons redeemed, and any payment identifiers handled through authorized third-party processors.

Search and Browsing Data – search queries, filters used, restaurant categories viewed, prior search history, and pages or restaurants clicked or viewed within the App.

Engagement and Interaction Data – click events, time spent on pages, interactions with restaurant listings, in-house ads or promotional content displayed by KAAKO, and responses to campaigns or offers.

Communications and Inbox Data – messages, feedback, or reviews you send through the App; communications received from restaurants or KAAKO support; and any content stored in your in-App inbox.

Notification and Preference Settings – your choices regarding push notifications, email alerts, language, and marketing preferences.

Location Information – approximate or GPS-based location (if enabled) to provide nearby restaurant results and personalized offers.
User-Generated Content (UGC) - reviews, photos, Q&A submissions, and deal information you voluntarily share publicly through the App.

Device and Usage Data – IP address, device type, operating system, mobile network information, app version, crash logs, and performance metrics collected automatically through Firebase Analytics, Crashlytics, and similar technologies.

2.2 Information Collected from Partners (Restaurants)

From restaurants using the Partner App, we may collect:

Business and Contact Information – restaurant name, address, cuisine type, owner or manager name, phone number, email address, and business registration or tax identification details.

Operational Data – available timeslots, discounts offered, menus, photos, booking capacity and quota, and reservation records.

Financial and Settlement Information – bank account or payment details, billing address, Goods and Services Tax (GST) and Provincial Sales Tax (PST) registration numbers (if applicable), commission invoices, coupon reimbursement records, and other accounting or settlement information necessary to process payments between KAAKO and the restaurant.

Device and Usage Data – login timestamps, IP address, authentication logs, and analytics information collected automatically through Firebase and related services.

2.3 Automatically Collected and Third-Party Information

We may also collect or receive information through:

Cookies and similar technologies on our website to remember preferences and analyze usage;
Analytics providers (e.g., Firebase Analytics, Google AdSense) to measure performance and ad engagement; and
Third-party integrations such as Google Maps API (for location services) and payment processors (for secure transactions).

We do not collect biometric identifiers or other sensitive information unless explicitly provided with your consent.

3. How We Use the Information

We use the information we collect to operate, maintain, and continually improve our Services. The purposes for which we use personal and business information depend on whether you are a User or a Partner.

3.1 For Users (Diners using the KAAKO App)

We may use your information to:

Provide and manage bookings – to process reservations, apply time-based discounts, send confirmations and reminders, and handle booking modifications or cancellations. We may use your booking data, including reservation time and cancellation status, to enforce booking rules (such as cancellation cut-off times or discount eligibility) and improve reliability of our platform.
Personalize your experience – to display nearby restaurants, suggest cuisines or offers that match your preferences, search history, and in-app activity.
Facilitate payments and rewards – to issue or redeem coupons, referral rewards, or promotional credits through authorized payment processors.
Track engagement and rewards history – to maintain accurate records of your coupon usage, referral activity, and program participation, ensuring transparency and preventing fraud.
Provide updates and promotional communications – to notify you about new restaurant partners, limited-time offers, or app features that may interest you, in accordance with your communication preferences and Canada’s Anti-Spam Legislation (CASL).
Optimize location-based recommendations – to suggest relevant restaurants and discounts near your current or preferred areas, when you grant location permission.
Communicate with you – to send booking updates, notifications, customer-service messages, and responses to your inquiries through the in-app inbox or by email.
Operate in-house advertising and promotions – to show restaurant promotions or campaigns within the app based on your browsing interests.
Maintain account security – to authenticate logins (including through Google or Apple Sign-In), detect suspicious activity, and prevent unauthorized access.
Analyze usage and improve performance – to measure engagement, resolve technical issues, and enhance usability through aggregated analytics.
User-Generated Content – We use your reviews, ratings, photos, deal submissions, and Q&A entries to operate community features, improve restaurant information accuracy, and enhance the reliability of our platform. UGC may be used to identify trends, surface popular content, and ensure fair and safe use of the Services. Some UGC may be subject to moderation or approval before being publicly displayed.
Comply with legal obligations – to meet record-keeping, tax, and regulatory requirements applicable to our operations in Canada.

3.2 For Partners (Restaurants using the Dashboard)

We may use your information to:

Create and manage your Partner account – to verify business ownership and maintain contact with restaurant representatives.
Enable booking and discount operations – to publish available timeslots, discounts, menus, and booking quotas to Users through the KAAKO platform.
Process financial settlements – to calculate commissions, reimburse coupon discounts, and issue payments or invoices including applicable GST and PST.
Provide support and communications – to respond to Partner inquiries, operational issues, or feedback.
Improve platform analytics and performance – to evaluate usage trends and service reliability.
Comply with legal and tax requirements – to maintain accurate records for accounting and government reporting purposes.

3.3 General and Administrative Uses (for All Users and Partners)

We may also use information for:

Security and fraud prevention – to protect accounts and data integrity, and to detect misuse of our Services.
Internal reporting and auditing – to assess system performance and compliance with our Fair Use Policy.
Research and development – to test new features, user flows, and promotions using aggregated or anonymized data.
Legal defense and rights protection – to enforce our Terms of Service, resolve disputes, and defend against legal claims.

We do not sell, rent, or trade personal information to third parties.
Any marketing or promotional communications will only be sent in accordance with applicable anti-spam and marketing-consent laws in Canada (including CASL).

4. Sharing and Disclosure of Information

We may disclose personal or business information only as described in this Policy or as required by law. KAAKO does not sell personal information to any third party.

4.1 Service Providers and Business Partners

We may share information with carefully selected third-party vendors that perform services on our behalf, including:

Cloud and data-hosting providers, such as Google Firebase (Cloud Firestore, Cloud Functions, Storage, Analytics).
Authentication providers, including Google Sign-In and Apple Sign-In, used solely for secure login.
Payment and billing processors, which may include Stripe, Apple Pay, or other authorized intermediaries handling commission settlements, coupon reimbursements, and related GST / PST transactions.
Analytics, marketing, and advertising tools, such as Firebase Analytics and Google AdSense, to measure usage and deliver in-house promotional content.
Email and communication platforms, such as Mailgun, used to deliver booking confirmations, promotional campaigns, and customer-support responses.

These providers are granted access only to the information required to perform their assigned functions and are contractually obligated to maintain confidentiality and use the information solely for authorized purposes.

4.2 Restaurant Booking Disclosures

When a User makes a reservation, limited booking details — such as the User’s name, contact number, party size, booking time, and any special notes (e.g., allergy preferences) — are shared with the participating restaurant to confirm and fulfill the reservation.

Restaurants are independently responsible for handling any data they receive from KAAKO in accordance with applicable privacy laws.

4.3 Corporate Affiliates and Business Transfers

We may share information with our corporate affiliates for operational support.

If KAAKO undergoes a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to the same protections described in this Policy.

4.4 Legal Requirements and Protection of Rights

We may disclose information when required or authorized by law, including:

To comply with subpoenas, court orders, or lawful requests from government authorities;
To meet tax-reporting or accounting obligations;
To enforce our Terms of Service or Fair Use Policy; or
To protect the rights, property, or safety of KAAKO, our users, out restaurant partners, or others.

4.5 Aggregated or Anonymized Data

We may share statistical or aggregated information that cannot reasonably be used to identify an individual or business.
Such information may be used for research, performance reporting, marketing analytics, or industry insights.

4.6 Public Display of Reviews, Photos, and Q&A Contributions

UGC that you submit — including reviews, ratings, photos, and Q&A submissions — will be publicly visible to other users of the KAAKO User App and to restaurant Partners.

Your name, profile photo (if provided), and timestamps may appear alongside your UGC.

We do not disclose your email, phone number, or other non-public account information with your UGC.

UGC may also appear in KAAKO promotional materials, search results, or marketing campaigns only in accordance with the license granted under our Terms of Service.

5. Cookies and Tracking Technologies

KAAKO and our service providers use cookies, mobile identifiers, and similar technologies to recognize you, improve functionality, and analyze usage of our Services.

These tools help us provide a consistent experience across devices, deliver relevant restaurant offers, and monitor app performance.

5.1 Types of Cookies and Technologies We Use

Essential Cookies – Required for core site and app functions such as secure login, booking management, and fraud prevention.
Performance and Analytics Cookies – Used to understand how users interact with our Services, detect errors, and improve features. We primarily use Firebase Analytics, Crashlytics, and related SDKs for this purpose.
Preference Cookies – Store language, location, and notification preferences to customize your experience.
Advertising and Campaign Cookies – Enable measurement of in-house promotional content and, where applicable, Google AdSense performance metrics. These cookies do not allow third parties to collect personal information from within the KAAKO mobile apps.

5.2 Mobile Identifiers and SDKs

Our mobile apps may use device identifiers, Firebase SDKs, and analytics tools to enable core functionality, track app performance, and deliver in-app promotions. These do not allow third parties to collect your personal information from our apps.

6. Data Retention

We retain personal and business information only for as long as necessary to fulfill the purposes for which it was collected, or as otherwise required by law.

Retention periods vary depending on the nature of the information and the purpose of its use, as described below.

6.1 User Data (Diners)

Account information – Retained while your account remains active. If you delete your account, certain records (such as booking history or communications) may be retained for a limited time to resolve disputes or comply with legal obligations.

Booking and transaction records – Retained for up to seven (7) years after the transaction date to meet accounting, auditing, and tax-reporting requirements.

Reviews, messages, and in-app communications – Retained as long as your account is active or until you request deletion, subject to moderation guidelines and backup policies.

Analytics and technical logs – Retained in aggregate or anonymized form once no longer needed for operational or security purposes.
User-Generated Content - UGC such as reviews, photos, deal submissions, and Q&A entries may be retained even after account deletion, where necessary to maintain platform integrity, prevent abuse, or preserve meaningful discussion history. Upon request, we will anonymize such UGC by removing identifiable information unless retention is legally required or necessary for fraud prevention.

6.2 Partner Data (Restaurants)

Business and contact information – Retained for as long as the restaurant maintains an active Partner account or until termination of the service agreement.

Financial and settlement records – Retained for up to seven (7) years to comply with Canadian tax and record-keeping obligations, including GST and PST reporting.

Operational data – Retained during the active business relationship and for a reasonable period afterward to ensure reconciliation and reporting accuracy.

6.3 Backup and Anonymization

Certain data may persist in secure system backups for a limited retention cycle before being overwritten.

Wherever feasible, we may anonymize or aggregate personal information so that it can no longer be associated with any identifiable individual or business.

Anonymized information may be used indefinitely for statistical and analytical purposes.

6.4 Deletion Requests

Users and Partners may request deletion of their personal information by contacting info@kaako.ca.

Deletion will be subject to applicable legal and contractual retention requirements, including those necessary for fraud prevention, dispute resolution, or compliance with tax and regulatory obligations.

7. Your Rights and Choices

KAAKO respects your rights to access and control your personal information.

Depending on your relationship with us (User or Partner) and where you reside, you may have the following rights under applicable privacy laws.

7.1 Access and Correction

You may request access to the personal information that KAAKO holds about you and obtain details about how it has been used or disclosed.

If you believe any of your information is inaccurate or incomplete, you may request that it be corrected.
We may require reasonable verification of identity before providing access or making corrections.

7.2 Deletion and Account Closure

You may request that we delete your account and associated personal information by contacting privacy@kaako.ca.
Upon receiving a verified request, we will delete or anonymize your data unless retention is required for:

Completing ongoing bookings or settlements;

Meeting tax, accounting, or legal record-keeping obligations;

Fraud prevention or security investigations; or

Resolving outstanding disputes.

Once these obligations are satisfied, your personal information will be securely erased from active systems.

7.3 User-Generated Content Rights

You may request the removal or anonymization of UGC you previously submitted, including reviews, photos, and Q&A posts, by contacting info@kaako.ca.

Please note that some UGC may remain visible in anonymized form or may be retained where required to enforce our Terms of Service, support fraud prevention, or maintain the continuity of Q&A or review discussions.

7.4 Withdrawal of Consent

Where processing is based on your consent (for example, receiving marketing emails or push notifications), you may withdraw that consent at any time by updating your in-app settings or contacting us directly.

Withdrawal of consent will not affect processing that occurred before your withdrawal or processing that is required to provide the Services.

7.5 Communication Preferences

You can control notification and marketing settings through your KAAKO account or device preferences.

All marketing communications will include an “unsubscribe” or equivalent opt-out option in compliance with Canada’s Anti-Spam Legislation (CASL).

8. Security of Information

KAAKO takes the security of your information seriously.

We take the protection of your personal and business information seriously and have implemented a combination of technical, administrative, and physical safeguards designed to maintain its confidentiality, integrity, and availability.

8.1 Secure Infrastructure

KAAKO is built on Google Firebase, a secure, industry-standard cloud platform that provides encrypted data storage, authentication, and network protection.

All data transmitted between your device and our servers is protected using Transport Layer Security (TLS) encryption.
Firebase’s infrastructure is hosted in Google Cloud data centers that meet international standards for data security and reliability.

8.2 Access Control and Data Permissions

We use Firebase Authentication and Firestore database security rules to ensure that each user can access only their own authorized information.

Access to user and partner data is restricted based on authentication tokens and verified identities.
Our Firestore rules are designed to enforce principle of least privilege, meaning no one — including other users or restaurants — can view or modify data that does not belong to them.

Administrative access to production data is limited to authorized KAAKO personnel who require it to perform operational duties, and all such access is logged and monitored.

8.3 Data Encryption and Storage

All personal information stored in Firebase Firestore and Firebase Storage is encrypted both in transit and at rest.

Sensitive data such as authentication identifiers, financial records, and settlement information are stored using secure, access-controlled mechanisms.

We periodically review our data storage policies to ensure ongoing compliance with privacy and security best practices.

8.4 Monitoring and Incident Response

KAAKO uses Firebase Crashlytics, Firebase Monitoring, and Google Cloud logging tools to detect abnormal behavior, service errors, or potential security threats.

If a data breach or unauthorized access incident were ever to occur, we would promptly investigate, contain the incident, and notify affected individuals and regulators in accordance with applicable privacy laws.

8.5 No Absolute Guarantee

While we strive to use commercially reasonable means to protect your information, no electronic storage or transmission system is completely secure.

Accordingly, we cannot guarantee absolute security, but we continuously review and update our practices to mitigate potential risks.

9. International Data Transfers

KAAKO Technology Inc. operates primarily in Canada but uses third-party cloud infrastructure that may store or process personal information outside the country.

Our Services are hosted on Google Firebase, part of the Google Cloud Platform, with data primarily stored in the United States.

9.1 Cross-Border Processing

Personal and business information collected through the KAAKO User App, Restaurant Dashboard, or website may be transferred to and processed in countries other than Canada, including the United States.

These countries may have privacy and data-protection laws that differ from those in Canada; however, we ensure that your information remains protected through contractual and technical safeguards consistent with Canadian requirements.

9.2 Safeguards for International Transfers

Firebase and Google Cloud maintain compliance with recognized security standards such as ISO/IEC 27001, SOC 2, and CSA STAR certifications.

All transfers of information between your device and our systems are encrypted using Transport Layer Security (TLS), and all stored data remains encrypted at rest.

Access to data stored outside Canada is limited to authorized personnel who require it to operate or improve our Services, and such access is logged and monitored.

9.3 User Acknowledgment

By using our Services, you understand and consent that your personal or business information may be processed and stored in the United States or other jurisdictions where our service providers operate.

We continue to apply the protections described in this Policy regardless of the location of processing.

10. Children’s Privacy

KAAKO’s Services are designed for general audiences and may be used by individuals aged 13 years and older.
We do not knowingly collect or solicit personal information from individuals under the age of 13.

If you are under 13, please do not register for an account, make a booking, or provide any personal information through our Services without parental or guardian consent. Parents or legal guardians who believe that a child under 13 has provided personal information to KAAKO may contact us at info@kaako.ca to request its deletion.

For users aged 13 to 18, we process personal information only to the extent necessary to provide our Services and in a manner consistent with applicable privacy laws.

We encourage all users under 18 to review this Privacy Policy with their parent or guardian to ensure they understand their rights and our practices.

11. User-Generated Content (UGC) and Community Features

KAAKO provides community features that allow Users to submit user-generated content (“UGC”), including restaurant reviews, ratings, photographs, suggested happy-hour or deal information, comments, and questions or answers (“Q&A”). This section explains how such content is collected, displayed, moderated, and retained.

11.1 Types of User-Generated Content

UGC may include, but is not limited to:

Written restaurant reviews and ratings
Photographs uploaded during or after restaurant visits
Suggested updates or submissions regarding restaurant deals, happy hour periods, or menu information
Questions and answers posted in the Q&A section of restaurant pages
Comments, feedback, or other publicly viewable text submitted through the App

UGC is voluntary and may be publicly visible to other Users and restaurant Partners.

11.2 Collection and Public Display

When you submit UGC, we collect the content itself along with metadata such as timestamps, display name, and profile image (if provided).

Your UGC will be displayed publicly on restaurant pages, search results, and other community features within the KAAKO platform.

Certain UGC may also appear in promotional content, curated lists, summary rankings, or other features that highlight platform activity.

Your email address, phone number, and private profile details are never displayed with your UGC.

11.3 Responsibility for Submitted Content

By submitting UGC, you acknowledge and agree that:

You are solely responsible for the accuracy and legality of the content you submit.
You must not include personal information about yourself or others within your UGC.
You must not upload copyrighted, offensive, defamatory, misleading, fraudulent, or otherwise prohibited content.
Content related to deals, discounts, or menu information must be based on genuine experience or observation.

Violations of these guidelines may result in the removal of your UGC or suspension of your account, in accordance with the Terms of Service and Fair Use Policy.

11.4 Moderation and Removal

KAAKO may review, moderate, or remove UGC at any time to:

Enforce our Terms of Service or Fair Use Policy
Comply with legal obligations
Respond to reports from Users or restaurant Partners
Prevent misinformation or harmful content
Protect the integrity of the platform

KAAKO is not obligated to review all UGC and does not guarantee that all objectionable content will be removed.

Restaurant owners who have verified ownership of their business may request the removal of inaccurate or harmful UGC, subject to KAAKO’s moderation guidelines.

11.5 License to Use Submitted Content

By submitting UGC, you grant KAAKO a worldwide, royalty-free, non-exclusive, transferable, and sublicensable license to:

Store, display, reproduce, publish, distribute, adapt, and modify your UGC
Use your UGC for operating, improving, and promoting our Services
Display your UGC to Users, restaurant Partners, and in-app features such as recommendations, rankings, and search results

This license continues even if you delete your account, unless your UGC is removed or anonymized under Section 11.6.

11.6 Retention, Removal, and Anonymization

UGC may be retained even after your account is deleted to preserve platform integrity, prevent fraud, or maintain continuity of community discussions (such as Q&A threads).

Upon your request, we will:

Remove UGC that is directly linked to your identity (where feasible); or
Anonymize UGC by removing your name, photo, or profile link while maintaining the usefulness of the content.

Some UGC cannot be fully deleted if it is required:

For legal compliance
To maintain historical accuracy
To resolve disputes
For detecting abuse or fraudulent activity

Requests can be submitted to info@kaako.ca.

11.7 Restaurant Partner Interactions with UGC

Restaurant Partners may, upon verifying ownership of their business, access UGC associated with their restaurant, including:

Reviews
Photos
Q&A submissions
Suggested deal or menu updates

Partners do not receive your personal contact information and cannot directly identify you unless you include such information in your UGC (which is discouraged).

Owners may request correction or removal of inaccurate UGC, subject to KAAKO’s moderation guidelines.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements.
Whenever we make material updates, we will:

Post the revised version on our website and within the KAAKO mobile applications;

Update the “Last Updated” date displayed at the top of the Policy; and

Notify registered users by email and, where appropriate, through an in-app notification.

Your continued use of our Services after any update to this Policy constitutes your acknowledgment of the revised terms.
We encourage you to review this Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal information is handled, please contact us at:

KAAKO Technology Inc.
Email: info@kaako.ca
Province of British Columbia, Canada

We will review and respond to all inquiries in a timely manner and in accordance with applicable privacy laws.
If you are not satisfied with our response, you may also contact the Office of the Privacy Commissioner of Canada or the Office of the Information and Privacy Commissioner for British Columbia for further guidance.

Privacy Policy

Effective Date: October 20th, 2025

Last Updated: Demeber 1st, 2025