Dated: August 7, 2017
INFORMATION WE COLLECT
At various times you may give your personal data to us. For example, in order to send a booking request or inquiry from you to another user, we may need to know all or some of the following: your full name, address, telephone number, e-mail address, your current location, and, in the case of a listing, a method of payment. You may also give personal data to us at other times, such as when registering on the Site or when submitting a listing for a property. We also receive your personal information when you set up financial account information for payment processing. We may also gather information from cookies or web beacons. You can find out more about how they operate in the relevant section of this policy below. We also collect IP addresses, mobile device identifier details, your location, navigation and click-stream data, the time of accessing the Site, properties you viewed, what you searched for, the duration of your visit, and other details of your activity on the Site. If you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information about you that way too. In connection with electronic communications we facilitate through a Site, we use electronic or manual checks to monitor such communications for trust and security purposes. For further details on how we collect personal data, see Surveys and Communications below. We obtain data from you either by you inputting your personal details, by the automatic collection of information about you as you use the Site, when we speak to you, or from third parties. Third party information may include financial information from our payment processor partners that we use to update our records and to prevent and detect fraud, information from your mobile provider if you are accessing the Site over a mobile device or information from a third party such as a social media or travel opinions site where you have asked us to share your data with them.
HOW WE USE YOUR INFORMATION
Our primary purpose in collecting your personal data is to provide you with the services you request and those which we believe will optimize your use of the Site. You agree that we may use your personal data for the following purposes:
- For the services provided on the Site or to support your request;
- To contact you from time to time with user or service updates;
- To send other messages that help us provide our services on the Site;
- To assist people you have done (or have agreed to do) business with;
- To customize, measure, report on and improve our services, content and advertising;
- To promote services related to the Site;
- To compare information for accuracy, update our records, and verify it with third parties;
- To prevent, investigate or prosecute activity we think may be potentially illegal, unlawful or harmful; and
We collate statistics about site traffic, sales and other commercial information which we pass onto third parties to assist us with improving the services we provide to you. We also use demographic information to tailor the Site and we share that information with third parties so that they can build up a better picture of our customer base and general consumer trends.
If you are listing a property, we may also display your phone number on the listing itself so that other members may contact you and to restrict fraudulent behavior. We may also contact you about your account and your use of our services.
HOW WE MAY DISCLOSE YOUR INFORMATION
We may disclose your personal data to enforce our policies, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, or in connection with actual or proposed litigation, or to protect our property, people and other rights or interests.
We may also share your personal data with:
- One of our partners if you’ve requested their services or if you’ve requested to be provided with information by them;
- The provider of any liability or other policy of insurance applicable to a user;
- Another member if you have done business with them;
- A third party performing services on our behalf, such as to process payments;
- Other companies or business entities, for example if we are thinking of a merger with or sale to that company or business entity;
- Any third party you have asked us to share your personal data with – such as Facebook if you have asked us to connect with your Facebook account; or
- Any legal or governmental entity pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments.
WHO PROCESSES YOUR PERSONAL INFORMATION
Your personal data (also referred to as personal information) – that is, data that identifies you, or from which you are identifiable – will be collected, processed, stored and used by us, and passed to and processed by third party data processors acting on our behalf. We do not knowingly collect or process data from anyone under the age of eighteen (18) years old.
We may offer different communications from time to time intended to enhance the services we or they offer. Users may cancel their subscription to these communications at any time, although it may take a short while for the changes in your preferences to become effective.
INQUIRIES AND OTHER ELECTRONIC COMMUNICATIONS
If you choose to send an inquiry or booking request through these links, your personal information, including your email address and any other information you supply (unless the Site specifies otherwise), will be visible to the property owner in question so that they might reply directly to you. Your details may also be sent to us and we have access to those communications even if you contact the property owner directly. If property owners and others (such as, but not limited to, members or users) further engage in communications through the Site, we also have access to those communications, which we may, in our discretion, monitor for compliance and security purposes. Additionally those inquiries and messages may be hosted on, be processed by or transmit through our servers. If you engage in such communications and call the other party, you may be asked to leave a return telephone number. Do not share information in the e-mail or phone call that you are not prepared to allow such person and us to have, including, but not limited to, credit card and bank account information. In addition inquiries and messages can be sent to the individual member you selected and to our system. Our customer service team may share such communications with property owners or managers. We may also from time to time, use third party e-mail servers to send and track receipt of such communications, and analyze the pattern of such communications for trust and security purposes as well as to gather data, such as inquiry and booking data (on an anonymous basis), to assist us in better understanding our business.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We take reasonable technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. We have security measures in place to protect our user database and access to this database is restricted internally. However, it remains your responsibility:
- To protect against unauthorized access to your use of the Site;
- To ensure no one else uses the Site while your machine is logged on to the Site (including by logging on to your machine through a mobile, Wi-Fi or shared access connection you are using);
- To log off or exit from the Site when not using it;
- Where relevant, to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network; and
- To maintain good internet security. For example if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us.
You should keep all of your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can, so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.
If you have asked us to share data with third party sites, however (such as Facebook) their servers may not be secure. Payment card and bank account information is generally stored by our payment processing partners and we contractually require them to keep that data secure. We also use third parties to help us optimize our Site flow, content and advertising (see below).
Note that, despite the measures taken by us and the third parties we engage, the Internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data.
If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties’ direct marketing purposes. To make such a request, please use the contact information below.
HOW TO ACCESS, UPDATE & DELETE YOUR INFORMATION
Upon your request, we will (a) correct or update your personal information; (b) stop sending emails to your email addresses; and/or (c) disable your account to prevent any future activity through that account. You can make these requests at the customer information section of the Site, or by emailing your request to email@example.com.