Privacy and Personal Data Policy

PERSONAL INFORMATION WE COLLECT 1.1. Information Required for Platform Use We collect personal information about you when you use the Platform. Without this information, providing some services may become impossible. This information includes: Contact information, account, and profile information. For example, name, surname, phone number, postal address, email address, date of birth, and profile photo. The specific information collected depends on the features used. Identity verification and payment information. For example, images of government-issued identification (in accordance with applicable law), identification number, or other information for identity confirmation, selfies for identity verification, bank account, or payment account information. If you are not a user, we may receive payment information related to you, for example, when a user provides your payment card. If a copy of your identification is provided to us, we may scan, use, and store information contained in your identification to confirm your identity and for security purposes. 1.2. Information You Provide to Us Voluntarily You may provide us with additional personal information. This information may include: Additional profile information. For example, gender, preferred language (or languages), city, and personal description. Depending on your account settings, some information may be displayed on your public profile page. Information about other individuals. For example, a payment method belonging to another person, or information about companions. By providing us with personal information about other individuals, you confirm that you have permission to provide this information for the purposes described in this Privacy Policy, and you have informed these individuals about the Privacy Policy. Other information. For example, when you fill out forms, add information to your account, participate in surveys, post messages on community forums, participate in promotions, communicate with customer support and other Users, import or manually enter contacts from your address book, specify your address and/or geolocation, and share your experiences with us. This category may also include medical information if you choose to share it with us. 1.3. Information Automatically Collected When Using the Platform and Our Payment Services When you use the Platform and Payment Services, we automatically collect personal and other information. This information may include: Geolocation information. For example, the precise or approximate location determined by the IP address, GPS of a mobile or other device, or other information you provide us, depending on your device settings. We also may collect this information when you are not using the app if you give the appropriate permission in your device settings. Usage statistics. For example, the pages or content you view, Listing searches, bookings made, additional services you select, and other actions on the Platform. Log data and device information. For example, details of your Platform usage (including transitions to third-party apps), IP addresses, access date and time, software and hardware data, device information, device event information, unique identifiers, crash data, and the pages you viewed or interacted with before or after using the Platform. We may collect this information even if you do not have an account or are not logged in. Cookies and similar technologies. Information about payment transactions. For example, the payment instrument used, date and time, payment amount, expiration date of the payment instrument, postal code, email address linked to PayPal, IBAN information, your address, and other details of the payment transaction. 1.4. Personal Information We Receive from Third Parties We collect personal information from other sources, including: Third-party services. If you connect the Platform to a third-party service (e.g., Google, Facebook, or WeChat) or log into your account using such a third-party service, you give permission for that service to send us information about your registration, friend list, and profile in accordance with that service's privacy settings. Information about your background. For Users in the USA, where permitted by law, we may obtain, for example, criminal record reports, information from sex offender registries, and other information about you and/or your background. For Property Hosts in India, we may check criminal records in accordance with applicable laws. To verify Users from other countries, to the extent permitted by law and with your consent (if required), we may request available information about offenses, convictions, and sex crimes. To obtain such information, we may use information about you, including your full name and date of birth. Invitations to use corporate products and account management. Organizations using our Corporate products may provide personal information to facilitate account management and send invitations to use corporate products. Other sources. To the extent permitted by law, we may receive additional information about you from service providers and/or partners, including recommendations, demographic data, and information that helps identify fraudulent activities and ensure security, and combine this information with the information we have about you. For example, as part of our risk assessment and fraud prevention activities, as well as security investigations, we may receive reliability check results or fraud warnings from identity verification services. We may receive information about you and your activities on and off the Platform or interaction with various services from our partners. We may receive medical information, including medical information related to infectious diseases. HOW WE USE THE COLLECTED INFORMATION We use your personal information as stated in this Privacy Policy. 2.1. Providing, improving, and developing the Platform. This information may be processed by us to: Provide you with access to the Platform, make and receive payments; Enable you to communicate with other Users; Process your requests; Conduct analytics, system debugging, and research; Conduct customer service training; Send you technical messages, support service messages, updates, security alerts, and account notifications; Process or evaluate insurance claims or similar claims; Personalize and customize the user interface based on interaction with the Platform, search history and bookings, profile information and preferences, and other content you submit; Allow you to use our corporate products and accommodation services. If you provide us with information about your contacts, such as your friends or those you travel with, we may process it to: (i) facilitate your invitation of referrals, (iii) detect and prevent fraud cases, and (iv) facilitate the processing of your requests or for any other purposes approved by you. 2.2. Ensuring Security and Mutual Trust. This information may be processed by us to: Detect and prevent fraud, spam, abuse, security incidents, and other malicious activities; Study discrimination and fight against it; Prevent fraud, conduct security investigations and risk assessments; Verify or authenticate the information you provided; Conduct comparisons with databases and other information sources, including information about your past; Comply with our legal obligations, protect the health and well-being of our Guests, and public representatives; Resolve disputes with our Users, including sharing information with your Co-Host or additional Guests about disputes related to your activity as a Co-Host or additional Guests; Ensure the enforcement of our agreements with third parties; Comply with laws, respond to legal requests, prevent harm and protect our rights (see Section 4.5); Ensure compliance with Terms and other policies; Evaluate your interaction with the Platform and information received from third parties. In some cases, if any action poses a danger or risks to our community or third parties, access to the platform may be automatically restricted or suspended based on the analysis of your account, actions on the platform, and information about actions on and off the platform that may be associated with you. If you disagree with decisions made automatically, contact us at the address mentioned in the "Contact Us" section below. 2.3. Ensuring the Functioning, Personalization, Analysis, and Improvement of Our Advertising and Marketing Campaigns. This information may be processed by us to: Send you promotional messages, marketing, and other information based on your preferences, as well as display advertisements on social networks; Personalize, evaluate, and improve advertising; Manage referral programs, rewards, conduct surveys, lotteries, contests, and other promotional events or activities sponsored or organized by the Platform or partners; Analyze preferences and parameters to send you promotional messages, marketing, advertising, and other information that we believe may be of interest to you; Invite you to events and inform you about other opportunities; and With your consent - send you promotional messages, marketing, and other information that may be of interest to you considering your preferences. 2.4. Analysis and Transfer of Your Messages. We may review, scan, or analyze your messages on the Platform, including for fraud prevention, risk assessment, compliance with regulatory requirements, conducting security investigations, product improvement, research, analytics, ensuring compliance with Terms, and customer support. For example, to prevent fraud, we may scan and analyze messages to conceal contact information and links to other sites. In accordance with applicable law, we may scan and analyze all images uploaded by users on the platform in correspondences, profiles, listings, and Impressions, for certain illegal or improper actions (e.g., evidence of child exploitation), to detect violations and report them to the relevant authorities. In some cases, we may also scan, review, or analyze messages to adjust, improve, and expand the range of offered products. Where feasible, we use Personalize and tailor the user interface based on your interaction with the Platform, search and booking history, profile information and preferences, and other content you submit; Enable you to utilize our corporate products and services for hosting. If you provide us with your contacts' information, for example, your friends or people you travel with, we may process it to: (i) facilitate your invitation of referrals, (iii) identify and prevent fraud cases, and (iv) facilitate the handling of your requests or for any other purposes you have approved. 2.2. Ensuring Safety and Mutual Trust. This information may be processed by us to: Detect and prevent fraud, spam, abuse, security incidents, and other malicious activities; Investigate and combat discrimination; Prevent fraud, conduct security investigations, and perform risk assessments; Verify or authenticate information you provided; Conduct comparisons with databases and other information sources, including information about your past; Comply with our legal obligations, protect the health and well-being of our Guests, and public representatives; Resolve disputes with our Users, including sharing information with your Co-Host or additional Guests about disputes related to your activity as a Co-Host or additional Guests; Ensure compliance with our agreements with third parties; Comply with laws, respond to legal requests, prevent harm and protect our rights (see Section 4.5); Ensure compliance with Terms and other policies; Evaluate your interaction with the Platform and information received from third parties. In some cases, if any action poses a danger or risks to our community or third parties, access to the platform may be automatically restricted or suspended based on the analysis of your account, actions on the platform, and information about actions on and off the platform that may be associated with you. If you disagree with the decisions made automatically, please contact us at the address mentioned in the "Contact Us" section below. 2.3. Ensuring Operation, Personalization, Analysis, and Improvement of Our Advertising and Marketing Campaigns. This information may be processed by us to: Send you promotional messages, marketing, and other information based on your preferences, as well as display ads on social networks; Personalize, evaluate, and improve advertising; Manage referral programs, rewards, conduct surveys, lotteries, contests, and other promotional events or activities sponsored or organized by the Platform or partners; Analyze your preferences and behavior to send you promotional messages, marketing, advertising, and other information we believe may interest you; Invite you to events and inform you about other opportunities; and With your consent - send you promotional messages, marketing, and other information that may be of interest to you considering your preferences. 2.4. Analysis and Sharing of Your Messages. We may review, scan, or analyze your messages on the Platform, including for fraud prevention, risk assessment, compliance with regulatory requirements, conducting security investigations, product improvement, research, analytics, ensuring compliance with Terms, and customer support. For example, to prevent fraud, we may scan and analyze messages to hide contact information and links to other sites. In accordance with applicable law, we may scan and analyze all images uploaded by users on the platform in correspondences, profiles, listings, and Impressions for certain illegal or improper actions (e.g., evidence of child exploitation), to detect violations and report them to the relevant authorities. In some cases, we may also scan, review, or analyze messages to adjust, improve, and expand the range of offered products. When possible, we use automatic tools. Sometimes, to evaluate and improve the functioning of these automatic tools, we may need to manually analyze individual correspondences, for example, in investigating fraudulent actions or in providing customer support. We do not review, scan, or analyze your correspondence to send third-party advertising messages, nor do we sell the results of such checks or analysis of correspondence. 2.5. Linking to Third-Party Service Accounts You can link your Account to third-party service accounts, such as social networks. Your contacts in these third-party services are referred to as "Friends." When you allow data exchange by linking an account: Part of the information provided to us as a result of linking accounts may be published in your public profile; Your actions on the Platform may become visible to your Friends on the Platform and/or in the third-party service; A link to your public profile on the third-party social network may be added to your public profile; Other users will be able to view the list of your mutual Friends or indication that you are a Friend of their Friend (if applicable); If other users attended the same educational institution, were born in the same city, or are in the same groups as you, they may see this information indicated in your social network; The information you provide to us as a result of linking accounts may be stored, processed, and transferred for the purposes of fraud prevention, conducting security investigations, and risk assessments; The publication and display of information you provide to the Platform 3.5. Business Transfers If we engage in a merger, acquisition, reorganization, sale of assets, bankruptcy, or other similar transactions, we may sell, transfer, or share some or all of our assets, including your information, in connection with such transaction or in contemplation of such transaction (for example, during due diligence). In this case, we will notify you before your personal information is transferred and becomes subject to a different privacy policy. OTHER IMPORTANT INFORMATION 4.1. Third-Party Partners and Integrations The Platform may contain links to third-party services. These third parties are not owned or controlled by us. When you interact with these third parties and use their services, you provide them with your information. The use of these services is governed by the privacy policies of their providers, such as the Additional Terms of Use for Google Maps and Google Earth services, Google Privacy Policy (for more information on how Google uses information, see here), PayPal Privacy Policy, and Citi Privacy Policy. YOUR RIGHTS You can exercise any rights described in this section in accordance with applicable law. We may ask you to verify your identity and request before processing your request. 5.1. Managing Your Information You can access and change your personal information through Account settings. If you have linked your Account to a third-party service, such as Facebook or Google, you can change the settings and unlink from this service in your Account settings. It is your responsibility to keep your personal data up to date. 5.2. Access to Information and Portability In some jurisdictions, according to the law, you may request certain copies of your personal information or information about how we process your personal information, request copies of the personal information provided in a standard, structured, and machine-readable format, and/or request the transfer of this information to another service provider (if technically feasible). 5.3. Data Deletion In some jurisdictions, you may request the deletion of your personal information. Please note that in the case of such a request for deletion of personal information, as well as in the case of suspension, cancellation, or voluntary closure of an account, the following rules apply: We have the right to retain your personal information necessary to achieve our legitimate business interests, including preventing money laundering, combating fraud, and enhancing security. For example, if an Account is blocked for fraudulent actions or for security reasons, we have the right to retain information from this Account to prevent the User from re-registering on the Platform in the future. We have the right to store and use your personal information to the extent necessary to fulfill our legal obligations. For example, companies may retain information to comply with tax and financial reporting requirements and audit requirements. Information you have shared (e.g., Reviews, forum posts) may remain publicly available on the Platform even after your Account is deleted. Due to the need to take measures to protect against accidental or intentional damage or loss of data, backup copies of your personal information will be deleted with a certain delay. SECURITY SYSTEM While guaranteeing complete security is impossible, we continuously undertake and improve administrative, technical, and physical measures to protect your personal information from unauthorized or illegal access, loss, destruction, or alteration. CHANGES TO THIS PRIVACY POLICY We reserve the right to make changes to this Privacy Policy at any time in accordance with applicable law. We will post the revised Privacy Policy and indicate the date of its last change at the beginning. In the event of significant changes, we will also notify you of these changes by email at least 30 (thirty) days before the date they take effect. If you disagree with the updated Privacy Policy, you may delete your Account. By not deleting your Account before the changes take effect and continuing to use the Platform, you thereby acknowledge acceptance of the updated Privacy Policy. We reserve the right to modify our Services at any time and for any reason, and to temporarily or permanently deny you access to our Services or the ability to use them, for example, if you violate the spirit or letter of our Terms, cause harm to us, our users, or others, or expose us, our users, or others to any risk or threat of legal claims. We also reserve the right to disable or delete your account if it has not been active since registration or has been inactive for a long time. CONTACT INFORMATION AND RESPONSIBLE PARTIES For questions or complaints regarding this Privacy Policy or the processing of personal data by the company, please contact us by sending an email to unitholderrl@gmail.com