Effective: Later in 2020 - work in progress..
- How and what type of personal information we collect and use
- When and with whom we share your personal information
- What choices you can make about how we collect, use, and share your personal information
2. What personal information do we collect and use, and how do we collect it?
We collect personal information when:
- You give us the information
- We collect it automatically
- We receive it from others
When you create an account on one of our sites, sign up to receive offers or information, or make a booking using our platform, you give us your personal information.
We also collect such information through automated technology such as cookies placed on your browser—with your consent where applicable—when you visit our sites or download and use our mobile apps. We also receive information from business partners and other third parties, which helps us improve our platform and associated tools and services, update and maintain accurate records, detect and investigate potential fraud, and more effectively market our services.
3. How is your personal information shared?
4. What are your rights and choices?
5. How to contact us
1. Core Principles
When it comes to your personal information we believe in transparency, not surprises. So before we get into the details, we want to share with you a few of our core privacy principles.
- First, we don’t sell your personal information to anyone. It’s just not the type of business we’re in.
- Second, we don’t share your personal information unless you’ve specifically allowed it, or for the very limited purposes described below.
- Finally, we appreciate that when you use our Houfy Services, you trust us with your information, and we take that responsibility very seriously.
This Privacy Notice applies to personal information collected by Houfy Corporation, through the Houfy websites, and mobile apps, mobile-optimized websites and other applications and/or electronic media (such as emails Houfy sends) (collectively, the “Services”). This includes, but is not limited to:
When you use the Houfy Services, we collect the following information, and use it only as described below:
2.1. Account Information.
We ask for and collect the following personal information about you when you use the Houfy Services. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information. When you sign up for an Houfy Account, we require certain information such as your first name, last name and email address.
- Profile and Listing Information. To use certain features of the Houfy Services (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
- Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
- Payment Information. To use certain features of the Houfy Services (such as booking or creating a Listing), we may require you to provide certain financial information (like credit card information) in order to facilitate the processing of payments (via Stripe or Square Payments).
- Communications with Houfy and other Members. When you communicate with Houfy or use the Houfy Services to communicate with other Members, we collect information about your communication and any information you choose to provide.
2.2. Third Party Account Information. If you use Third Party Services, such as social media or photo-sharing services, you may provide us with your Third Party Services account information, such as your username (note that we don’t store any passwords you use to access Third Party Services). We transmit, and may store, such account information, only as needed to provide the Houfy Services, and only in accordance with the terms and policies of the Third Party Services.
We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Third Party Services. If you link, connect, or login to your Houfy Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Background Information. For Members in the United States, to the extent permitted by applicable laws, Houfy may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, Houfy may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
- Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products (such a FabStayz LLC and programs with property managers and owners) may submit personal information to facilitate account management and invitations to use enterprise products.
- Referrals. If you are invited to Houfy, the person who invited you may submit personal information about you such as your email address or other contact information.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Houfy Services through partnerships, or about your experiences and interactions from our partner ad networks.
2.3. Payment Information. When you initially provide or update your payment information, we transmit it via an encrypted connection to our Payment Processor, Stripe or Square. Stripe and Square use and process payment information in accordance with their Privacy Policies. We don’t store payment information, other than zip code and/or country, which is required for billing and to comply with tax and other government regulations.
2.4. Communications With Us. When you send us emails or other communications, such as customer support inquiries, we maintain those communications and their contents so that we can resolve your inquiries or otherwise assist you.
Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications through your account’s “Settings” page
When you interact with an email sent from Houfy (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction. We won’t email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.
2.5. Public Comments On The Services. We maintain any comments, contributions to discussions or messages submitted to members of the Houfy Services, in order to provide the Houfy Services.
2.6. Files You Provide Us. When you use the Houfy Services, we store, process and transmit your Member Content (such as your photos) and information related to your Member Content (such as location tags in photos). We process and store such files and information in order to provide the Houfy Services, as described in our Terms of Service.
You may choose to provide us with additional personal information in order to obtain a better user experience when using the Houfy Services. This additional information will be processed based on our legitimate interest or when applicable, your consent.
- Additional Profile Information. You may choose to provide additional information as part of your Houfy profile (such as preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
- Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Houfy Services, like inviting them to use Houfy.
- Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Houfy Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team or use other features of the Houfy Services.
2.7. Usage Information. This includes information about your activity on and interaction with the Houfy Services, such as your IP address, your device or browser type, the webpage you visited before coming to our sites and identifiers associated with your devices. This information enables us to analyze how the Houfy Services are being accessed and used, and to track performance of the Houfy Services.
When you use the Houfy Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Houfy Services.
- Geo-location Information. Your devices (depending on your settings) may transmit location information to the Houfy Services. We use this information to customize, improve and protect the Houfy Services. For example, we may use your location information to determine local language preferences, or to geotag a post.
- Usage Information. We collect information about your interactions with the Houfy Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Houfy Services.
- Log Data and Device Information. We automatically collect log data and device information when you access and use the Houfy Services, even if you have not created an Houfy Account or logged in. That information includes, among other things: details about how you’ve used the Houfy Services (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Houfy Services.
- Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Houfy Services currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
When you use the Houfy Services, we may share your information only as described below:
3.1. Third Parties You Authorize. You can give third parties access to your and your End Users’ information on the Houfy Services. For example, you may wish to integrate Your Sites with a third party newsletter service that requires access to the email addresses you collect from your End Users, in order for that newsletter service to send emails on your behalf and at your direction. Just remember that such third party’s use of this information will be governed by the terms and privacy policies of the third party.
3.2. Following The Law. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to comply with the law, protect our rights or prevent fraud or abuse of Houfy or our members. When we receive law enforcement or national security requests for information, we strongly believe in privacy and transparency. We scrutinize such requests carefully and challenge vague, overbroad or otherwise unlawful requests. And when legally permitted, we provide our members with notice that their information is being requested. This notice is provided so that you have the opportunity to challenge such requests.
3.4. Business Transfers. If we're involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal.
We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.
If you know or have reason to believe that your Houfy Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Houfy Account, please contact us following the instructions in the Contact Us section below.
We'll retain your personal information for as long as we need it to provide you with the Services. You can ask for your personal information to be deleted at any time by deleting your Account or contacting us at email@example.com. Please note that there may be latency in deleting your personal information from our servers and backup storage, and we may retain your personal information in order to comply with the law, protect our rights, resolve disputes or enforce our agreements.
To modify or delete the personal information you have provided to us, simply log into the Houfy Services and update your profile. We may retain certain information as required by law or for necessary business purposes. On request, we'll provide you with a copy of your personal information that we maintain. This request may be subject to a fee not exceeding the prescribed fee permitted by law.
We may periodically email you service-related announcements. We'll also send you emails related to your transactions. We may also send you marketing or promotional communications, but you can opt out of receiving subsequent marketing or promotional communications by clicking the link marked unsubscribe (or a similar phrasing) that’s included in those communications.
9. End User Information
9.3. End User Payment Information. Your End Users’ payment information may be processed via third party eCommerce Payment Processors with which you integrate your Account, in accordance with such eCommerce Payment Processors’ terms and policies. We transmit your End Users’ complete payment information when they initially provide or update it, only so that we can pass it along to the eCommerce Payment Processors you agree to use. We don’t collect or store your End Users’ payment information.
10. Privacy Shield
10.1. Compliance. Houfy complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union to the United States (“EU Personal Data”). We’ve certified to the Department of Commerce that we adhere to the Privacy Shield Principles and, assuming our certification is approved, you’ll be able to find it here. You can learn more about Privacy Shield by visiting https://www.privacyshield.gov/.
10.3. Inquiries And Disputes. If you have questions you believe to be within the scope of our Privacy Shield certification, please contact us first at firstname.lastname@example.org and we'll respond within 45 days. For any complaints that we can’t resolve directly, JAMS is the independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance, and you can contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield. In the event your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under the Privacy Shield Principles. For purposes of enforcing compliance with the Privacy Shield, Houfy is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
10.4 California & Vermont Residents.
Houfy will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.
10.5 California Privacy Rights.
California law permits Members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. Houfy does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.
12. Contact Us
Houfy, Inc., Legal Department, PO Box 8392, Breckenridge, CO 80424 USA