Last Updated: October 30, 2020
Vinera Hub exists to help build connections between people and make the world more open and inclusive. In short—to build a world where anyone can belong anywhere. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy.
- PERSONAL INFORMATION WE COLLECT
2.1 Information needed to use the Vinera Hub Platform.
We collect personal information about you when you use the Vinera Hub Platform. Without it, we may not be able to provide you with all services requested. This information includes:
- Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
2.2 Information you choose to give us.
You can choose to provide us with additional personal information. This information may include:
- Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
- Address Book Contact Information. Address book contacts you import or enter manually.
- Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.
2.3 Information Automatically Collected by Using the Vinera Hub Platform and our Payment Services.
When you use the Vinera Hub Platform and Payment Services, we automatically collect personal information. This information may include:
- Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
- Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Vinera Hub Platform.
- Log Data and Device Information. Such as details about how you’ve used the Vinera Hub Platform (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 Vinera Hub Platform. We may collect this information even if you haven’t created an Vinera Hub account or logged in.
- Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.
2.4 Personal Information We Collect from Third Parties.
We collect personal information from other sources, such as:.
- Third-Party Services. If you link, connect, or login to the Vinera Hub Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as 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, we 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, we 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 may submit personal information to facilitate account management and invitations to use enterprise products.
- Referrals and co-travelers. If you are invited to the Vinera Hub Platform such as a co-traveler on a trip, the person who invited you can 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 references, 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 or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Vinera Hub Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.
- HOW WE USE INFORMATION WE COLLECT
3.1 Provide, Improve, and Develop the Vinera Hub Platform. We use personal information to:
- enable you to access the Vinera Hub Platform and make and receive payments,
- enable you to communicate with other Members,
- perform analytics, debug and conduct research,
- provide customer service,
- send you messages, updates, security alerts, and account notifications,
- if you provide us with your contacts’ information such as your friends or co-travellers, we may process this information: (i) to facilitate your referral invitations, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
- personalize and customize your experience based on your interactions with the Vinera Hub Platform, your search and booking history, your profile information and preferences, and other content you submit, and
- enable your use of our enterprise products.
3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:
- detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
- study and combat discrimination consistent with our Nondiscrimination Policy,
- conduct security investigations and risk assessments,
- verify or authenticate information provided by you,
- conduct checks against databases and other information sources, including background or police checks,
- comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees and members of the public,
- resolve disputes with our Members,
- enforce our agreements with third parties,
- comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5)
- Enforce our Terms and other policies (e.g. Nondiscrimination Policy), and
- in connection with the activities above, we may conduct profiling based on your interactions with the Vinera Hub Platform, your profile information and other content you submit to Vinera Hub, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Vinera Hub Platform if such processes detect activity that we think poses a safety or other risk to Vinera Hub, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us via the Contact Information section below.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use personal information to:
- send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
- personalize, measure, and improve our advertising,
- administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Vinera Hub or its third-party partners,
- analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
- invite you to events and relevant opportunities.
3.4 Provide Payment services. Personal information is used to enable or authorize third parties to use Payment Services:
- Detect and prevent money laundering, fraud, abuse, security incidents.
- Conduct security investigations and risk assessments.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce the Payment Terms and other payment policies.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
- Provide and improve the Payment Services.
- SHARING & DISCLOSURE
4.1 Sharing With Your Consent or at Your Direction.
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Vinera Hub account or participating in promotional activities by Vinera Hub partners or third parties.
Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Vinera Hub or otherwise promote our products and services.
4.2 Sharing Between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information such as:
- When a booking request is made or dispute is submitted, certain information may be shared between Guest(s) and Host(s), including profile, name, names of any additional Guests, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a booking is confirmed, additional information is shared to assist with coordinating the trip, like profile photo and phone number. When you as a Host have a confirmed booking, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Listing address.
- When you as a Host invite another Member to host with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, calendar, Listing information, Listing photos, and email address.
- When you as a Guest invite additional Guests to a booking, your full name, travel dates, Host name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest.
4.3 Information You Publish in Profiles, Listings, and other Public Information.
You can make certain information publicly visible to others, such as:
- Your public profile page, which includes your profile photo, first name, description, and city.
- Listing pages that include information such as the Accommodation or Experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
- Reviews, ratings and other public feedback.
- Content in a community or discussion forum, blog or social media post.
We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms and apps.
Information you share publicly on the Vinera Hub Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.
4.4 Host Service Providers.
Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Vinera Hub Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third-party service providers.
4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Vinera Hub, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Vinera Hub, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Vinera Hub, our Members, or expose Vinera Hub to a claim of obstruction of justice.
For jurisdictions where Vinera Hub facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, bookings, Accommodations and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.
In jurisdictions where Vinera Hub facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Vinera Hub in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.
4.6 Programs with Managers and Owners.
We may share personal information of Hosts and Guests such as booking information, and information related to compliance with applicable laws.
4.7 Host Information Provided to Vinera Hub for Work Customers.
If a booking is designated as being for business or work purpose and (1) is made by a Guest affiliated with an Enterprise, (2) the Enterprise is enrolled in Vinera Hub for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Accommodation address, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of Vinera Hub’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.
4.8 Service Providers.
We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Vinera Hub Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Vinera Hub’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.
4.9 Business Transfers.
4.10 Corporate Affiliates.
To support us in providing, integrating, promoting and improving the Vinera Hub Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:
- Sharing with Vinera Hub, Inc. Even if your country of residence is not the United States, your information will be shared with Vinera Hub, Inc. which provides the technical infrastructure for the Vinera Hub Platform.
- Sharing with Vinera Hub Payments. In order to facilitate payments on or through the Vinera Hub Platform, certain information will be shared with the relevant Vinera Hub Payments entity.
- Sharing with Vinera Hub Ireland. Even if your country of residence is the United States, Japan or China, your information may be shared with Vinera Hub Ireland which provides customer support and other business operation services to other Vinera Hub entities.
- Sharing with Vinera Hub GSL. Even if your country of residence is not Japan, your information may be shared with Vinera Hub GSL which provides customer support and other business operation services to other Vinera Hub entities.
- Sharing with Vinera Hub China. Even if your country of residence is not China, some of your information will be shared with Vinera Hub China in the following circumstances:
- Public data. Information you share publicly on the Vinera Hub Platform.
- Creating a Listing. If you create a Listing in China, information shared includes: (i) your name, phone number, email address, and passport/ID details, (ii) information relating to the Listing (e.g., address), (iii) booking and check-in information relating to the Listing, such as Guest details as set out below in Host Services, dates, time and payment amounts, and (iv) messages between you and prospective and confirmed Guests at the Listing.
- Host Services. If you book a Host Service located in China, information shared includes: (i) your name, phone number, and email address (ii) booking and check-in information, including dates and time, (iii) messages between the Host and you or other Guests on the same booking, and (iv) the names, nationalities, gender, date of birth, and passport/ID details of any Guests.
- Sending Messages. If you send a message to a Host in relation to that Host’s Listing in China, information shared includes your name, profile picture and message content.
- OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the Vinera Hub Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.
5.2 Linking Third-Party Accounts.
You can link your Vinera Hub account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:
- some of the information provided to us from linking accounts may be published on your public profile,
- your activities on the Vinera Hub Platform may be displayed to your Friends on the Vinera Hub Platform and/or that third-party service,
- a link to your public profile on that third-party service may be included in your Vinera Hub public profile,
- other Vinera Hub users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
- other Vinera Hub users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
- information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
- publication and display of information that you provide to the Vinera Hub Platform through this linkage is subject to your settings and authorizations on the Vinera Hub Platform and the third-party service.
5.3 Third-Party Partners & Integrations.
- YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information.
You can access and update some of your personal information through your Account settings. If you connected your Vinera Hub Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.
6.2 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Data Erasure.
In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
- We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an Vinera Hub Account for fraud or safety reasons, we may retain information from that Vinera Hub Account to prevent that Member from opening a new Vinera Hub Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Vinera Hub and Vinera Hub Payments may keep information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Vinera Hub, even after your Vinera Hub Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
- Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
- CONTACT INFORMATION AND RESPONSIBLE Vinera Hub ENTITIES