Homely Spaces Limited Privacy Statement

Last Updated: August 15th, 2020

Homely Spaces values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, and tells you how to contact us.

Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Homely Spaces’ platform and services, and as otherwise described in this Privacy Statement
Enable and facilitate acceptance and processing of payments, coupons, and other transactions
Administer loyalty and rewards programs
Collect and enable booking-related reviews
Help you to use our services faster and more easily through features such as the ability to sign in using your account within the online services of Homely Spaces.

Communications and Marketing:

Respond to your questions and requests for information, and process information choices
Enable communication between travelers and travel suppliers, such as hotels and vacation-property owners and managers
Contact you (such as by text message, email, phone call, mail, push notification, or messaging on other communication platforms) to provide information such as travel booking confirmations and updates, for marketing purposes, or for other purposes as described in this Privacy Statement
Market our products and services, optimize such marketing to be more relevant to you, and measure and analyze the effectiveness of our marketing and promotions
Administer promotions such as contests, sweepstakes, and similar giveaways.

Other Business Purposes and Compliance:

Conduct surveys, market research, and data analytics
Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services
Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as otherwise described in this Privacy Statement
Create aggregated or otherwise anonymized or de-identified data, which we may use and disclose without restriction where permissible
Promote security, verify the identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks
Comply with applicable laws, protect our and our users’ rights and interests, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of legal processes
Comply with applicable security and anti-terrorism, anti-bribery, customs and immigration, and other such due-diligence laws and requirements
Operate our business as permitted by law.

Sharing of Personal Information:

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

Homely Spaces may share, access, and use your personal information as described in this Privacy Statement.
Third-party service providers. We share personal information with third parties in connection with the delivery of services to you and the operation of our business (for example, to provide payment-card processing, customer service, business analytics, and fraud-prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect personal information we share with them and may not use any directly identifying personal information other than to provide the services for which we have contracted them. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented to such use under the terms provided by the third party).
Travel suppliers. We share personal information with travel-related suppliers such as hotels, airlines, car-rental companies, insurance providers, vacation-rental property owners and managers, and where available, activity providers, and rail and cruise lines who fulfill your booking. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.
Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.
Other third parties. When you access certain features such as Facebook’s “Like” button, or use a single sign-on that allows you to login to our online services with your social-media credentials, you will share information with the social media company or other providers, such as the fact that you have visited or interacted with us. In the European Economic Area (EEA), Switzerland, and the United Kingdom (UK) we will not load social-media sharing or sign-on buttons on our website unless and until you accept our use of cookies and similar technologies. For more information, see our Cookie Statement. The third-party provider may combine this information with other information they have about you. The personal information shared will be governed by the third-party provider’s privacy policy (including any personal information we may access via the third-party provider). These third-party providers should inform you about how you can modify your privacy settings on their sites.
Legal rights and obligations. We may disclose your personal information 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 law enforcement or governmental authority, in connection with actual or proposed litigation, or to protect and defend our property, people, or other rights or interests. We may also share your personal information pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments as required by law or legal process.
Corporate transactions. We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignment, or asset sale, or in the unlikely event of bankruptcy. In the case of an acquisition, we will inform the buyer that it may use your personal information only for the purposes disclosed in this Privacy Statement.

Your Rights and Choices

You have certain rights and choices with respect to your personal information, as described below:

You can control our use of certain cookies by following the guidance in our Cookie Statement.
You can update the accuracy of your information at any time by either logging into your account or contacting us
If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the “unsubscribe” link in the email. You can also log into your account to change communication settings. Please note that if you choose to unsubscribe from or opt out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe.
For our mobile apps, you can view and manage notifications and preferences in the Settings menus of the apps and of your operating system
If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent.

For questions about privacy and your rights and choices, please contact us.

International Data Transfer:

The personal information we process may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data-protection laws that are different from the laws of your country.
The servers for our platform are located in the United States, and the Homely Spaces companies and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.
We also require that third-party service providers to whom a data transfer is made have appropriate safeguards in place to protect your personal information in compliance with applicable data protection law. The particular measures used will depend on the service provider, and our agreements with them may include European Commission-approved Standard Contractual Clauses, the service provider’s certification under the EU-U.S. or Swiss-U.S. Privacy Shield certification, or reliance on the service provider’s Binding Corporate Rules, as defined by the European Commission.

Security:

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

Record Retention:

We will retain your personal information in accordance with all applicable laws, for as long as it may be relevant to fulfill the purposes set forth in this Privacy Statement, unless a longer retention period is required or permitted by law. We will de-identify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods of time.

The criteria we use to determine our retention periods include:

The duration of our relationship with you, including any open accounts you may have with Homely Spaces, or recent bookings or other transactions you have made on our platform
Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us
Whether there are any relevant legal or tax-related obligations affecting how long we will keep your personal information, including contract and audit obligations, litigation holds, statutes of limitations, and regulatory investigations.

Cookie Statement:

Types of cookies and similar technologies

Cookies are small pieces of text sent as files to your computer or mobile device when you visit most websites. Cookies may be delivered by us (first-party cookies) or delivered by a third-party partner or supplier (third-party cookies). Cookies are either session cookies or persistent cookies. Session cookies enable sites to recognize and link the actions of a user during a browsing session and expire at the end of each session. Persistent cookies help us recognize you as an existing user, and these cookies are stored on your system or device until they expire, although you can delete them before the expiration date.

Other similar technologies:

Web beacons, gifs, and clear gifs are tiny graphics, each with a unique identifier, that are embedded invisibly on sites and in emails. Web beacons allow us to know if a certain page was visited or if ad banners on our sites and other sites are effective. We also use web beacons in our HTML-based emails to let us know whether our emails have been opened by recipients, which helps us to gauge the effectiveness of certain communications, promotions, and marketing campaigns.Proximity-based beacons send one-way signals over very short distances, to communicate with associated apps installed on your phone or mobile device. They can notify you, for example, about experiences related to your trip and can alert you to related deals or promotions. Beacons communicate with your device only when you are in close proximity and only if you have given consent within the relevant mobile application.
Pixels are small objects embedded into a web page that are not visible to the user. We use pixels to deliver cookies to your computer, facilitate the log-in process, monitor the activity on our sites, and deliver online advertising.
Tags are small pieces of HTML code that tell your browser to request certain content generated by an ad server. We use tags to show you relevant advertising and promotions.
Scripts are pieces of JavaScript code that launch automatically when certain webpages load, to determine whether users view associated advertisements.
Local Storage Objects, such as HTML 5, are used to store content and preferences. Third parties with whom we partner to provide certain features on our site to display advertising based upon your web browsing activity use Local Storage Objects to collect and store information.
All of the technologies described above will be collectively referred to in this Cookie Statement as “cookies.”

Homely Spaces’ use of cookies:

At Homely Spaces, we use cookies for a number of reasons, including to:

Functional Cookies. We want to make sure that when you visit our site, your preferences (such as your preferred language), settings, and previous searches are remembered. Functional cookies enhance your experience on Homely Spaces.
Analytics Cookies. We use analytics cookies to:
Understand our site’s performance and how it is used, including the number of visitors, how long you stay on the site, and which parts of the site you visit. We can see details about how visitors have interacted with the site, such as the number of clicks made on a given page, mouse movements and scrolling activity, search words used, and the text entered into various fields
Test different designs and features for our site
Monitor how our visitors reach our sites
Determine the effectiveness of our advertising
Improve our services, including your experience on our site
For analytics, our third-party service providers may use cookies to perform their services and may combine the information that they collect about you on our sites with information they have collected elsewhere. For example, we use Google Analytics cookies to monitor the performance of our sites. Our ability to use and share information collected by Google Analytics about your visit to our sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. This Cookie Statement does not cover such third parties’ use of your information.
Some analytics cookies can perform tasks essential or functional to online services, such as enabling site improvements and testing changes to a site.

Advertising Cookies:

Homely Spaces and our third-party advertising partners may use advertising cookies to show you advertisements both on and off our sites that are based on your interests. We may allow third parties to collect information about your online activities through cookies to perform their services and may combine the information that they collect about you on our sites with other information that they have collected. These third parties include business partners who collect information when you view or interact with (1) their advertisements on our sites; or (2) our advertising or booking information on their sites and advertising networks, which collect information about your interests when you view or interact with one of the advertisements or tracking mechanisms they place on many different sites on the Internet. Our partners may make assumptions about your interests, characteristics, or preferences and add you to groups based on those assumptions in order to show you tailored advertisements. Homely Spaces does not have access to the cookies these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Cookie Statement or our Privacy Statement.

How can you manage your cookies?

You can set or amend your web browser controls to accept or refuse cookies whenever you like, but please remember if you do choose to reject cookies, your access to some of the functionality and areas of our site may be restricted.

Do-Not-Track Signals and Similar Mechanisms:

Some web browsers may transmit “do not track“ signals to sites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether users are even aware of them. Participants in the leading Internet-standards-setting organization that is addressing this issue are in the process of determining what, if anything, sites should do when they receive such signals. We currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess our sites’ responses to these signals and make appropriate updates to this Cookie Statement.

If you have any questions or concerns about our use of your personal information, please contact us.

Updates to Privacy Statement.

We may update this Privacy Statement in response to changing laws or technical or business developments. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Statement.

​Homely Spaces Limited Privacy Statement

Homely Spaces Limited Privacy Statement