1. Information We Collect
There are three general categories of information that we collect.
1.1. Information You Give Us.
We collect information you share with us when you use
the SHW in order to ensure the adequate performance of contracts between you
and Mediterra Ltd, or between you and a Supplier. The provision of this
information is necessary to use the SHW and, without it, we will not be
able to provide you with services that you request.
When you sign up for an SHW account or submit a request for Accommodation booking information, we require certain information such as your name and email address. Profile Information. To use certain features within the SHW, we may need to ask you to complete a profile, which may include your address and phone number. Other Authentication-Related Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identification that you provide (like a photo of your government-issued ID) or other authentication information.
When you use the Payment Services (such as when booking Accommodation or a trSHel-related experience through us or establishing a Supplier relationship via us), we require certain financial information (like your bank account or credit card information) to process payments and comply with applicable law. If you are a Supplier, we may require additional information such as your ID or tax ID (where permitted by applicable law), and other proof of identification or verification in order to verify your identity, provide the Payment Services to you, and comply with applicable law. If you are a Guest, we may retain your financial information to assist you with booking trSHel-related experiences with third parties.
Communications with Mediterra Ltd.
When you communicate with Mediterra Ltd, we collect information about your communication and any information you choose to provide.
Other Information. You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, trSHel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with an SH representative, conduct a search, update or add information to your SHW account, respond to surveys, participate in promotions, or use other features of the SHW.
1.2. Information We Automatically Collect from Your Use of the SHW.
When you use the SHW, we collect information about the
services you use and how you use them, even if you don’t sign up for an SH
account. We process this information for the activities and legal bases
described in Section 2 below.
We collect information about your interactions with the SHW, such as the pages or other content you view, your searches for villas, bookings you hSHe made, the experiences and activities you book with others through us, and other actions on the SHW.
When you use certain features of the SHW, we may collect different types of information about your general location (e.g. IP address, zip code).
We automatically collect log information when you use the SHW, even if you hSHe not created an SH account or logged in. That information includes, among other things: details about how you’ve used the SHW (including if you clicked on links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the SHW.
We collect information related to your transactions on the SHW or transactions made through the SHW, including the date and time, amounts charged, and other related transaction details.
Cookies and Similar Technologies.
1.3. Information We Collect from Third Parties.
We may collect information that others provide about
you when they use the SHW, or obtain information from other sources and combine
that with information we collect through the SHW. SH does not control,
supervise or respond for how the third parties providing your information
process your personal data, and any information request regarding the
disclosure of your personal information to SH should be directed to such third
Third Party Services.
If you link, connect, or login to your SH account with a third party service (e.g., Facebook, Twitter, Google), we may collect information from the third party service, such as your registration and profile information. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
For certain Members in the United States, to the extent permitted by applicable laws, SH 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, SH may obtain the local version of background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports. We will only collect this information where required by applicable laws or where necessary to ensure the adequate performance of our services for you.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners (such as SafelyStay) and combine it with information we hSHe about you. For example, we may receive background check results 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 SHW, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through SH, the restaurant may send information to us that you submitted to them, like your dining preferences or dining activity. We may receive information about you and your activities on and off the SHW through partnerships, or about your experiences and interactions from our partner ad networks.
2. How We Use The Information We Collect
We use, store, and process information about you to provide, understand, improve, and develop the SHW, and to create and maintain a trusted and safer environment.
2.1. Provide, Improve, and Develop the SHW.
Enable you to access and use the SHW.
Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
Enable you to communicate with other Members. Operate, provide, improve and optimize the SHW and experience, such as by performing analytics and conducting research.
Personalize or otherwise customize your experience by, among other things making Accommodation suggestions, ranking search results or showing ads based on your search or booking history, and any preferences you provide to us, or that are signified by your search and booking history. Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
Provide customer service.
Send you service or support messages, such as updates, security alerts, and account notifications. If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any other purpose you authorize at the time of collection. We process this information given our legitimate interest in improving the SHW and our users’ experience with it, and to ensure the adequate performance of our contract with you.
2.2. Create and Maintain a Trusted and Safer Environment.
Detect and prevent fraud, spam, abuse, security
incidents, and other harmful activity.
Conduct investigations and risk assessments.
Verify or authenticate information or identification provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
Conduct checks against databases and other information sources.
Comply with our legal obligations.
Resolve any disputes with any of our users and enforce our agreements with third parties. Enforce our Terms of Service, Member agreements, and policies. We process this information given our legitimate interest in protecting the SHW, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing.
Send you promotional messages, marketing, advertising,
and other information that may be of interest to you based on your
communication preferences (including information about SH or partner campaigns
and services, such as services offered by SH’s affiliate, Airbnb).
Personalize, measure, and improve advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by SH or its third party business partners.
Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our services, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you. We process this information given our legitimate interest in protecting the SHW, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3. Sharing & Disclosure
3.1. With Your Consent or Where Authorized by Law.
We may share your information at your direction or as described by us to you at the time of sharing, such as if you, as a Guest, hSHe requested us to connect you with a third party vendor or to purchase services from a third party vendor on your behalf, in connection with your booking (e.g., an insurance provider or activities provider), or if you, as a Supplier, hSHe agreed to let us market your Accommodation through, or refer you to, a third party’s platform. In these situations, you are authorizing SH to disclose to these third party vendors information required to book them and to receive the relevant services from them. This could include special preferences or requests, and any additional guest information. These third party vendors are not controlled by SH and personal information shared with them is subject to their privacy policies and practices. We may also share certain contact details about you, such as your name, email and past reservations in SH, to other companies and business partners of SH, including our affiliate, Airbnb, who may then send you marketing communications about products or services that may interest you.
3.2. Sharing between Suppliers and Guests.
When you as a Guest submit a booking request, certain
information about you may be shared with the Supplier to coordinate the
booking, such as your name, contact details, and arrival date.
When you as a Supplier hSHe a confirmed booking, certain of information about you may be shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation address. Sharing this information is necessary to provide Guests with our services, and we don’t share your billing and payout information with other Members.
3.3. Reviews, Listings, and other Public Information.
The SHW publishes information that is visible to the
general public. For example:
Public Listing pages are publicly visible and include information such as the Accommodation’s approximate or exact location, Listing description, calendar SHailability, and any additional information the Supplier chooses to share. After completing a booking, Guests may write reviews which may appear publicly on Listing pages (and other pages on which we may market Accommodations) under their first name, last initial, and general location. If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the SHW, that content is publicly visible. Information you share publicly on the SHW may be indexed through third party search engines. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4. Service Providers.
We use a variety of third party service providers to help us provide services related to the SHW and ensure we can adequately provide you with our services. For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers hSHe limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this policy.
3.5. Additional Services by Suppliers.
Suppliers may use third party services SHailable through the SHW to assist with managing their Accommodation or providing additional services, such as cleaning services, insurance or activities providers. Suppliers may use features on the SHW to share information about the Guest (like the Guest’s check-in and check-out dates, name, phone number, and anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services.
3.6. Safety and Compliance with Law.
3.7. Corporate Affiliates.
To help us provide the SHW, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Additionally, we share your information with our affiliates to support, integrate, promote, and improve the SHW and our affiliates’ services. Our affiliates include Airbnb and Booking companies.
We may display parts of the SHW (e.g., your Listing page) on sites operated by SH’s business partners, using technologies such as widgets or APIs.
3.9. Tax Authorities.
In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers and Guests expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.
3.10. Business Transfers.
3.11. Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified information for industry and market analysis, regulatory compliance, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1. Analyzing your Communications.
We may review, scan, or analyze your communications on the SHW for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, 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 websites. 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. However, occasionally we may need to manually review some 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 communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on SH’s legitimate interest in ensuring compliance with applicable laws, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Linking Third Party Accounts.
You may link your SH account with your account at a
third party social networking service. When you create this link:
The 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
the publication and display of information that you provide to SH through this linkage is subject to any of your settings and authorizations on the SHW and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
4.3 Google Maps/Earth.
5. Third Party Partners & Integrations
The SHW may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). SH doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Airbnb, or both. These Third Party Partners will hSHe their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Choices
6.1. Managing Your Information.
You may access, update, and correct most of your basic personal information by logging into your SH account and reviewing your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by us. In some cases and where permitted by law, we may charge a fee which will be disclosed to you before we comply with your request. You are responsible for keeping your personal information up-to-date.
6.2 Data Retention & Account Cancellation.
We generally retain your information for as long as is
needed to provide the SHW to you, or for as long as your account is active. If
you no longer want us to use your information to provide the SHW to you, you
may cancel your account or request us to erase your personal information. To
cancel your SH account, contact us. If you cancel your account or request
erasure of your personal information, note that:
Information you hSHe shared with others (such as Listing reviews) may continue to be publicly visible on the SHW in association with your first name, even after your SH account is cancelled.
Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers. Because we maintain the SHW to protect from accidental or malicious loss and destruction, residual copies of your information may not be removed from our backup systems for a limited period of time. SH may retain certain information to the extent necessary to comply with its legal obligations. SH may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if SH removes a user account for fraud or user safety reasons, SH may retain certain information from that account to prevent that user from opening a new SH account in the future.
6.3 Withdrawing Consent.
6.4 Data Portability.
In some jurisdictions, applicable law may entitle you to request a copy of your personal information that you hSHe provided to us and/or to request us to move such personal information to another service provider. In such cases, and in line with our legal obligations, we will provide you or the service provider with information in a structured and commonly used format.
6.5 Restricting Processing.
In certain extraordinary circumstances (e.g. where you think that SH is not holding accurate data about you) and in line with applicable law, you may request SH to temporarily restrict our use of your personal information for a limited period of time until the extraordinary circumstance that justified the restriction ends.
6.6 Objecting to Processing (including Automated Decision-Making).
In some jurisdictions, applicable law may entitle you to require SH not to process your personal information for certain specific purposes, such as profiling or marketing purposes.
6.7 Exercising Rights and Lodging Complaints.
If you would like to learn more about, or exercise any of, the rights described in this Section 6, contact us at privacy@apanemSHillas.com. We may ask you to verify your identity before taking further action on your request. You hSHe the right to lodge complaints about the data processing activities carried out by SH before competent data protection authorities.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.