Effective as of 04/28/2020.
We provide important information for individuals located in the European Economic Area and United Kingdom (collectively, “Europe” or “European”) below.
Table of Contents
- Personal Information We Collect
- How We Use Personal Information
- How We Share Personal Information
- Your Choices
- Other Sites, Mobile Applications and Services
- Security Practices
- International Data Transfers
- How To Contact Us
- Your California Privacy Rights
- Notice to European Users
- Biometric Data Policy
Personal Information We Collect
Information you provide to us. Personal information we collect on or through the Service or otherwise may include:
- Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, professional title and company name.
- Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload. This also includes information you provide by completing forms on our Service.
- Profile information, such as your username and password that you may set to establish an online account with us, your photograph, interests, and preferences.
- Registration information, such as information that may be related to a service, an account or an event for which you register.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Financial information, such as your stated income, economic standing, financial account number or payment card information.
- Demographic Information, such as your birthdate, city, state, country of residence, and postal code.
- Government-issued identification numbers, such as a national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license of state ID number).
- Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us. This may include billing information.
- Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service such as characteristics regarding your stays at other locations.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your username, user ID, profile picture, cover photo, and networks to which you belong. You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.
Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, we may receive your information from booking sites, homeowners, guests, property managers, identity verification vendors, consumer reporting agencies, data providers, publicly-available sources, marketing partners and insurance companies. This may include information such as guest/host identification number, guest/host name, guest/host address, guest/host phone number, guest/host email address, guest/host date of birth, guest/host driver’s license number, and guest/host social security number.
Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.
Third Party Personal Information
Users of the Service may have the opportunity to provide a guest or host’s personal information to us. You may only submit such information to us if you have permission to provide the guest or host’s personal information to us.
How We Use Personal Information
To operate the Service. We use personal information to:
- provide, operate and improve the Service
- provide information about our products and services
- establish and maintain user profiles on the Service
- facilitate your login to the Service via third-party identity and access management providers, such as Booking.com
- communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages
- communicate with you about events or contests in which you participate
- understand your needs and interests, and personalize your experience with the Service and our communications
- provide support and maintenance for the Service
- respond to your requests, questions and feedback
For research and development. We analyze use of the Service to improve the Service and to develop new products and services, including by studying user demographics and use of the Service.
To send you marketing and promotional communications. We may send you Safely-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
To display advertisements. We work with advertising partners to display advertisements on the Service or elsewhere online. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Service or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
To comply with law. We use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
How We Share Personal Information
Partners. We may sometimes share your personal information with partners or enable partners to collect information directly via our Service. For example, we may share personal information with insurance companies, travel sites, identity verification vendors, data providers and others.
Third-party platforms and social media networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
Other Users of the Service and the Public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, we may share guest personal information with hosts and host information with guests. Additionally, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display and share your name, username, and a link to your user profile along with the content you submit. We may make available settings through the [My Account] page that enables you to exercise choice regarding certain information that is displayed publicly or to other users. We do not control how other users or third parties use any personal information that you make available to other users or the public.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.
Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at email@example.com. You may continue to receive service-related and other non-marketing emails.
Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to the Service via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the Service using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.
Other sites, mobile applications and services
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
European Union users should read the important information provided below about transfer of personal information outside of the European Union.
The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 16 . If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
How to Contact Us
Please direct any questions or comments about this Policy or privacy practices to firstname.lastname@example.org [email address]. You may also write to us via postal mail at:
Attn: Legal – Privacy
P.O Box 19124
Atlanta, GA 31126
Your California Privacy Rights
Under California Civil Code section 1798.83, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us via email at P.O. Box 19124, Atlanta, GA 31126 and email@example.com. You must put the statement “Your California Privacy Rights” in your request and include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Notice to European Users
The information provided in this “Notice to European Users” section applies only to individuals in Europe.
Controller, Representative, and Data Protection Officer.
The contact information for our representative in Europe is: Please contact firstname.lastname@example.org
Legal bases for processing.
|Processing purpose (click link for details) Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.||Legal basis|
|To operate the Service||Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Service you access and request.|
|To administer events and contests |
For research and development
To send you marketing communications
To display advertisements
For compliance, fraud prevention and safety
To create anonymous, aggregated or de-identified data
|These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations.|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service.|
Use for new purposes.
Sensitive personal information.
We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us.
Automated Decision-Making and Profiling.
We may use automated decision-making and/or profiling in regard to your personal information for some services and products, for example we may decline your request for insurance. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision-making and/or profiling by contacting us at email@example.com.
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to firstname.lastname@example.org or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:
- Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
- Pursuant to the consent of the individual to whom the personal information pertains
- As otherwise permitted by applicable European requirements.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.
What types of cookies and similar tracking technologies does Safely use on the Sites?
|Advertising||These cookies are used by advertising companies to collect information about how you use our Sites and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Service and elsewhere, and to measure how the ads perform.||Facebook Twitter||See ‘your choices’ below.|
|Analytics||These cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.||Google Analytics Mixpanel||See ‘your choices’ below. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.|
|Essential||These cookies are necessary to allow the technical operation of our Service (e.g., they enable you to move around on a website and to use its features).||Google Tag Manager||See ‘your choices’ below.|
|Functionality/performance||These cookies enhance the performance and functionality of our Service.||Intercom||See ‘your choices’ below.|
In addition to cookies, our Sites may use other technologies, such as Flash technology and pixel tags to collect information automatically.
Browser Web Storage
We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.
We may use Flash cookies (which are also known as Flash Local Shared Object (“Flash LSOs”)) on our Sites to collect and store information about your use of our Sites. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Sites.
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Mobile Application Software Development Kits (SDKs)
We may use third-party software development kits (“SDKs”) in our mobile applications. A SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our App.
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Users of our mobile applications may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt-out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.
Last modified 01/21/2021.