1. INTRODUCTIONThank you for using do-so! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with do-so.
If you change your country of residence, the Data Controller and/or Payments Data Controller will be determined by your new country of residence as specified above, from the date on which your country of residence changes. To this end the Data Controller and/or Payment Data Controller that originally collected your personal information will need to transfer such personal information to the new applicable Data Controller and/or Payments Data Controller due to the fact that such transfer is necessary for the performance of the contractual relationship with you.
Please see the Contact Us section below for contact details of the Data Controllers and Payments Data Controllers.
2. INFORMATION do-so COLLECTSThere are three general categories of information we collect.
2.1 Information You Give to Us.
2.1.1 Information that is necessary for the use of the do-so Platform.We ask for and collect the following personal information about you when you use the do-so Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
• Account Information. When you sign up for an do-so Account, we require certain information such as your first name, last name, email address, and date of birth.
• Profile and Listing Information. To use certain features of the do-so Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. To learn more, see our Help Center article about providing identification on do-so.
• Payment Information. To use certain features of the do-so Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Payment service).
• Communications with do-so and other Members. When you communicate with do-so or use the do-so Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
2.1.2 Information you choose to give us.You may choose to provide us with additional personal information in order to obtain a better user experience when using do-so Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.
• Additional Profile Information. You may choose to provide additional information as part of your do-so profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
• Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the do-so Platform, like inviting them to use do-so.
• Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your do-so Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us (such as through Host Stories), or use other features of the do-so Platform.
2.1.3 Information that is necessary for the use of the Payment Services.The Payments Data Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
• Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
• Identity Verification and Other Information. If you are a Host, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
2.1.4 Information We Automatically Collect from Your Use of the do-so Platform and Payment Services.When you use the do-so Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the do-so Platform and Payment Services.
• Geo-location Information. When you use certain features of the do-so Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. do-so may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
• Usage Information. We collect information about your interactions with the do-so Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the do-so Platform.
• Log Data and Device Information. We automatically collect log data and device information when you access and use the do-so Platform, even if you have not created an do-so Account or logged in. That information includes, among other things: details about how you’ve used the do-so 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 do-so Platform.
2.1.5 Information We Collect from Third Parties.do-so and Payment service may collect information, including personal information, that others provide about you when they use the do-so Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the do-so Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
• Third Party Services. If you link, connect, or login to your do-so Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Your References. If someone has written a reference for you, it will be published on your do-so public profile page with your consent. To learn more, see our Help Center article about References.
• Background Information. For Members in the United States, to the extent permitted by applicable laws, do-so and Payment service 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, do-so and Payment service 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.
• Referrals. If you are invited to do-so, the person who invited you may submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the do-so Platform through partnerships, or about your experiences and interactions from our partner ad networks.
2.2 Children’s Data.Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
3. HOW WE USE INFORMATION WE COLLECTWe may use, store, and process personal information to (1) provide, understand, improve, and develop the do-so Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with do-so Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
3.1 Provide, Improve, and Develop the do-so Platform. We may use the personal information to provide, improve, and develop the do-so Platform such as to:• enable you to access and use the do-so Platform,
• enable you to communicate with other Members,
• operate, protect, improve, and optimize the do-so Platform and experience, such as by performing analytics and conducting research,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,
• to operate, protect, improve, and optimize the do-so Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Host Guarantee, Host Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with the do-so Platform, your search and booking history, your profile information and preferences, and other content you submit to the do-so Platform, and
• enable your use of our enterprise products.
We process this personal information for these purposes given our legitimate interest in improving the do-so Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:• detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• conduct security investigations and risk assessments,
• verify or authenticate information or identifications 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, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
• comply with our legal obligations,
• Resolve any disputes with any of our Members and enforce our agreements with third parties,
• enforce our Terms of Service and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the do-so Platform, your profile information and other content you submit to the do-so Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the do-so Platform if such processes detect activity that we think poses a safety or other risk to the do-so Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the do-so Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:• send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about do-so or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
• personalize, measure, and improve our advertising,
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by do-so or its third party partners,
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the do-so Platform, information obtained from third parties, 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,
• enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any do-so Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an do-so Account, and
• invite you to events and relevant opportunities (for example, when you share your Host story, we may use the information provided to reach out to you to invite you to relevant events).
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
3.4 How the Payments Data Controller uses the Personal Information Collected. We may use the personal information as a part of Payment services such as to:• Enable you to access and use the Payment Services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• 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.
The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
4. SHARING & DISCLOSURE
4.1 Advertising and Social Media; Sharing With Your Consent.Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your do-so Account or when you participate in promotional activities conducted by do-so partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the do-so Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by do-so. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask do-so to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
4.2 Sharing between Members.To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us.
4.3 Profiles, Listings, and other Public Information.The do-so Platform lets you publish information, including personal information, that is visible to the general public. For example:
• Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
Based on our legitimate interest to promote the do-so Platform we may display parts of the do-so Platform (e.g., your Listing page) on sites operated by do-so’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on the do-so Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. 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.
4.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.do-so and Payment service may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do-so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against do-so, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of do-so, its employees, its Members, or members of the public. For example, Host tax information may be shared with tax authorities or other governmental agencies.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the do-so Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
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 do-so’s property, its Members and the do-so Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4.6 Service Providers.do-so and Payment service uses a variety of third-party service providers to help us provide services related to the do-so Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.
For example, service providers may 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 do-so Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims (such as claims under the do-so Host Guarantee). These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions .
do-so and the Payment service will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
4.8 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 anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications.We may review, scan, or analyze your communications on the do-so Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, 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 messaging 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 do-so's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2 Linking Third Party Accounts.You may link your do-so Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:
• some of the information you provide to us from the linking of your accounts may be published on your do-so Account profile;
• your activities on the do-so Platform may be displayed to your Friends on the do-so Platform and/or that third party site;
• a link to your public profile on that third party social networking service may be included in your do-so public profile;
• other do-so users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
• other do-so 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;
• 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 do-so through this linkage is subject to your settings and authorizations on the do-so Platform 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.
6. YOUR RIGHTSYou may exercise any of the rights described in this section before your applicable do-so Data Controller and Payments Data Controller by sending an email to [firstname.lastname@example.org]. 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 may access and update some of your information through your Account settings. If you have chosen to connect your do-so Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2 Rectification of Inaccurate or Incomplete Information.You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your do-so Account).
6.3 Data Access and Portability.In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.4 Data Retention and Erasure.We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely." Please note that if you request the erasure of your personal information:
• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an do-so Account for fraud or safety reasons, we may retain certain information from that do-so Account to prevent that Member from opening a new do-so Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, do-so and Payment service may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the do-so Platform, even after your do-so Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the do-so Platform to protect 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.
6.5 Withdrawing Consent and Restriction of Processing.If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to do-so specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of do-so override your own.
6.6 Objection to Processing.In some jurisdictions, applicable law may entitle you to require do-so and Payment service not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing do-so and/or Payment service will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
8. SECURITYWe are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your do-so Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your do-so Account, please contact us following the instructions in the Contact Us section below.