Last updated 23rd May 2018
This Privacy Statement describes in a clear manner our commitment to protect customer privacy. It outlines how we collect, use, process and disclose any information, including your personal information obtained through the Website.
The statement outlines through your use of our Website www.homestay.com, owned and operated by Homestay Technologies Limited (Irish registered company number 505065):
- What personal data we collect and process from you as a customer and through your use of our Website.
- How we obtain, use, store and disclose any information given to us.
Homestay Technologies Limited, referred to as ‘we’ ‘us’ ‘our’ or ‘Homestay.com’ in this statement, respects your right to privacy and complies with our obligations in accordance with Irish and EU data protection laws. Homestay Technologies is the ‘data controller’ of any personal information that is collected and processed from our customers.
The purpose of this website Privacy Statement is to outline how we deal with any personal data you provide to us or we collect while visiting the Website.
The Website and services are intended solely for persons who are 18 years or older, any access to or use of the site or services by anyone under 18 years of age is expressly prohibited. By accessing, creating a user account or using the site or services you represent and warrant that you are over 18 years of age. If you are under 18 years of age, an adult must accompany and stay with you in the homestay for the duration of the booking.
Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy statements of any other website.
Personal Data is data that identifies you or can be used to identify or contact you and may include your name, nationality, gender, address, email address, booking reference number, user IP addresses (in circumstances where they have not been deleted, clipped or anonymised), telephone number, and payment details. Such information is only collected from you if you voluntarily submit it to us.
We will process any personal data provided to us by you for the following purposes: (i) Contract Operation & Management; the provision of the Services (ii) Translation; translating to another language for the purposes of overseas persons accessing the Site and/or the Services; and (iii) Direct Marketing; we, and/or our authorised agents with your consent may inform you by telephone, letter, email or post of special offers, discounts, competitions and promotions. Such emails may include links to the websites of third parties. With your consent we may make personal information provided to us available to third parties whom we work with for the purposes of direct marketing or to inform you of new features, special offers or new services.
The opportunity to opt in and out of such communications will be readily accessible from both your user account and any communications.
Personal data collected from you is necessary for the operation of the service contract between you and us. Without this data, we cannot provide you with our services. Below outlines the information processed:
- User Data: When you join the Website as a User, you provide the following information to create a profile on the Website: first name, last name, nationality, gender, email address, phone number and date of birth.
- Accommodation Data: Further information is required to create a host profile including your address, phone number, profile picture, pictures of your homestay, your location coordinates, your location description, amenities, and homestay rules.
- Messaging Data: To confirm a booking through the Website, users must communicate via our messaging system, the Website will collect all information and correspondence communicated via this messaging system. The messaging system includes a facility to allow hosts and guests to video call. Video calls may be recorded for auditing and performance monitoring purposes.
- Financial Data: Certain financial information (like your credit card details or bank account details) may be required from certain users when transacting a booking on the Website or where we facilitate the processing of deposit payments via a third party payments provider. This information is not collected or stored by our systems. The Website only collects a “tokenized” version that allows us to securely process payments using the third party payment platforms. Your email address and contact information may be provided to the payment providers so they can contact you directly in case of payment related issues. For any query in relation to the collection, storing or processing of this financial information, you will need to contact the payment providers directly.
Additional Personal Data
You may choose to provide us with additional personal information to enhance your profile on our Website. This additional information is processed based on your consent to provide information:
- Preferences: such as: Preferred language(s), a personal description, reason for travel, guest preference. This information will form part of your profile page, and will be publicly visible to others.
- Contacts: You may choose to import contacts from your address book or enter your contacts’ information manually to invite your contacts to become users and join the Website.
- Video/Voice Call: The Website uses a third party provider TokBox to facilitate the use of video / voice call for both hosts and guests. We will not disclose any user data derived from any user’s usage of the Video Call service (including without limitation, chat logs, contact information or IP addresses) other than in compliance with our Website privacy statement.
- Additional Information: You may choose to provide us with additional information when you fill in a form, conduct a search, update or add information to your user account, respond to surveys, post to blogs, social media posts, participate in promotions, or use other features of the Website.
Non Personal Data
Non Personal Data is data the Website automatically gathers, both statistical and other analytical information collected on an aggregate basis of all visitors to our web site. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses (where they have been clipped or anonymised), browser types and other anonymous statistical data involving the use of the Website.
We use non-personal data gathered from visitors to the Website in an aggregate form to get a better understanding of where our visitors come from and to help us better design, optimize, promote and operate the Website.
We automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for operational purposes to ensure we fulfil, optimize and improve the functionality of the Website and our contract with you. Below outlines the information processed:
- Geo-location Data: such as your IP address and country / city you are browsing from, to offer you an improved user experience and to verify your profile setup.
- Visitor Data: Visits to any pages or content you view, your homestay searches, bookings you have made, messages you have sent, reviews you have submitted and other actions taken on the Website.
- Device: Device information and log data when you access the Website even if you have not created a user account or logged in. That information includes, 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 page you’ve viewed or engaged with before using the Website (also known as “referrer”).
- Cookies: Cookies and other similar technologies, such as tracking pixels. We may allow our business partners to use these tracking technologies or engage others to track your behaviour on our behalf. You may disable the usage of cookies through your browser settings.Visit the section below on Cookies for more information. Disabling certain cookies will deteriorate the functionality of the Website. Disabling all cookies inhibits the operation of the Website, you will be unable to create a user account, make a request or complete a booking.
Information collected from Third Parties.
We will utilize and collect information from third parties to provide services on the Website:
- Payments Information: where we record and store the ID, date, method, amount and status of your payments on our Website given to us by our third party providers, Worldpay and Paypal, and the ID, date, method, amount and status of your payment of deposit out payments through Payoneer our third party providers. Use of these provider services is subject to their privacy policies. For hosts in selected countries we record the status of payments through a third party provider named Payoneer.com
- Account Login Information: As a user you can opt to link, connect or login to your user account via third party services such as Facebook. This third party will send us information for your user account registration and profile. The use of these services and information sent is controlled by that service and controlled and authorized by you via your own user account settings with that third party and subject to the third party privacy statement.
- Mapping Information: For mapping purposes, we utilise Google Maps/Earth services, including the Google Maps API(s). The use of Google Maps/Earth is subject to Google Maps privacy statement.
- Analytics Information: For website analysis Google analytics is used to track in aggregate the overall Website performance. For email analysis Sendgrid is used to track delivery of emails and interaction with call to actions included in those emails. For SMS messages, Nexmo and Message Bird are used to track delivery of SMS to your mobile phone.
- Social sharing Information: Addthis.com is used to allow users share pages from the Website on social networks. The third party service also sets cookies which track the usage of the service. They collect non-personally identifiable information from many of the websites in which AddThis is enabled, and use that information to deliver targeted advertising and personalized content on those websites as well as other websites. You can opt out of this here: http://www.addthis.com/privacy/opt-out
- Reviews Information: Reviews written or published about you as a host or you as a guest in relation to your stay will be automatically published where the review is 4 or 5 star in rating. We will moderate all other reviews and their publication is at the sole discretion of the Website. The Website reserves the right to use reviews at our discretion for marketing, promotion or improvement of service. The Website reserves the right to refuse, edit or remove reviews at our sole discretion.
- Paid Advertising Information: We use paid advertising (such as Google Adwords, Bing Ads, Facebook Ads, Google DoubleClick) to promote our website. These services will track if you click on a paid link and will mark a “conversion” on specific pages of our Website (eg: when you complete a request or a booking). These tracking cookies are used to determine what forms of advertisement are more effective to promote the Website.
- URL Shortener Information: We may use URL shortener services to provide you with shorter links to our pages (eg: goo.gl links). The Google URL shortener service tracks how many times shortened URLs are clicked and when.
The Website partners with affiliate websites worldwide, granting non-exclusive revocable license to use the affiliate platform and affiliate integration solutions to market the accommodation listings on affiliate websites. These partnerships increase the exposure of your accommodation to generate more bookings for your homestay. Affiliated websites use tracked links, widgets or API’s to integrate the Website listings. All data and/or content provided by the Host, including any description of the Host itself, descriptions of accommodation and any related facilities, photographs, video, maps, directions and contact details may be passed to the affiliate website for the purpose of integration and mapping. The affiliate will not expose any addresses or contact details or use the accommodation or host content for any purpose not expressly set out in an agreed affiliate partnership agreement including without limitation, directly or indirectly contacting of any host without the written consent of the Website.
Third Party / Ancillary Partner Integrations
The Website or communications to you may contain links to third party websites or services. Any such links are subject to the relevant parties own privacy policies which you should review when you visit any third party links from the Website.
What do we use your personal data for, why and for how long?
Your data will be used for some or all of the following purposes:
- The successful operation of the Services and Website
- To allow access to the Website in order to list and book on the Website
- Facilitate the communication between users via the Website messaging system
- Optimise the website for best performance, enhance user experiences, and ensure relevant targeted advertising, to auto suggest listings or rank listings
- To provide an efficient Customer Service function, to assist with customer queries.
- Share host user details such as name, address, email and phone number when a booking is confirmed and transacted with the guest user. Likewise share guest user details such as name, email, nationality, phone number with the host when a booking is confirmed.
- Allow translation of your profile to other languages to internationalise the Website.
- Facilitate your referral invitations and initiatives
- To prevent and detect fraudulent activity, spam, security incidents or inappropriate activity, where the outcome may give rise to user deactivation at the discretion of the Website
- Conduct marketing Initiatives, for example pre trip or mid trip newsletters, blog publications, social media advertising through third party platforms such as Facebook or Twitter, special offers or personalized services where you have explicitly given consent to do so.
- To display ads based on your interactions with the Website, for example, the city you searched for and your booking history. We may use third party providers such as Facebook or Google AdWords to display these ads.
- To comply with any affiliate partner agreements, where your listing is promoted via third party affiliated websites, via tracked links, widgets or API’s
- To comply with our legal obligations, such as responding to legal requests, applicable laws and servicing of contracts
Importantly, you can opt out of all or some direct marketing initiates by sending an e-mail to email@example.com or visiting your user account. You can request for your data to be erased and your user account closed at any time by sending an email to firstname.lastname@example.org.
Please note we may retain some of your personal data for reasons such as;
- Fraud detection and prevention and user safety
- Any legal obligations, eg for legal or audit purposes
- Content shared with us, such as reviews, blogs, posts, may remain visible.
- Activity history, such as booking data may remain for the purposes of reporting but will be anonymized.
How long do we retain your personal data for?
We will only process your personal data where we have a legal basis to do so and retain your personal data for as long as is necessary for the performance of the contract between us both. Your data will not be retained for longer than necessary to fulfil the purpose it is being processed for.
Security of your personal data
Your personal data is held on secure servers in Ireland hosted by Amazon Web Services (aws.amazon.com) whom are Safe Harbour Certified. We reserve the right to move your data to different datacenters (including datacenters located outside of the European Economic Area) to ensure maximum security and best level of service and by availing of the Services, you hereby consent to such transfer.
The database used for personal data (Amazon RDS) and storage system (Amazon S3) use industry standard AES-256 encryption, securing your data from unauthorized access to the underlying storage.
Any sensitive information transmitted between your computer and our Website is encrypted using SSL. DigiCert Inc. provides our SSL Cert and ensures your information is transmitted safely and securely. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.
Should you believe the security of your user account has been compromised in any way, please contact us immediately at email@example.com.
Our website also uses additional third party services, such as Google Analytics, AddThis, and more, that allow us to provide enhanced functionality and/or gather stats about the website usage. For a full list of cookies used please refer to Cookie Settings page: https://www.homestay.com/cookie_settings.
Whenever you use the Website or our apps, cookies and other tracking technologies are used in various ways. This statement explains how and why we use these technologies and the choices you have.
A cookie is a small amount of data that is placed in the browser of your computer or on your mobile device. For example, a cookie allows us to recognize your browser, while another could store what pages you visited. Two types of cookies are used on the Website: “session cookies” and “persistent cookies.” Session cookies normally expire when you close your browser. Persistent cookies remain on your device after you close your browser, and can be used again the next time you access the Website. We strive to serve cookies or allow the serving of cookies with the minimum reasonable lifespan possible.
On top of cookies, other tracking technologies are used on the Website. These include tracking pixels, software libraries that send your activity to our servers and tracking URLs. These technologies can be used to retrieve information from your device, such as device type, screen size, operating system, IP address, and time of visit. These can serve and read cookies in your browser. Tracking pixels are tiny transparent images that help us confirm when you visit a given page. Software libraries help us understand the actions, if any, you have taken on a page, for example to understand if you are “present” to receive a video call, or if a message is best delivered as a pop up in the browser or as a follow up SMS.
Why Homestay.com Uses These Technologies
Below outlines our use of different types of cookies:
1. Necessary Functionality and Session Cookies
We use session cookies to remember when you are logged in, so we don’t need to ask you to sign in for every page you visit. We also implement functionality cookies to remember your preferences and to help you to use the Website and apps efficiently and effectively. If you are using the Website or apps to search for a homestay, these functionality cookies remember your preferred currency and language, and if you have already seen and dismissed information popups and dialogs.
Lastly, we use technical cookies to optimize delivery of pages through our content distribution network and to enable libraries for live chat, instant messaging and video calls.
All of the above are “first party cookies” and are essential for the Website to function correctly and therefore are always enabled.
A minimal amount of “third party cookies” are required for important features of the Website, such as live chat to support our customers. These can be turned off in your browser settings if required.
2. Performance / Analytics Cookies
We use these cookies to gain insight into how visitors use the Website. This helps us understand what works and what doesn't, allowing us to optimize and improve the Website and apps. The data we gather can include which of the Website pages you have visited, which referring/exit pages you have entered and left from and which emails you opened. We use analytics cookies as part of our digital marketing campaigns to learn how users interact with the Website or apps.
These are “first party cookies”, required by us to maintain our level of service and therefore are always enabled.
3. Optional And Third Party Cookies
"Add This" is a button which allows the sharing of Website pages on social networks. Add This also sets cookies which track the usage of the service and may be used to deliver advertisements which are of interest to you.
Google Advertising & Conversion:
We use third-party cookies to display relevant advertisements on the Website and on other websites. This is called “remarketing,” and it is based on your browsing activities. Remarketing cookies expire after 30 days and are not used for personal identification. For more information on Google Remarketing, please see here.
To measure return on investment with Google AdWords, we use the AdWords conversion tracking cookie. Google uses a different cookie for each Google AdWords customer and there is no consolidation of the cookie data with other data. If you click on one of our Ads and proceed to a page including a conversion tag, and the cookie has not yet expired, the conversion is recorded.
Facebook Advertising Conversion:
We also use the Facebook Pixel for measuring conversions from our advertising and remarketing campaigns on Facebook. This pixel allows us to understand and deliver ads and make them more relevant to you. The collected data remains anonymous and we cannot see the personal data of any individual user. The collected data is saved and processed by Facebook. See Facebook’s Data Use Statement: https://www.facebook.com/about/privacy.
How to Control your Cookie Settings
Even though most browsers automatically accept cookies, you can still modify your browser settings to decline cookies. Click on the Help portion of your browser’s toolbar for detailed instructions. Your mobile device may allow you to control cookies through the browser settings.
You can instruct us not to use libraries that use third party cookies by visiting https://www.homestay.com/cookie_settings. Please note that to prevent collection of third party cookies you need to visit the third party website settings or configure your browser settings accordingly.
If you do choose to disable cookies altogether, some parts of the Website may not work as intended or may not work at all.
Website visitors have the ability to prevent their data from being used by Google Analytics by installing the Google Analytics Opt-Out Browser.
Manage your Add This settings here
To customize Google display network ads, visit the Google Ads Settings page. To learn about behavioural targeting and advertising cookies visit this site which includes instructions on how to opt out.
Need further information?
Messaging System, Moderation and Management
Property Registration Details
For some jurisdictions it may be a requirement for us to register property license numbers or ID’s, in instances where homestays are specifically required to hold a license by law in order to list on the Website. In these instances, we may be required to share information of the homestay with the relevant authority, such as the Host’s full name and contact details, the accommodation address, tax identification number, listing details, and number of nights booked.
Disclosure of Information to Third Parties
We may provide non-personal data to third parties, where such information is combined with similar information of other users of the Website. For example, we might inform third parties about the number of unique users who visit the Website, the demographic breakdown of users of the Website or the activities in which visitors to the Website engage while on the Website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties. We will not disclose your personal data to third parties unless you have consented to this disclosure or unless such disclosure is required to fulfill your order (in such circumstances, any such third party will be bound by similar data protection requirements). We will disclose your personal data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order or other statutory requirement.
Business transfer of Data
In the event of a sale, merger, acquisition, liquidation, receivership or transfer of all or substantially all of the assets of Homestay Technologies Limited, we reserve the right to transfer information (including your personal data) to the acquiring party or legal successor. In this event, we will notify you before your personal data is transferred and becomes subject to a different privacy statement.
Updating, Verifying and Deleting Personal Data
Your information may be accessed and kept up to date via your user account. For information you cannot access via your user account, you also have a right to request it to be corrected, if inaccurate, or erased. Please forward any such requests by email to firstname.lastname@example.org. You are responsible for keeping your personal information up to date.
Right of Access to Your Personal Data
To find out what personal data we hold on you or to have your personal data updated, amended or removed from our database, please contact email@example.com.
Right to Opt Out of Direct Marketing / Manage your Consent
You can withdraw your consent to the processing of your personal information at any time via your user account settings or by requesting to opt out via email to firstname.lastname@example.org.
Changes to the Privacy Statement
Any changes to this Privacy Statement will be posted on the Website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal data in a manner significantly different from that stated in this Privacy Statement, or as otherwise disclosed to you at the time it was collected, we will notify you by email and you will have a choice as to whether or not we use your information in the new manner. Should you disagree with any changes or modifications to the privacy statement, you may cancel your user account. However should you continue to use the services following this notification you will be bound by the new privacy terms.
Governing Law and Jurisdiction
This Privacy Statement is governed by the laws of Ireland and is subject to the exclusive jurisdiction of the Irish courts. You have the right to file a complaint with the Irish Data Protection Commissioner in relation to how your data is being processed.
Exclusion of Liability
Homestay Technologies Limited and its subsidiaries, affiliates, officers, agents and employees, from and against any claim, liabilities, damages, losses and/or expenses, including, without limitation, reasonable legal and accounting fees, arising out of or in any way connected with: (i) any claims made by Customers; (ii) the provision of accommodation by a Host; and (iii) the Partner’s use of the Site and/or the Services, arising out of or in connection with the use of any personal information relating to you in accordance with this privacy statement and your consent.
Questions or Comments
If you wish to contact us to discuss any matter in relation to this Privacy Statement or our processing of your personal data, please feel free to contact us by email at email@example.com.