Effective date: April 16, 2020
In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered a C-A account, including Suppliers and Guests. A “Supplier” is someone who offers services (“Supplier Services”) via published listings on the C-A Platform (“Listings”). A “Guest” is someone who books or seeks to book Supplier Services. “Accommodation” means a vacation or other property. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the C-A Platform.
There are three general categories of information that we collect.
1.1. Information You Give Us
We collect the information you share with us when you use the C-A Platform to ensure the adequate performance of contracts between you and C-A, or between you and a Supplier. The provision of this information is necessary to use the C-A Platform and, without it, we will not be able to provide you with services that you request.
When you sign up for a C-A account or submit a request for Accommodation booking information, we require certain information such as your name and email address.
To use certain features within the C-A Platform, we may need to ask you to complete a profile, which may include your address and phone number.
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 travel-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 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 travel-related experiences with third parties.
When you communicate with C-A, we collect information about your communication and any information you choose to provide.
You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other Guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with a C-A representative, conduct a search, update or add information to your C-A account, respond to surveys, participate in promotions, or use other features of the C-A Platform.
1.2. Information We Automatically Collect from Your Use of the CA Platform
When you use the C-A Platform, we collect information about the services you use and how you use them, even if you don’t sign up for a C-A account. We process this information for the activities and legal bases described in Section 2 below.
We collect information about your interactions with the C-A Platform, such as the pages or other content you view, your searches for villas, bookings you have made, the experiences and activities you book with others through us, and other actions on the C-A Platform.
When you use certain features of the C-A Platform, 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 C-A Platform, even if you have not created a C-A account or logged in. That information includes, among other things: details about how you’ve used the C-A Platform (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 C-A Platform.
We collect information related to your transactions on the C-A Platform or transactions made through the C-A Platform, including the date and time, amounts charged, and other related transaction details.
1.3. Information We Collect from Third Parties
We may collect information that others provide about you when they use the C-A Platform, or obtain information from other sources and combine that with information we collect through the C-A Platform. C-A does not control, supervise or respond for how the third parties providing your information process with your data, and any information request regarding the disclosure of your personal information to C-A should be directed to such third parties.
If you link, connect, or log in to your C-A 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 authorized by you via your privacy settings at that service.
For certain Members in the United States, to the extent permitted by applicable laws, C-A 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, C-A 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 have 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 C-A Platform, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through C-A, 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 C-A Platform through partnerships, or about your experiences and interactions from our partner ad networks.
We use, store, and process information about you to provide, understand, improve, and develop the C-A Platform, and to create and maintain a trusted and safer environment.
2.1. Provide, Improve, and Develop the CA Platform
We process this information given our legitimate interest in improving the C-A Platform 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
We process this information given our legitimate interest in protecting the C-A Platform, 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
We process this information given our legitimate interest in protecting the C-A Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.1. With Your Consent or Were Authorized by Law
3.2. Sharing between Suppliers and Guests
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 C-A Platform publishes information that is visible to the general public. For example:
The information you share publicly on the C-A Platform 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 C-A Platform 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 have 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 available through the C-A Platform to assist with managing their Accommodation or providing additional services, such as cleaning services, insurance or activities providers. Suppliers may use features on the C-A Platform 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 to coordinate the stay, managing the accommodation, or delivering other services.
3.6. Safety and Compliance with Law
We will attempt to notify Members about these 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 C-A’s property, its Members and the C-A Platform (collectively, “Risk Scenarios”). 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 if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
3.7. Corporate Affiliates
To help us provide the C-A Platform, 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 C-A Platform and our affiliates’ services. Our affiliates include other C-Africa companies and Airbnb companies.
We may display parts of the C-A Platform (e.g., your Listing page) on sites operated by C-A’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 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.
4.1. Analyzing your Communications
We may review, scan, or analyze your communications on the C-A Platform 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 C-A’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 C-A account with your account at a third party social networking service. When you create this link:
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
The C-A Platform 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”). C-A 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 have 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.
6.1. Managing Your Information
You may access, update, and correct most of your basic personal information by logging into your C-A 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 C-A Platform to you, or for as long as your account is active. If you no longer want us to use your information to provide the C-A Platform to you, you may cancel your account or request us to erase your personal information. To cancel your C-A account, contact us. If you cancel your account or request erasure of your personal information, note that:
6.3 Withdrawing Consent
In some jurisdictions, applicable law may entitle you to withdraw consent you previously gave to C-A to process your information and to end your use of the C-A Platform by cancelling your account as described in this section. Additionally, you may have the right to limit how we use your personal information.
6.4 Data Portability
In some jurisdictions, applicable law may entitle you to request a copy of the personal information that you have provided to us and/or to request us to move such personal information to another service provider. In such cases, and 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 C-A is not holding accurate data about you) and in line with applicable law, you may request C-A to temporarily restrict our use of your personal information for a limited period 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 C-A 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 [email protected]. We may ask you to verify your identity before taking further action on your request. You have the right to lodge complaints about the data processing activities carried out by C-A before competent data protection authorities.
7.1 Service Providers
When you use the C-A Platform, you authorize us to transfer, store and process your information in such countries. Laws in these countries may differ from the laws applicable to the place where you live. By using the C-A Platform, you consent to transfer your data to these countries.
7.2 California Residents,
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
Effective date: April 16, 2020
A cookie is a small data file that is transferred to your device (e.g. your phone or your computer). For example, a cookie could allow us to recognize your browser, while another could store your preferences. There are two types of cookies used on the C-A Platform: (1) “session cookies” and (2) “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device after you close your browser, and can be used again the next time you access the C-A Platform.
Why C-A Uses These Technologies
We use these technologies for several purposes, such as:
We may also allow certain business partners to place these technologies on the C-A Platform. These partners use these technologies to (1) help us analyze how you use the C-A Platform, such as by noting the third-party services from which you arrived, (2) market and advertise CA services to you on the C-A Platform and third-party websites, (3) help us detect or prevent fraud or conduct risk assessments, or (4) collect information about your activities on the C-A Platform, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the C-A Platform, we work with several analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the C-A Platform and on other websites and online services. Targeting and advertising cookies we use may include Google, Facebook, Microsoft, Criteo, OpenX, Pubmatic, StackAdapt, AppNexus and other advertising networks and services we use from time to time. For more information about targeting and advertising cookies and how you can opt-out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt-out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into the C-A Platform and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.
Third-Party Social Plugins
The C-A Platform may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the C-A Platform. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the C-A Platform to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
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