PrivacyPolicy - CAMPINN

Last updated 28/5/18

 

CampInn Privacy Policy

 

CampInn offers online travel-related services through our own websites and mobile apps, as well as through other online platforms such as partners’ websites and social media. All the information in this Privacy Policy applies to all of these platforms.

The Privacy Policy applies to any kind of information we collect through these platforms or other means connected to these platforms (such as contacting our customer service team via email, phone or other).

 

The Privacy Policy may be amended from time to time and the last version will have the date it was updated. If you care about your privacy, visit this page regularly and you’ll know exactly where you stand. If we make changes to the Privacy Statement which will have an impact on you we will notify you of these changes before the new activities begin.

 

We value your privacy and should you disagree with the Privacy Policy we will be sad, but you should discontinue using our services. If you agree with our Privacy Policy we welcome you to make your next CampInn “Simplified Journey to Nature”!

 

 

1.     DEFINITIONS

 

1.1.  “Agreement” means the T&C and that you are using and/or visiting the Platform and you agree to these T&C and the Privacy Policy (the “T&C”), and you expressly consent and agree to be bound by the T&C and all applicable laws and regulations that govern the Platform and your booking

1.2.  "CampInn", "us", "we" or "our" means CampInn Limited, company number 11402183, a limited liability company incorporated under the laws of the United Kingdom.

1.3.  "Platform" means the (mobile) website and app on which the Service is made available owned, controlled, managed, maintained and/or hosted by CampInn.

1.4.  "Product" means the various different travel products and services that can be ordered, acquired, procured, purchased, bought, paid, rented, provided, reserved, combined or consummated by you from the Host and the method of payment and payment process.

1.5.  "Provider" means the professional provider or certain third party Host of a legal travel or travel related product or service who offer Products, as defined hereinafter as from time to time available for Reservation on the Platform (whether B2B or B2C).

1.6.  "Service" means the online purchase, order, (facilitated) payment or reservation service as offered or enabled by CampInn in respect of various products and services as from time to time made available by Host(s) on the Platform.

1.7.  “Members” mean registration of users of the Platform who order, acquire, procure, purchase, buy, pay, rent, consumer, reserve, combined or consummated of a Product(s) from Host(s).

1.8.  "Reservation" means the order, purchase, payment, booking or reservation of a Product on the Platform which has been confirmed on the Platform.

1.9.  “Listing” means a publication of availability of a Product(s).

 

2.     INFORMATION WE COLLECT

 

2.1.  Information necessary for the use of the Platform.

We ask for and collect the following personal information about you when you use the 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.

1.1.1.    Account
To sign up for an account on the Platform, we require certain information such as your first name, last name, email address, and date of birth.

1.1.2.    Profile and Listing Information

To use certain features of the Platform and Reservations we may ask you to provide additional information, which may include your address, phone number, and a profile picture.

1.1.3.    Identity Verification Information

To help create and maintain a trusted environment, we may collect identity verification information in form of official documentation or other authentication information.

1.1.4.    Payment Information

To use certain features of the Platform and facilitate Reservations or publish a Product, we may require you to provide certain financial information to be able and charge and collect payment methods.

1.1.5.    Communications with CampInn and other Members

When you communicate with CampInn or use the Platform to communicate with other Members or Hosts, we collect information about your communication and any information you choose to provide.

 

2.2.  Voluntary information for a better CampInn experience

Additional personal information may significantly improve your experience on the Platform. This additional information will be processed based on your consent.

1.1.6.    Additional Information

You may choose to provide additional information as part of your CampInn profile which isn’t mandatory and will be public on the Platform for your Reservations or publicizing your Product.

1.1.7.    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 Platform.

1.1.8.    Other Information

You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your CampInn Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Platform.

 

2.3.  Information that is necessary for making payment or receiving payments

The Payments Data Controller needs to collect the following information, as it is 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:

1.1.9.    Payment Information

To make payments CampInn and the Platform do not collect any data and we use Stripe services. We suggest you look at their Global Privacy Policy — Worldwide

1.1.10. Identity Verification and Other Information

If you are a Host Stripe or CampInn may require identity verification information 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.

 

3.     INFORMATION WE AUTOMATICALLY COLLECT FROM YOUR USE OF THE PLATFORM AND PAYMENT SERVICES

 

When you use the Platform, we automatically collect information, including 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 Platform.

 

3.1.  Geo-location Information

When you use certain features of the 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. CampInn may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

3.2.  Usage Information

We collect information about your interactions with the Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Platform.

3.3.  Log Data and Device Information

We automatically collect log data and device information when you access and use the Platform, even if you have not created an CampInn account or logged in. That information includes, among other things: details about how you’ve used the Platform, 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 Platform.

3.4.  Cookies and Similar Technologies

We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, the Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookie Policy.  

3.5.  Payment Transaction Information

CampInn, Stripe and other payment platforms may collect information related to your payment transactions through the Stripe, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and CampInn and to allow the provision of the payments.

 

4.     INFORMATION WE COLLECT FROM THIRD PARTIES

 

CampInn and any payment platform may collect information, including personal information, that others provide about you when they use the Platform and any payment service, or obtain information from other sources and combine that with information we collect through the Platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

 

5.     HOW WE USE INFORMATION WE COLLECT

 

5.1.  We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
We process this information given our legitimate interest in improving the Platform and our Members’ and Hosts’ experience with it, and where it is necessary for the adequate performance of the contract with you.

5.2.  Create and Maintain a Trusted and Safer Environment.

5.2.1.    We observe reasonable procedures to prevent unauthorised access to, and the misuse of, personal data.

5.2.2.    We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

5.2.3.    We will retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you (including maintaining the online user account (if created)), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us via the contact details provided below.

5.2.4.    We process this information given our legitimate interest in protecting the Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

5.3.  PROVIDE, PERSONALIZE, MEASURE, AND IMPROVE OUR ADVERTISING AND MARKETING

5.3.1.    Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about CampInn or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).

5.3.2.    Personalize, measure, and improve our advertising.

5.3.3.    Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by CampInn or its third party partners.

5.3.4.    Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the 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.

You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your CampInn Account.

 

6.     CERTAIN CIRCUMSTANCES OF SHARING YOUR INFORMATION WITH THIRD PARTIES

 

6.1.       In order to complete your Reservation, we transfer relevant Reservation details to the Host you have booked. Depending on the Reservation and the Host, this can include your name, contact details, payment details, the names of the Members travelling with you and any preferences or other information you specified when you made your Reservation. If you have a query about your Reservation, we may contact the Host and ask them to handle your request. Unless payment is made during the book process via the Platform, we may forward your credit card details to the booked Host for further handling. In cases of reservation-related disputes, we may provide the Host with information about the reservation process as needed to handle the dispute. This may include a copy of your reservation confirmation as proof that a Reservation was actually made.

6.2.       In order to support the use of the CampInn services, your details may be shared with subsidiaries and affiliates of CampInn which act as service providers for CampInn, including in relation to customer support services.

6.3.       We use service providers to process your personal data on our behalf. This processing is for several purposes, including sending out marketing material or validating the correctness of the email address you provided during the booking process or completing the payment processes required including the deposit process. Third party service providers are bound by confidentiality clauses and are not allowed to use your personal data for other purposes than instructed by CampInn.

6.4.       Payment providers and (other) financial institutions: When a chargeback is requested for your Reservation by either you or by the holder of the credit card used to make your reservation, we need to share certain reservation details with the payment service provider and the relevant financial institution to handle the chargeback. This may also include a copy of your reservation confirmation or the IP address used to make your reservation. We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

6.5.       We disclose personal data to law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud or if we are otherwise legally obliged to do so. We may need to further disclose personal data to competent authorities to protect and defend our rights or properties, or the rights and properties of our business partners.
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 Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

6.6.       We work with many business partners around the world. These business partners distribute or advertise the CampInn services, including the services and products of our Hosts.

6.7.       When you make a reservation on one of our business partners’ websites or apps, certain personal data that you give them such as your name and email address, your address, payment details and other relevant information, will be forwarded to us to finalize and administer your Reservation. If customer service is provided by the business partner, CampInn will share details relevant to your reservation with the business partners (as and when needed) in order to provide you with appropriate and efficient support. When you make a reservation through one of our business partners’ websites, the business partners can receive certain parts of your personal data related to the specific reservation such as your name and email address. This is for their own internal purposes (such as analytical purposes) and, if requested by you, for the administration of loyalty programs or marketing.

6.8.       When you make a reservation on a business partners’ website, please also take the time to read their privacy notice if you wish to understand how these business partners may process your personal data. For fraud detection and prevention purposes and as strictly necessary, we may also exchange information about our users with business partners.

6.9.       As part of the Reservation process, we will be required to share some of your personal data that is relevant for the reservation with this business partner.

6.10.    We share personal data with advertising partners, including your email address, as part of marketing the CampInn services via third parties (to ensure that relevant advertisements are shown to the right audience). We strive to only share email addresses in hashed form to enable the matching of your email address with an existing customer database so that your email address cannot be used for other purposes.

6.11.    The transmission of personal data as described in this Privacy Policy may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. Where required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements using the contact details below.

6.12.    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 CampInn account or when you participate in promotional activities conducted by CampInn partners or third parties.

6.13.    We don’t share your billing and payout information with other than the Hosts and the payment process vendor.

6.14.    After completing a booking, Members and Hosts may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Platform.

6.15.    Hosts may need to use third party services available through the Platform to assist with managing their Products or providing additional services requested by you, such as cleaning services or lock providers. Hosts may use features on the Platform to share information about the Member (like check-in and check-out dates, Member name, Member phone number) with such third party service providers for the purposes of coordinating the stay, managing the Accommodation, or providing other services.

6.16.    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 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.

6.17.    The social media platforms with which we may share your personal data are not controlled or supervised by CampInn. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

6.18.    If CampInn undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence).

6.19.    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, demographic profiling, marketing and advertising, and other business purposes.

 

7.     GOOGLE MAPS/EARTH

 

Parts of the Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

 

8.     THIRD PARTY PARTNERS & INTEGRATIONS

 

The 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”). CampInn 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, CampInn, 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.

 

9.     YOUR RIGHTS

 

You may exercise any of the rights described in this section before your applicable to CampInn by sending an email to support@campinn.com. Please note that we may ask you to verify your identity before taking further action on your request.

 

10.  MANAGING YOUR INFORMATION

 

You may access and update some of your information through your profile settings. You are responsible for keeping your personal information up-to-date.

 

11.  RECTIFICATION OF INACCURATE OR INCOMPLETE INFORMATION

 

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your the Platform).

 

12.  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).

 

13.  DATA RETENTION AND ERASURE

 

13.1.    We observe reasonable procedures to prevent unauthorised access to, and the misuse of, personal data.

13.2.    We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on our servers. Only authorized personnel are permitted to access personal data in the course of their work.

13.3.    We will retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you (including maintaining the online user account (if created)), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Statement. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us via support@campinn.com.

 

14.  WITHDRAWING CONSENT AND RESTRICTION OF PROCESSING

 

Where you have provided your consent to the processing of your personal information by CampInn you may withdraw your consent at any time by changing your Account settings or by sending a communication to CampInn 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 CampInn override your own.

 

15.  OBJECTION TO PROCESSING

 

In some jurisdictions, applicable law may entitle you to require CampInn and CampInn Payments 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 CampInn and/or CampInn Payments 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.

Where your personal information is processed for direct marketing purposes, you may, at any time ask CampInn to cease processing your data for these direct marketing purposes by sending an e-mail to support@campinn.com.

 

16.  SECURITY

 

We 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 CampInn account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your CampInn account, please contact via support@campinn.com.

 

17.  CHANGES TO THIS PRIVACY POLICY

 

CampInn reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Platform will be subject to the revised Privacy Policy.