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.