Last Updated: January 1, 2015
“Aggregated information" means information about all of our users or specific groups or categories of users that we combine together and which does not include the users’ Personal Information.
"Data Controller" means Cribkeys, the company responsible for the use of and processing of Personal Information.
"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
WHAT TYPES OF INFORMATION DOES CRIBKEYS GATHER ABOUT ITS USERS?
1. Information that you give us We receive, store and process information that you make available to us when accessing or using our Platform. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account;
- access or use the Platform, such as to search for or post Accommodations, make or accept bookings, pay for Accommodations, book or pay for any associated services that may be available (such as but not limited to cleaning), post comments or reviews, or communicate with other users;
- link your account on a third party site (e.g. Facebook) to your Cribkeys account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; and
- communicate with Cribkeys.
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
3. Log Data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Cribkeys or logged in to your Cribkeys account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
4. Cookies, and other Tracking Technologies
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Cribkeys services on third party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.
1. to enable you to access and use the Platform;
2. to operate, protect, improve and optimize the Platform, Cribkeys’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;
3. to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
4. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
5. where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information sent on behalf of our business partners that we think you may find interesting. You will be able to unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Cribkeys account;
6. to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Cribkeys or our business partners; and
7. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
HOW CRIBKEYS USES AND PROCESSES USER COMMUNICATIONSWe may review, scan, or analyze your communications with other users exchanged via the 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, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings.
We will not review, scan, or analyze your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Cribkeys, in its sole discretion, may review, scan, analyze, and store your communications, whether done manually or through automated means.WHEN CRIBKEYS DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOMIMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countriesWe may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area ("EEA") including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.If you are located in the EEA or in Switzerland, please also see our Safe Harbor Notice (http://wwwcribkeys.uk/safe_harber_notice).Your Personal Information may be disclosed as follows:
1. Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes.2. Your public Listing page will always include some minimum information such as the city and neighborhood where the Accommodation is located, your public profile photo and your responsiveness in replying to Guests’ queries. Parts of your public Listing page may be displayed in other parts of the Platform to other users for marketing purposes. The Platform may also display the Accommodation’s approximate geographic location on a map, such that a user can see the general area of the Accommodation.3. The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.4. When you submit a request to book an Accommodation, your full name will become visible to the Host. In addition, if you agree to be contacted by the Host by phone when submitting your request and the Host decides to do so, Cribkeys will call your phone number first, before connecting you with the Host. We will not share your phone number unless there is a confirmed booking.5. When your request to book an Accommodation is accepted by the Host or when you accept a Guest’s request to book your Accommodation, we will disclose some of your Personal Information to the Host or Guest. However, your billing information will never be shared with another user.6. When a Guest stays at your Accommodation or when you stay at a Host’s Accommodation, we will ask you to review the Guest or the Accommodation. If you choose to provide a review, your review may be public on the Platform.7. You may link your account on a third party social networking site to your Cribkeys account. We refer to a person’s contacts on these third party sites as “Friends”. When you create this linkage:
o some of the information you provide to us from the linking of your accounts may be published on your Cribkeys account profile; your activities on the Platform may be displayed to your Friends on the Platform and/or that third party site; other Cribkeys users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable; other Cribkeys users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking site(s); and the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes.
The publication and display of information that you provide to Cribkeys through this linkage is subject to your settings and authorizations on the Platform and the third party site.
8. We may distribute parts of the Platform (including your Listing) for display on sites operated by Cribkeys’s business partners, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
10. We may also engage third party companies and individuals, who may be located outside of the EEA, to provide services to us, including services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed). We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
11. You acknowledge, consent and agree that Cribkeys may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against Cribkeys; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service, (http://wwwcribkeys.uk/terms) and the Host Guarantee Terms and Conditions (http://wwwcribkeys.uk/host_garantee); (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Cribkeys, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless prohibited by law or by the government request, or if doing so would be futile or ineffective.
We may also publish, disclose and use Aggregated Information and non-personal information for industry analysis, demographic profiling, marketing and advertising, and other business purposes.
BUSINESS TRANSFERS BY CRIBKEYS
HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR CRIBKEYS ACCOUNT
You may review, update, correct or delete the Personal Information in your Cribkeys account by logging in to your account. If you would like to cancel your Cribkeys account entirely, you can do so by logging in to your account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the
Platform in association with your first name, even after your Cribkeys account is cancelled.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Information against the unauthorized access, destruction or alteration of your information. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
SPECIAL FEATURES AND PROGRAMS
Referral service and requesting for references
The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your Cribkeys profile.We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Cribkeys does not collect or retain the contact information that is used to send them.You may also send invitation/request emails via the Platform itself, in which case we will ask you for the email addresses to send these emails to. You can type in the email addresses manually, or you can request Cribkeys to import the contacts in your email account address book(s). In both cases, we will use the information sent to us for the sole purpose of sending your friends and contacts a one-time email, inviting him or her to visit the Platform or to write a reference for you. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Cribkeys in response to your referral.If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.Affiliate ProgramIf you are allowed to join Cribkeys’s Affiliate Program (see http://wwwcribkeys.uk and you sign up for it, you will have to provide us with certain Personal Information to enable us to provide the Affiliate Program to you.MeetupsThe Platform may allow registered account holders to organize, search for or participate in offline events (“Meetups”) in selected cities.If you organize a Meetup or indicate that you will attend one, this information, together with some of your public information (such as your profile picture and public profile page) and any messages that you post about that Meetup, will be visible to users who browse the event. However, Cribkeys will never disclose where you are staying to another user.GroupsThe Platform may allow registered account holders to participate in online discussion forums ("Group(s)”) in selected cities.If you join a Group, then your membership in the Group as well as some of your public information (such as your profile picture and public profile page) will be visible to users who browse the Group. If you publish postings in a Group, then your postings will be visible to such users as well. The ability to browse the Group will depend on the Group settings, and it may or may not be limited to members of that Group.
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion.
1. to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.2. to simplify your access to and use of the Platform and make it more seamless.3. to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
4. to show you content (which may include advertisements) that is more relevant to you.