Privacy Policy

HOUSE PARTIES PRIVACY POLICY – JULY 2020

A. THE PURPOSE OF THIS PRIVACY POLICY
The purpose of this policy statement is to inform you of the policies that have been put in place to protect your privacy interests: to inform you of the types of information we collect, how we collect it, why we collect it, who we share it with, the legal basis for collecting it and your rights. We promise to keep your personal data safe and private, not to sell your personal data, and to give you a simple way to understand how and why we use your data and how you can contact us to amend, access or request that your data be deleted.

B. WHO WE ARE

House Parties, its website and management are operated by House Parties Limited, a private limited company registered in England and Wales. Our company registration number is 02601372. Our registered office is 2 Suffolk Court, Suffolk Place, Cheltenham, Gloucestershire GL50 2QG. We are registered with the Information Commissioner’s Office as a Data Controller under ICO Number Z1208726. For more information on the ICO visit their website at www.ico.org
This Privacy Policy sets out how we collect, process and protect any information (including personal data) that you give when you use this website, or communicate with us in any way.
Use of this website is in accordance with our Terms of Use. By using our website, you indicate that you agree to our Terms of Use and this Privacy Policy. We may change this Privacy Policy from time to time by updating this page. Any changes will be effective immediately upon notice which we may give by any means, including updating this page. You should revisit this page regularly to stay informed of updates. You must be over 18 years old to use our site and to make booking enquiries with Owners. If you do not agree with this policy please do not use this website.

C. TERMINOLOGY

When this Privacy Policy mentions “House Parties,” “we,” “us,” “our,” or “data controller” it refers to House Parties Limited. When referring to the “customer” “client”, “you”, “yours” we refer to users of our House Parties website, services, booking portal and all forms of communication and data exchange with House Parties Limited, its officers, management and staff. “Data” refers to personal data including not only data that is commonly considered to be personal in nature (e.g. names, physical addresses, email addresses), but also data such as IP addresses, behavioural data, geolocation data, financial information, and more. If you have any questions about your personal data and this Privacy Policy you can contact us for more information any time by emailing enquiries@house-parties.com or phoning 01242 285755.

This Privacy Policy applies to all users of our website and service, including property Owners or agents who advertise with us “Owners”, website users who have registered for an account “web users” and website visitors who have not registered for an account but visit our website “visitors”.

D. THIS POLICY AND THE GDPR

GDPR stands for the General Data Protection Regulation, a European privacy law approved by the European Commission which came into force on 25 May 2018.
GDPR Regulations have replaced previous data protection legislation regulations across Europe. House Parties is registered with the Information Commissioner Office (ICO) and compliant with GDPR Regulations 2018. 

The GDPR is an attempt to strengthen, harmonize, and modernize EU data protection law and enhance individual rights and freedoms, consistent with the European understanding of privacy as a fundamental human right. The GDPR regulates, among other things, how individuals and organizations may obtain, use, store, and eliminate personal data. It applies to any organisation processing personal data of EU citizens. The UK is due to exit the EU under Brexit in 2020/2021; however, the UK will continue to comply with these regulations to cover the transfer period and to uphold the extraterritorial reach of GDPR afterwards, in order to do business within the EU.

E. INFORMATION WE COLLECT

We will only collect, record, process and store data which we legitimately need, to ensure we provide the best possible service to our web visitors, users, property owners, customers and service providers.
There are three categories of information we collect:
1. Essential information you give to us.
(a) Information necessary for use of the website required for the performance of our contract with you:
i) Account information – registration details such as first name, last name and email address.
ii) Listing information (if you are an Owner) – such as your address, phone number, your property address and geo-location.
iii) Payment Information – Payments are processed using our account Third Party Processors (TPPs) on their secure platforms and will include the method, date and time, amount, card expiry date, billing postcode, your address and other related information. Payment information is processed securely by us and/or our TPPs who are audited and certified as PCI (Payment Card Industry) Service Provider Members. 
iv) Communications – if you contact us or make use of any messaging service between us and third parties (eg. Property Owners) we may collect the information you choose to provide in that communication.
(b) Non-essential information you choose to give us. You can choose to give us additional information that is not essential for use of the site but will enhance your experience and help us provide a better service to you: 
i) Examples of this are usernames such via Facebook, Instagram and Twitter and other platforms and website.
ii) Review information – If you submit a review on the House Parties website, we will collect this information and any personal data you may include in the review and this may be publicly available on the website.
iii) Other information – If you fill out any form on our website or a third-party site, we may direct you to such as SurveyMonkey, you are choosing to give us this information.

2. Information we automatically collect from your use of our website.
When you use our website, we automatically collect information, including personal data. This information is necessary for the performance of any contract, where applicable, between you and us, with legitimate interest to improve the functionality of the site and provide you with a good service.

(a) Site Usage Information – We collect information about pages you visit, the searches and enquiries you make as well as other actions.
(b) Geolocation information – We collect information that includes your IP address and this can be used to determine your approximate location.
(c) Log data and device information – We collect log data and device information when you use the site, even if you are not logged in or registered for an account with us. This information is vital to us to prevent fraudulent or malicious use of the site.
(d) Cookies – Cookies are small pieces of digital information a website sends to your computer for record-keeping purposes, stored in a file on your computer. They make web surfing easier by saving preferences. We never save passwords or credit card information in cookies. The use of cookies is an industry-standard and you will find that you experience pop-up cookie userboxes for most major websites you visit. You always have the option to not allow any website to store cookies on your website but you will experience a less interactive/bespoke service. We use cookies and similar tracking technologies on our website and in our emails, to analyse trends and movements around the site, serve targeted advertisements, gather demographic information about our user base as a whole, and to tell us when emails we send have been delivered or viewed, and links in them clicked. We may also partner with Third Parties and TPPs to display advertising on our website, or to manage and serve our advertising on other sites or provide secure processing to enable us to fulfil our contracts with clients and customers. These third parties may use cookies or similar tracking technologies in order to provide you advertising or other content based upon your browsing activities and interests. If you wish to opt-out of interest-based advertising click http://www.youronlinechoices.eu/ . 
(e) Payment information for customers and property owners. We collect information related to your payments for services. This information is required and necessary for the performance of any contracts with you. Card payments are processed securely by our service providers and will include the method, date and time, amount, card expiry date, card number, CVV code and billing postcode, name, address, bank (such as IBAN) and other information. 

3. Information we collect from third parties.
We may collect personal data that other site users may submit to us when they use the website and communicate with us, or we may obtain information from other third parties as detailed below. We have no control how these third parties may themselves control or process this information and any information request relating to the data they might provide to us must be directed to that third party.

(a) Third parties – if you login or connect to us using Facebook, they may send us information such as your registration and profile information. This information is controlled by Facebook and you authorise its processing by us when you connect using their service and via the privacy settings in your Facebook account.
(b) Property Reviews on third-party sites – (this applies to those writing reviews as well as property owners). An online review about a property on a third party site may contain some personal information. If someone has written a review about your property on a third party site, or you have written a review on a website that also lists a property listed on our website, it may contain your personal data as you have agreed with that third party website. House Parties has no control over the data on such third party sites, and you must contact the third party website owner for any changes or deletions.

F. HOW WE USE THIS INFORMATION

We may use and disclose personal data only for the following purposes:

1. To communicate with Web Users and Owners and provide customer support.
2. To send information and promotional material to you by email. You will only receive this information if you have positively opted in and you can stop receiving this content at any time.
3. To send you alerts and notifications by email based on transactions you make on the site – such as making an enquiry or leaving a review. 
4. To charge and collect money from our customers. This includes sending you notices and alerts by email or telephoning. We use third parties for secure card payment processing, and we send billing information to them for processing orders and payments. We use industry-standard third party accounting systems to manage our financial accounts.
5. To provide, support and improve the website and service to you. This may include sharing your personal data with third-party service providers to support and enhance our service. We ensure your data is protected by ensuring all third parties we may use have entered into a contract to only use your data as is necessary and in a manner that is consistent with this Privacy Policy.
6. To provide suggestions to you. We use data to suggest properties or other content that we think will be of interest to you. For example, suggesting properties similar to those you may have made an enquiry at.
7. To enforce compliance with our Terms of Use and applicable law. This includes storing server log data that help us prevent site misuse and violation.
8. To protect the rights and safety of our customers, site visitors and third parties.
9. To meet legal requirements, comply with the law, court orders, respond to legal requests or an official investigation.
10. To provide information to our advisors or agents, such as lawyers and accountants.
11. We may share your data with a third party if we choose to sell, transfer or merge part or all of our business, or if we seek to acquire another business or merge with them. We will only share your data with a third party in this case if they comply with GDPR Regulations and guarantee to keep your data safe and private and have the appropriate safeguards in place compliant with the Office of the Information Commissioner. https://ico.org.uk/

G. THIRD-PARTY LINKS

House Parties includes links to third party websites including social media sites such as Facebook, Instagram, LinkedIn, Pinterest and Twitter. We do not control these sites and when you visit them you may be providing personal data. The third party’s use of your information will be governed by their own Privacy Policy which we recommended you review. We do not accept any responsibility or liability for their policies whatsoever.

H. WHO WE MAY SHARE YOUR DATA WITH 

1. Other Site Users.
(a) Making an Enquiry- If you interact with the site to make a booking enquiry directly with us or with a property owner or agent, we may need to share with that owner/agent any information you need to provide such as your name, your email address, dates of your proposed stay, how many people are in your group. This is necessary for the adequate performance of our contract with you or your contract with the property owner. 
(b) Leaving a review – If you choose to leave a review on our website for a property you have stayed at, we may publish this information on the site and it will be visible to all site users and the general public. We will publish your “public name” which is your name as provided to us on registration or a pseudonym if you choose to change it (your “public name”). We will also publish the star rating and any other information you choose to provide. By leaving a review you acknowledge and agree that this information is provided and may be published with you consent.
(c) Uploading Property Information – If you are a property owner or agent, your use of the site is governed by House Parties Owner Terms, to which you must agree in order to use our service to promote your property. Any information you choose to provide to be uploaded to the Owners Area may include your personal data and may be provided to the Web Users and the general public as displayed on your property listing with your consent. You always have the opportunity to review the listing and can request changes by contacting House Parties directly.
(d) Responding to an Enquiry – If you are a property owner or agent, if you respond to an enquiry from a web user via our website, any information you submit (including personal data you choose to submit) will be provided to the enquirer and will be stored on our platform for review by that web user at any time. This information is provided by you with your consent.

2. Our Employees and Contractors.
Your data will be shared with our employees, contractors and agents who all enable us to provide the service. We need to share this information in order to ensure the adequate performance of our contract with you. Such recipients will have entered into a contract to keep your data safe and private and in a manner that is consistent with this Privacy Policy.

3. Third-Party Processors.
We use a variety of TTPs to help us provide and support our services. We need to share information with them in order to ensure the adequate performance of our contract with you. These TTPs would be classed as “data processors” under GDPR. Examples include payment processors, hosting providers, email delivery systems, software providers and site usage analysis services. All TPPs we use enter into a contract that requires them to use your personal data only for the provision of services to us and in a manner that is consistent with this Privacy Policy. TPPs we use at present include amongst others: Mailchimp, Google Analytics, Supercontrol, Stripe and Barclaycard. We use TPPs for many purposes including taking payments, to better understand our website users and visitors (for example how long people stay on a particular page and what they like). This enables us to take that feedback and improve our website and services. We will only share your data with a third party if they agree to keep your data safe, and comply with the Information Commissioners Office regulations.

I. TRANSFERS TO THIRD PARTY PROCESSORS (TPPs) OUTSIDE THE EU

We are a UK registered company, operating in the UK and our website and service is available to anyone worldwide. We use a number of TPPs to enable us to provide and support the website and service to our Property Owners, website users and website visitors. Some of these TPPs are based outside the European Economic Area (EEA) and data is processed on servers located outside the EEA. These TPPs have limited access to your information, and perform processes on our behalf. We only use TPPs who we are confident have the appropriate safeguards in place and they are contractually bound to protect and use it only for the purposes for which it was transferred, consistent with this Privacy Policy.

Examples of TPPs we use hosted outside the EU include (but are not limited to) website hosting companies, Mailchimp and SaaS (software as a service) (eg. Stripe).
www.privacyshield.gov The EU-US Privacy Shield is a framework that protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. Our TPPs are certified and comply with the EU-US-Swiss Privacy Shield Framework. Where appropriate we agree Data Processing Addendums with TPPs to be confident that any data from the EEA that is being transferred outside of the EEA will be subject to the same high levels of security, privacy control, and data protection that it would receive in the EU.

J. YOUR RIGHTS

The GDPR provides the following rights for individuals:

1. Right to be informed.
You have the right to be informed about the collection and use of personal data. This Privacy Policy should contain all the information you need for you to exercise this right. Should you wish to have access to all or part of your data please contact us at digitally at enquiries@house-parties.com, in writing to House Parties, 2 Suffolk Court, Suffolk Place, Cheltenham, Gloucestershire GL50 2QG or by phone on 01242 285755. Such access will be granted in accordance with GDPR, free of charge and will be supplied to you within 28 days. The ICO provides full information on your rights of access to any information House Parties holds on you. Our website systems undergo continuous upgrading; you may have access and the ability to update some of your personal data through your account settings.

2. Right to rectification.
You have the right to ask us to have inaccurate personal data rectified, or completed if it is incomplete, where you cannot do this yourself.
3. Right to erasure.
You have a right to have your personal data erased. This is also known as the “right to be forgotten”. You can ask us to delete your data by emailing us at
enquiries@house-parties.com. We may ask for proof of identity and will respond to a request for erasure within one month.
4. Right to restrict processing.
In certain circumstances, you have a right to restrict the way we may process your personal data, as an alternative to erasing it, if you have a particular reason for wanting it restricted
5. Right to data portability.
Your right to data portability entitles you to obtain personal data you have provided to us – in a commonly used, structured format – and request that we send it to another service provider if technically possible.
6. Right to object or withdraw consent.
You have the right to object to our processing of your personal data where the use is based on our legitimate interests (including profiling), or where it is used for direct marketing. You may at any time ask us to stop the processing of your information for direct marketing purposes, by emailing us at enquiries@house-parties.com or by changing the email preference settings in your account/s.

K. HOW LONG WE MAY KEEP YOUR DATA

We generally retain your information for as long as your account is active or as long as necessary to provide you with our service and/or to meet legal and regulatory requirements. This varies according to the type of relationship we have with you. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements. Where data are no longer required, we will ensure that they are disposed of in a secure manner.

L. SENSITIVE DATA

We will not normally seek data on your racial or ethnic origins, sexual orientation, gender or political opinions, disability, religious or other beliefs, trade union membership, physical or mental health, disability, sex life or criminal convictions. When we do collect sensitive data, it will be limited to data which are required to be kept by law: needed for legal proceedings or to establish, exercise or defend legal rights (including protection against fraud), and/or clearly and strictly necessary to fulfil a contract between you and us or between you and a third party who requires this information.

M. SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

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