Privacy Policy

Last Updated: May 27, 2020

1. INTRODUCTION


Thank you for using Airlou! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Airlou. We are committed to protecting all the personal information we collect and help ensure that personal information is handled properly worldwide.

This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Airlou Platform. This privacy policy describes our privacy practices for all websites, platforms and services that link to it. Please read the privacy policy on the applicable site.


1.1 Definitions


If you see an undefined term in this Privacy Policy (such as “Listing” or “Airlou Platform”), it has the same definition as in our Terms of Service (“Terms”).


1.2 Data Controller


When this policy mentions “Airlou,” “we,” “us,” or “our,” it refers to the “Airlou company that is responsible for your information under this Privacy Policy (the “Data Controller”).

2. INFORMATION WE COLLECT


There are three general categories of information we collect.


2.1 Information You Give to Us.


2.1.1 Information that is necessary for the use of the Airlou Platform.

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

Account Information. When you sign up for an Airlou Account, we require certain information such as your name and email address. To use certain features of the Airlou Platform (such as creating a Listing), we may ask you to provide additional information, which may require linking to your social media such as Instagram, Youtube, TikTok, Personal Blog/Website and a profile picture.


2.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using Airlou Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

Additional Profile Information. You may choose to provide additional information as part of your Airlou profile (such as a personal description, Instagram profile, Youtube channel, TikTok profile, Personal Blog/Website link and a profile picture). This information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.


2.1.3 Information We Automatically Collect from Your Use of the Airlou Platform.

When you use the Airlou Platform, we automatically collect 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 Airlou Platform.

Geo-location Information. When you use certain features of the Airlou 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. Airlou may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. Usage Information. We collect information about your interactions with the Airlou Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Airlou Platform.

Log Data and Device Information. We automatically collect log data and device information when you access and use the Airlou Platform, even if you have not created an Airlou Account or logged in. That information includes, among other things: details about how you’ve used the Airlou Platform (including if you clicked on 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 Airlou Platform.

Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information.


3. HOW WE USE INFORMATION WE COLLECT


We may use, store, and process personal information to (1) provide, understand, improve, and develop the Airlou Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Airlou Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.


3.1 Provide, Improve, and Develop the Airlou Platform. We may use the personal information to provide, improve, and develop the Airlou Platform such as to:


enable you to access and use the Airlou Platform,

enable you to communicate with other Members,

operate, protect, improve, and optimize the Airlou Platform and experience, such as by performing analytics and conducting research,

provide customer service,

send you service or support messages, updates, security alerts, and account notifications,

if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection,

to operate, protect, improve, and optimize the Airlou Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Host Guarantee, Host Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with the Airlou Platform, your search and booking history, your profile information and preferences, and other content you submit to the Airlou Platform, and

enable your use of our enterprise products.

We process this personal information for these purposes given our legitimate interest in improving the Airlou Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.


3.2 Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:


detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,

conduct security investigations and risk assessments,

verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide),

conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,

comply with our legal obligations,

Resolve any disputes with any of our Members and enforce our agreements with third parties,

enforce our Terms of Service and other policies, and

in connection with the activities above, we may conduct profiling based on your interactions with the Airlou Platform, your profile information and other content you submit to the Airlou Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Airlou Platform if such processes detect activity that we think poses a safety or other risk to the Airlou Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

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


Your Choices


You have choices on the promotional messages that you choose to receive.

You can limit the information you provide to Airlou. Participation in promotions and marketing programs is voluntary.

You can limit the communications that Airlou sends to you.

To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your Airlou Account.

To revoke permissions that you may have given to send promotional text messages, text STOP in response to any message.

You can always update your notification settings within your Airlou Account by visiting the Notifications section of your Airlou Account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.


4. SHARING & DISCLOSURE


4.1 Profiles, Listings, and other Public Information.


The Airlou Platform lets you publish information, including personal information, that is visible to the general public. For example:

Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others. Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share. After completing a booking, Guests 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 Airlou Platform (such as the Listing page). If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Airlou Platform, that content is publicly visible. Based on our legitimate interest to promote the Airlou Platform we may display parts of the Airlou Platform (e.g., your Listing page) on sites operated by Airlou’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

Information you share publicly on the Airlou Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.


4.2 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.


Airlou may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Airlou, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability (See more information on Airlou’s Law Enforcement Guidelines here), (iv) to enforce and administer our Terms of Service, or other agreements with Members, or (v) to protect the rights, property or personal safety of Airlou, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

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 Airlou Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Airlou’s property, its Members and the Airlou Platform. In instances where we comply with legal requests without notice for these reasons, we may attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.


5. YOUR RIGHTS


Consistent with applicable law, you may exercise any of the rights described in this section.


5.1 Rectification of Inaccurate or Incomplete Information.


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


5.2 Data Access and Portability.


In some jurisdictions, applicable law may entitle you to request certain 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).


5.3 Data Retention and Erasure.


We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely." Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Airlou Account for fraud or safety reasons, we may retain certain information from that Airlou Account to prevent that Member from opening a new Airlou Account in the future. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Airlou may keep some of your information for tax, legal reporting and auditing obligations. Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Airlou Platform, even after your Airlou Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Because we maintain the Airlou Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.


5.4 Withdrawing Consent and Restriction of Processing.


If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Airlou 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 Airlou override your own.


5.5 Objection to Processing.


In some jurisdictions, applicable law may entitle you to require Airlou 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 Airlou 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.


8. 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 Airlou Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Airlou Account, please contact us following the instructions in the Contact Us section below.


9. CHANGES TO THIS PRIVACY POLICY


Airlou 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 Airlou 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 at least thirty (30) days 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 Airlou Platform will be subject to the revised Privacy Policy.