DROPDESK PRIVACY POLICY

1.1.1 Contact, Account, and Profile Information.

Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

1.1.2 Identity Information.

Where appropriate, we may ask you for an image of your government-issued ID (in accordance with applicable laws) or other verification information, and/or a selfie when we verify your ID.

1.1.3 Payment Information.

Such as payment account or bank account information. If you are not a DropDesk user, we may receive payment information relating to you, such as when a DropDesk user provides your payment card to complete a booking.

1.1.4 Loyalty and Marketplace Information.

Such as the Branded Marketplace through which you access or use the DropDesk Platform, your Loyalty Program enrollment and status, Loyalty Fees, Loyalty Discounts, Coupons, Pass Credits, and other benefits, offers or features associated with your Account or an applicable Branded Marketplace.

1.2.1 Additional Profile Information.

Such as gender, preferred language(s), city, and personal description.

1.2.2 Information About Others.

Such as a payment instrument or contact information belonging to another person, for example a Team member using DropDesk Pass. By providing us with personal information about others, you certify that you have permission to provide that information to DropDesk for the purposes described in this Privacy Policy and you have shared the DropDesk Privacy Policy with them.

1.2.3 Biometric Information.

Such as facial recognition data derived from photos and identification documents you submit for verification, where offered and with your consent where required by applicable law.

1.2.4 Other Information.

Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with DropDesk customer service and other Members, provide your address and/or geolocation, or share your thoughts with us.

1.3.1 Geolocation Information.

Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings.

1.3.2 Usage and Log Information.

Such as communications with us, Hosts, Users or Marketplace Partners, Bookings you have made, additional services and amenities you have added, Loyalty Program activity, access dates and times, and other actions on the DropDesk Platform.

1.3.3 Device Information.

Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data, and read receipts. We may collect this information even if you haven’t created a DropDesk Account or logged in.

1.3.4 Cookies and Similar Technologies.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Site. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. This website’s uses of cookies include those cookies that are strictly necessary to enable the features of the website, performance cookies to see how visitors use the website, and functionality cookies that enable the webpage to “remember” machines or devices, personalize website content and tailor user experience. In addition, cookies may be used to help us define our audience so that we can make appropriate changes to this website (“Demographics” cookies) and target advertisements to users when they are browsing this website and other websites (“Interest Reporting” cookies), in each case by reference to anonymous identifiers, not personal information.

1.3.5 Payment Transaction Information.

Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, your address, transaction status, refunds, disputes, applicable Service Fees, Loyalty Fees and discounts, and other related transaction details.

1.4.1 Third-Party Applications.

If you choose to link, connect, or login to the DropDesk Platform with a third-party service, such as Google or Facebook, you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

1.4.2 Background Information Providers.

For Members in the United States, to the extent permitted by applicable laws, we may (but are not obligated to) obtain, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we may obtain police, background, or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

1.4.3 Team Invitations and Account Management.

Organizations that use our Team product may submit personal information to facilitate account management and invitations to Team members.

1.4.4 Marketplace Partners.

If you access, register for, interact with, or make or receive a Booking through a Branded Marketplace operated by a Marketplace Partner, we may receive Personal Information from the relevant Marketplace Partner. This may include your contact and account information, information concerning your relationship with or eligibility to participate in the Branded Marketplace, Loyalty Program information, and information concerning Packages, Bookings, transactions and other activity associated with that Branded Marketplace. We may combine this information with other information we maintain about you in connection with your use of the DropDesk Platform.

1.4.5 Complaints.

If a Host, Member, Marketplace Partner, or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint.

1.4.6 Financial Institutions and Payment Providers.

If you elect to pay with funds from your bank account or use Payment Services, we may receive certain information from your financial institution, Stripe, or other payment providers, such as bank account details, transaction status, payment confirmations, payout information, disputes, refunds and other information necessary to facilitate Payment Services.

1.4.7 Other Sources.

To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from (i) third-party service providers, other third parties, Marketplace Partners and/or partners, or (ii) Members and any other individuals, entities, and authorities, and combine it with information we have about you.

3.2.1 Hosts and Users.

To facilitate a Booking, provide Host Services, enable communications between Members, address Booking Modifications, cancellations, refunds, disputes, safety matters and customer service issues, and otherwise perform the applicable contract between a Host and User, we may share Personal Information between the applicable Host and User. Depending upon the applicable Package or Host Service, this may include names, contact information, Booking details, dates and times, number and identity of Users where appropriate, transaction and payment status, communications, special requests and other information reasonably necessary to facilitate or administer the Booking or provide the Host Service. Hosts and Users receiving Personal Information are responsible for their own use of that information in accordance with applicable law and these Terms.

3.2.2 Marketplace Partners and Branded Marketplaces.

If you access, register for, participate in, purchase a Package through, or otherwise interact with a Branded Marketplace operated by a Marketplace Partner, we may share Personal Information with the relevant Marketplace Partner as reasonably necessary to operate and administer that Branded Marketplace and provide the applicable services. Depending upon your use of the Branded Marketplace, this may include your name and contact information, membership or account information, Packages and Host Services viewed, offered or purchased, Booking and transaction information, Loyalty Program enrollment and status, Loyalty Fees, Loyalty Discounts and Coupons, communications relating to the Branded Marketplace, and other information reasonably necessary to administer the applicable Branded Marketplace. Marketplace Partners may use this information to administer their Branded Marketplace, manage participating Members and Packages, administer applicable Loyalty Programs and benefits, provide customer support, facilitate transactions and Bookings, communicate with Members concerning the Branded Marketplace, and perform their respective obligations in connection with the Branded Marketplace. A Marketplace Partner’s use of Personal Information for its own purposes may also be subject to its own privacy policy and applicable law. A Marketplace Partner’s access to Personal Information through the DropDesk Platform does not, by itself, authorize the Marketplace Partner to use that information for unrelated independent marketing purposes. Any such use must be permitted by applicable law and, where required, based upon the Member’s consent or other applicable authorization.

3.2.3 Members’ Service Providers.

Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the DropDesk Platform to share information about the User with such third-party service providers. Other Members may use services other than DropDesk to process your data, including email or reservation management software. Such services are outside of DropDesk’s control and will be subject to applicable law.

3.2.4 Building Management.

We may share personal information of Hosts and Users with the owner(s) of a Venue, a homeowners’ association, and/or their agent, such as a building operator or property management company (“Building Management”), including Booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. User Booking and personal information, including User contact information, may be shared with the Building Management of the building, complex, or community where the Venue or Package is located to facilitate Host Services, compliance with applicable laws, security, billing, and other services.

3.2.5 DropDesk Enterprise and Teams.

If a Booking is designated as being for a business or work purpose and is made by a User affiliated with an Enterprise enrolled in DropDesk Teams, we may disclose information related to the Booking to the Enterprise to the extent necessary for the adequate performance of DropDesk’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the User we may also share this information with third parties engaged by the Enterprise to provide support services.

3.2.6 Service Providers.

We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, hosting and debugging, (v) allow the provision of the DropDesk Services through third-party platforms and software tools, (vi) provide customer service, advertising, or payments services, (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, or (ix) review, scan, and analyze communications on the DropDesk Platform for certain purposes. These providers are contractually bound to protect your personal information, have access to your personal information to perform these tasks, and may also disclose your information where required by law.

3.2.7 Payment Services and Stripe.

DropDesk uses Stripe and its affiliates to provide payment processing and related Payment Services. In connection with a Booking, Loyalty Fee, subscription, Host payout, refund or other transaction, we may provide Stripe with Personal Information and transaction information reasonably necessary to process the transaction, verify identity, facilitate payouts, prevent fraud and abuse, manage disputes and chargebacks, and satisfy legal, regulatory and compliance requirements. Stripe may collect certain payment and identity information directly from Members and process that information in accordance with its own privacy policy and applicable law. DropDesk does not necessarily receive or store all payment card or financial account information provided directly to Stripe.

3.2.8 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the DropDesk Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies. Even if your country of residence is not the United States, your information will be shared with DropDesk, LLC in the United States which provides the technical infrastructure for the DropDesk Platform.

3.3.1 Build Your Public Profile.

Information you share publicly on the DropDesk Platform may be indexed through third-party search engines. In some cases, you may opt-out of this sharing in your Account settings. We may make certain information publicly visible to others, such as:

3.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights.

3.3.2(i) Disclosure.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, Marketplace Partners, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against DropDesk, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our Terms and Policies with Members, (v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning DropDesk and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of DropDesk, its employees, its Members, Marketplace Partners, or members of the public.

3.3.2(i)(a) To Tax Authorities.

Where legally required or permissible according to applicable law, we may disclose Hosts’ and/or Users’ information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations.

3.3.2(i)(b) To Governmental Authorities for Registrations, Notifications, Permits, or License Applications or Numbers.

In jurisdictions where DropDesk facilitates or requires a registration, notification, permit, or license application or number of a Host with a governmental authority, we may share information of participating Hosts with the relevant authority, during the application process, when the Package is published, and periodically thereafter.

3.3.2(ii) Notification.

Where appropriate and/or legally required, 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 or harm to DropDesk, our Members, or expose DropDesk to a claim of obstruction of justice.

3.3.3 Effectuate Business Transfers.

If DropDesk 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, such as due diligence. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5.5.1 Legitimate Business Interests.

We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a DropDesk Account for fraud or safety reasons, we may retain information from that DropDesk Account to prevent that Member from opening a new DropDesk Account in the future.

5.5.2 Legal, Tax, Reporting, and Auditing Obligations.

We may retain and use your personal information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations.

5.5.3 Shared Information.

Information you have shared with others, such as Reviews and forum postings, may continue to be publicly visible on DropDesk, even after your DropDesk Account is canceled. Information previously shared with Hosts, Users, Marketplace Partners or other third parties may also remain in their possession and be retained by them in accordance with applicable law and their own legal obligations or privacy practices.

5.5.4 Residual Copies.

Because we take measures to protect data 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.