Last Updated: October 30, 2020
Vinera Hub exists to help build connections between people and make the world more open and inclusive. In short—to build a world where anyone can belong anywhere. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy.
2. PERSONAL INFORMATION WE COLLECT
2.1 Information needed to use the Vinera Hub Platform.
We collect personal information about you when you use the Vinera Hub Platform. Without it, we may not be able to provide you with all services requested. This information includes:
2.2 Information you choose to give us.
You can choose to provide us with additional personal information. This information may include:
2.3 Information Automatically Collected by Using the Vinera Hub Platform and our Payment Services.
When you use the Vinera Hub Platform and Payment Services, we automatically collect personal information. This information may include:
2.4 Personal Information We Collect from Third Parties.
We collect personal information from other sources, such as:.
3. HOW WE USE INFORMATION WE COLLECT
3.1 Provide, Improve, and Develop the Vinera Hub Platform. We use personal information to:
3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:
3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use personal information to:
3.4 Provide Payment services. Personal information is used to enable or authorize third parties to use Payment Services:
4. SHARING & DISCLOSURE
4.1 Sharing With Your Consent or at Your Direction.
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Vinera Hub account or participating in promotional activities by Vinera Hub partners or third parties.
Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Vinera Hub or otherwise promote our products and services.
4.2 Sharing Between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information such as:
4.3 Information You Publish in Profiles, Listings, and other Public Information.
You can make certain information publicly visible to others, such as:
We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms and apps.
Information you share publicly on the Vinera Hub Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.
4.4 Host 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 Vinera Hub Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third-party service providers.
4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where 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 Vinera Hub, (iii) to 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 (more information on Vinera Hub’s Law Enforcement Guidelines here ), (iv) to enforce and administer our agreements with Members, or (v) to protect the rights, property or personal safety of Vinera Hub, 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.
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 or harm to Vinera Hub, our Members, or expose Vinera Hub to a claim of obstruction of justice.
For jurisdictions where Vinera Hub facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, bookings, Accommodations and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.
In jurisdictions where Vinera Hub facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Vinera Hub in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.
4.6 Programs with Managers and Owners.
We may share personal information of Hosts and Guests such as booking information, and information related to compliance with applicable laws.
4.7 Host Information Provided to Vinera Hub for Work Customers.
If a booking is designated as being for business or work purpose and (1) is made by a Guest affiliated with an Enterprise, (2) the Enterprise is enrolled in Vinera Hub for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Accommodation address, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of Vinera Hub’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.
4.8 Service Providers.
We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Vinera Hub Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Vinera Hub’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.
4.9 Business Transfers.
4.10 Corporate Affiliates.
To support us in providing, integrating, promoting and improving the Vinera Hub Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:
5. OTHER IMPORTANT INFORMATION
5.1 Analyzing your Communications.
We may review, scan, or analyze your communications on the Vinera Hub Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.
5.2 Linking Third-Party Accounts.
You can link your Vinera Hub account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:
5.3 Third-Party Partners & Integrations.
6. YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.
6.1 Managing Your Information.
You can access and update some of your personal information through your Account settings. If you connected your Vinera Hub Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.
6.2 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Data Erasure.
In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
While no organization can guarantee perfect 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.
9. CONTACT INFORMATION AND RESPONSIBLE Vinera Hub ENTITIES