Effective as of April 14th 2020.
• Data Collection: Information we collect or receive. How we collect your data. How information is used. How information is shared.
• Third Party Advertisers: Information collected by or through third-party advertising companies and how to opt out of third-party interest-based advertising.
• Communication Preferences.
• How We Protect Your Data.
• External Websites.
• Children’s Privacy.
• Your Privacy Rights: How we handle Do Not Track Signals. California Privacy Rights. Nevada Privacy Rights. Non-US Privacy Rights. Your data protection rights.
• Contacts: How to contact us. How to contact the appropriate authorities.
1. Information We Collect or Receive.
We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of our Site. In the course of operating the Site, we will collect and/or receive the following types of information:
(a) Personal Information. We only receive or collect information that identifies you personally (“Personal Information”) if you choose to provide such personally identifiable information to us via registration, email, or other means. When you sign up to become a user or contact us, you will be required to provide us with Personal Information about yourself. This Personal Information may include your name, date of birth, e-mail address, physical address, photo, phone number, and your driver’s license for the background check explained later in this Policy. We do not collect any of your Personal Information when you use the Site unless you voluntarily provide us with the information.
(d) Geolocational Information. Certain features and functionalities of the Site are based on your location. In order to provide these features and functionalities while you are using your mobile device and/or computer, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of your Geolocational Information occurs only when the Site is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
(f) Other Information. In addition to the Personal Information, Payment Information, and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Site; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Site. Such other information may include:
(i) From You. Additional information about yourself that you voluntarily provide to us, such as your age, a username, and your product and service preferences.
(ii) From Your Activity. We may collect or receive information regarding: your IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; referring and exit pages and URLs; date and time of your activity; and details regarding your activity on the Site, such as search queries and other performance and usage data.
(iii) About Your Mobile Device. We may collect or receive information regarding: the type of mobile device you are using; advertising Identifier (“IDFA” or “AdID”); the operating system and version (e.g., iOS, Android or Windows); your carrier; and the network type being utilized (WiFi, 3G, 4G, LTE).
2. How We Collect Your Data.
You directly provide us with most of the data we collect. We collect data and process data when you:
(a) Registration and Check-in. When you register with us through the Site or become a Zencity member through the Site to book an accommodation at a Zencity unit, we will ask you for certain Personal Information. We will also ask for your email address and password when you register as a Zencity service partner. You may be asked to provide a picture and government ID for identity verification purposes at registration or check-in, which picture and government ID image may be stored. Your Payment Information, such as a credit card number or billing information, is collected by our third party payment processor on our behalf.
(b) Communications. If you contact us directly, we will collect your name, contact details, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. You may choose to submit your email address and phone number on our Site to receive our updates. You may also provide us with your reviews of our services or complete surveys regarding our services. If you reach out to us with inquires or requests, we will keep a record of how your inquiry or request was handled.
(c) Administration and Personalization of Your Profile. We may collect any Personal Information you provide to us as part of the administration and personalization of your Zencity account profile. You may voluntarily provide us with information about yourself so that we can personalize your stays with us.
(d) Online Usage Data and Property Usage Data. We may automatically collect the following information about your use of our Site through: cookies, web beacons, and similar technologies: your domain name; browser type; operating system type, name and version; page views; links you click; your IP address; location information; the length of time you visit or use our Site; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the services and communications that we send you. We also automatically collect your Zencity stay history and may automatically collect information regarding the use of a Zencity accommodation. Please see the sections listed under the “Cookies” topic and the section labeled “Information Collected by or Through Third-Party Advertisers” below for more information. Where required under applicable law, we will only perform such data collection with your consent.
(e) Third-Party Travel Services. We may receive your booking information via our partners (e.g., Airbnb), such as your name, email address, phone number, information available in your user account with a third-party travel service and your Zencity stay information.
(f) Background Checks. If you are based in the United States and book a Zencity accommodation there, we may engage with a vendor to verify your criminal history. We may receive and store your name, date of birth, address, photo, and whether or not you passed the check.
3. How Information is Used.
We collect your data so that we can: Provide our services and enable you to access and use the Site; Improve our overall Site, and your experience with our Site (such as making suggestions, and ranking search results); Process and confirm your booking, check-in details, and to manage your account; Email you with special offers on other services we think you might like and administer our promotional programs; Solicit your feedback and provide you with customer services; and Comply with our legal obligations and ensure compliance with Zencity Policies (such as verifying information or identifications provided by you, resolve disputes, enforce our Terms of Service and other policies, conduct security investigations and risk assessments, and detecting or preventing fraud and other harmful activity).
We may also receive your data, with your permission, to run a limited criminal background check which will require your name, birth date, and address.
4. How Information is Shared.
(a) In order to provide our services and administer our promotional programs, we may share your information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
(b) We engage third-party companies and individuals to perform functions on our behalf. Examples include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the information only as necessary to perform their functions and to the extent permitted by law.
(c) When we process your reservation, we may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
(d) With your permission, we engage third parties, such as TransUnion, to run a limited criminal background check. We will store the information provided to us related to recommending or not recommending you.
(e) We may share reports with landlords and property managers regarding the use of their properties. Additionally, we may share guest names and dates of stay at their properties for security purposes (e.g. to ensure the individuals who are staying with them are guests). For long term rentals, we may share guests’ name, email address, phone number, ID, birthday and address with landlords. If permitted by applicable law, we may also share pass/fail results of background checks that we carry out on their guests based in the United States.
(f) In an ongoing effort to better understand our users, the Site, and our products and services, we analyze certain information in anonymized and aggregate form to operate, maintain, manage, and improve the Site, and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Site, and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
(g) We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
(h) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the information may be part of the transferred assets.
(i) To the extent permitted by law, we may also disclose the information:
(i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or
(ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
5. What are Cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit www.allaboutcookies.org.
7. Types of Cookies We Use.
There are a number of different types of cookies, however, our Site uses the cookies listed below.
We use session cookies, which expire once you close the Site, and persistent cookies, which stay on your mobile device or computer until you delete them and other technologies to help us collect data and to enhance your experience with the Site.
We use functionality cookies so that we recognize you on our Site and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
We use advertising cookies to collect information about your visit to our Site, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our Site.
8. How to Manage Cookies.
If you do not want us to deploy cookies in the Site, you can opt out by setting your mobile device or computer to reject cookies. You can still use the Site if you choose to disable cookies, although your ability to use some of the features may be affected.
9. Information Collected by or Through Third-Party Advertising Companies.
10. How to Opt Out of Third-Party Interest-Based Advertising.
If you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org for details on how to do so. You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/. Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because that page is not operated by us, we are unable to perform the opt-outs on your behalf. Additionally, users of mobile devices can limit ad tracking by accessing any settings offered by your mobile operating system.
11. Communication Preferences.
If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. You should be aware that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to the Site (e.g., requests for support).
We may also deliver notifications to your mobile device or computer (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device or computer.
12. How We Protect Your Information.
We take commercially reasonable steps to protect your data and information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We securely store your data with a cloud host. All of our servers are encrypted, with a standard process for data deletion. Sensitive data such as your passwords are stored as hashed values. We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that your information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mails sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
13. External Websites.
14. Children’s Privacy.
The Site is not directed to children under the age of 18. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 16. We ask that minors (under the age of 18) not use the Site. If a child under the age of 16 has provided us with Personal Information, a parent or guardian of that child may contact us at email@example.com and request that such information be deleted from our records. For more information about the Children’s Online Privacy Protection Act (COPPA), please visit www.ftc.gov.
15. How We Handle Do Not Track Signals.
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.
16. California Privacy Rights.
Under the California Consumer Privacy Act, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to firstname.lastname@example.org. California residents who are our users in California now have the right to see a report summarizing all of their personal data that we have collected and to request the removal of their data from our computer systems.
California law permits members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those third parties. See the “Contact Us” section for where to send such requests. Zencity does not share Personal Information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ Personal Information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes or collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
Notice to California Minors. If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our Site or other online services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g. if the content has been reposted by another user). To request removal of content or information, please email email@example.com.
17. Nevada Privacy Rights.
Zencity does not sell your Personal Information. However, we believe it is important that you are aware you have the right to opt-out of the sale of your Personal Information. Access requests may be made directly to firstname.lastname@example.org.
18. Important Notices to Non-U.S. Residents.
The Site and its servers are operated in the United States. If you are located outside of the United States, please be aware that your information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Site, you hereby consent to such transfer, processing, and use in the United States and elsewhere.
If you are located in the European Economic Area (“EEA”), we only process your Personal Information based on valid legal grounds, including when:
(a) Consent. You have consented to the use of your Personal Information, for example for marketing purposes or to track your online activities via cookies and similar technologies.
(b) Contract. We need your Personal Information to provide you with our services, for example for account registration and management or to respond to your inquiries.
(c) Legal Obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations, or anti-terrorism laws.
(d) Legitimate interest. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
19. Your Data Protection Rights.
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The Right to Access. You have the right to request copies of your personal data.
The Right to Rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete information you believe is incomplete.
The Right to Erasure. You have the right to request that we erase your personal data, under certain conditions.
The Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
The Right to Object to Processing. You have the right to object to our processing of your personal data, under certain conditions.
The Right to Data Portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we will respond to you within thirty (30) days. If you would like to exercise any of these rights, please don’t hesitate to contact us.
Email us at: email@example.com
Call us: (760) 548-3936
Or write to us at: Zencity ATTN: Privacy, 600 W. Cermak Rd, Suite B-E1, Chicago IL 60616
How to Contact Us.
Email us at: firstname.lastname@example.org
Call us: (760) 548-3936
Or write to us at: Zencity ATTN: Privacy, 600 W. Cermak Rd, Suite B-E1, Chicago IL 60616
How to contact the appropriate authority.
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with the supervisory authority of your residence, place of work or where the incident took place.