Privacy Policy

INTRODUCTION

Lodgee takes your privacy very seriously and is committed to protecting your personal data and respecting your privacy. We comply with all relevant data protection laws, including the General Data Protection Regulation.

This policy explains to you how we collect, use and process your personal data and for which purposes. Please read it carefully to understand our views and practices regarding your personal data when using our Platform.

Any capitalized terms used throughout this policy have the same meaning as in our Terms of Service.

DATA CONTROLLER

Two & Three Ltd, the company owning and controlling the Lodgee platform, is your data controller. This means that we are responsible for, and control the collecting and processing of, your personal data. You can find all our details under How to contact us.

Further in this policy Two & Three Ltd is also referred to as “we”, “our” and “us”. Our Users are referred as “you” and “your”.

PERSONAL INFORMATION WE COLLECT

You can access and browse parts of our Site without having to supply any personal data. But if you want to set up an account and make full use of our services you will need to provide us with personal data.

Please note that you can always monitor and control the processing of your personal data by exercising Your rights.

Please see below for the type of information we collect from you and what our purpose is for doing so.

  1. Personal information you give to us

    This is information about yourself that you provide us with at our request. It includes information you provide when you sign up for an account and when you communicate with us.

    Such personal information includes:

    • first name(s)
    • last name
    • address
    • e-mail address
    • telephone number
    • date of birth

    On what basis do we collect this information and what is the purpose of it?

    • This information is all necessary to enable us to perform our obligations under the contract we have with you (our Terms of Service). In other words: without this information we cannot provide our services to you.
    • Some of your information is also needed to enable us to comply with our legal obligations.
    • In addition, we also use your e-mail address to notify you about changes to our terms, services or policies.
    • We also use your e-mail address to send you our newsletter, although we need your specific consent to do so.
  2. Other personal information about you that you choose to share with us

    We may give you the option to share additional information with us. If you choose to do so, this may enhance your user experience and you may be better equipped to make full use of all our services and features. The processing of such information is not strictly necessary to use our Platform, and therefore we do need your consent as a lawful basis for processing such information.

    It includes information you provide when you complete your profile on our Platform, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, post content, invite your contacts to use our Platform, or report a problem with our Platform.

    Such information may include:

    • Your gender
    • Your profile picture
    • Your personal description
    • Your contacts (address book/e-mail addresses)

    Please be aware that such information may be visible to the general public. If you do not want other people to have access to such information, do not upload it.

    • This information is all necessary to enable us to perform our obligations under the contract we have with you (our Terms of Service). In other words: without this information we cannot provide our services to you.
    • Some of your information is also needed to enable us to comply with our legal obligations.
    • In addition, we also use your e-mail address to notify you about changes to our terms, services or policies.
    • We also use your e-mail address to send you our newsletter, although we need your specific consent to do so.
  3. Other information we collect about you

    Each time you visit our platform we will automatically collect the following information. This is mostly non-personal information, but it does include some personal information, such as your IP-address and your location.

    We use this information to operate, protect, improve and optimize our Platform and also to personalize and customize your user experience.

    We need to collect and process that information to adequately perform our services (to provide you with all the functionalities we offer) and the processing of such information is also in our legitimate interest to provide, improve and safeguard the different functionalities we offer.

    Such information can be categorized as follows:

    • Technical information: the Internet protocol (IP) address used to connect your device to the Internet, device information, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • Information about your visit: the full Uniform Resource Locators (URL), clickstream to, through and from our site including date and time, products and services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;
    • Location data: we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates or similar information regarding the location of your device. Some features of our Platform, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
  4. Personal information we receive from other sources

    Sometimes we receive personal information about you from third-parties if you access our Platform through a third-party connection or log-in or from other Users when they use our Platform. Such information you may be used by us in combination with information we already have about you and will only be processed for the purposes set out above.

    Information shared with or provided to us includes:

    • Information about you if you access our Platform through a third-party connection or log-in, such as Google or Facebook. That third party may pass on certain information about your use of its service to us. This information could include the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. We do not control how such third-parties process and share your personal information with us. You should therefore always review, and if necessary, adjust your privacy settings on such third-party sites and services before linking or connecting them to us. You may also unlink your third-party account from our Platform by adjusting your settings on the third-party service;
    • Information about you shared by other Users of our Platform in a review about you.
  5. Information collected from your communications

    Sometimes, we may analyze or scan your communications on our Platform. We may use automated methods to do this, but every now and then we may also need to conduct such analyses manually. Such access to and processing of personal information is based on our legitimate interest to comply with applicable laws as well as our terms and policies, to prevent fraud, keep our Platform safe and secure, and our continued efforts to improve the functionalities we offer our Users.

    We do this for a number of purposes:

    • To comply with laws and regulations
    • To enforce our terms and policies
    • To comply with legal requests and cooperate with investigations
    • To prevent fraud
    • To improve, fix and expand the services we offer

OUR SITE IS NOT FOR CHILDREN UNDER THE AGE OF 18

Our Platform is not intended for children under the age of 18 or the legal age of majority in your country of residence. We do not knowingly collect or distribute personal information from or about such persons. If you are under the age of 18 or the applicable age of majority in your country of residence, please do not use our Platform and services.

If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us so we can remove such information promptly.

COOKIES

A cookie is a small text file that is placed onto the electronic device you use when you visit our Site. Cookies can be used to help you navigate websites more efficiently and to perform certain functions, as well as to provide information to us. There are several types of cookies and other online tracking devices such as web beacons, action tags, local shared objects or flash cookies, and single-pixel gifs. Cookies can perform different functions and serve different purposes:

  • Strictly necessary cookies: these cookies are required for a good operation of our Site and include, for example, cookies enabling you to log into secure areas of our Platform. Because these cookies are necessary for the operation of our Platform, you cannot turn them off.
  • Analytical/performance cookies: these cookies allow us to recognize and keep count of the visitors of our Platform and see how our visitors navigate our Site. They enable us to estimate our audience size and usage patterns and help us to improve our Platform so your online experience can be made more efficient and enjoyable.
  • Functionality cookies: these cookies are used to recognize visitors returning to our Platform. They enable us to personalize our content for you and remember your preferences. This speeds up your access to our Platform.
  • Targeting cookies: these cookies record your visits to our site, the pages you visited and the links you have followed. We use such information to make our Platform - and advertising displayed on it - more relevant to your interests.

When you visit our Platform for the first time, you will see a notice displayed on our landing page about the use of cookies. This notice links to this policy and gives you a choice to accept or refuse analytical, functionality and targeting cookies. Such cookies are automatically blocked and will only be used after you click accept. Some features of our Platform may not function properly if you choose to decline the use of cookies.

Please note that you can always withdraw your consent by either contacting us or by adjusting the privacy preferences of your browser.

You can change your privacy preferences regarding the use of cookies and other similar technologies through your browser. You may set your browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block all cookies. Blocking all cookies will affect your online experience and may prevent you from enjoying the full features offered through our Platform. Because the use of cookies is browser-specific, you need to modify your preferences for each different browser.

WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

With whom do we share your personal information?

  1. Other users of our Platform

    To perform our obligations under our Terms of Service it is necessary to share some of your personal information with other Users of our Platform.

    The following are examples of situations in which we share your information with other Users:

    • Guests: when you make a Booking, some personal information will be passed on to the Host, such as your full name and the names of any accompanying Guests. Once your Booking is confirmed by the Host, we will also share your e-mail address and phone number with the Host. This is done to enable communication between Guests and Hosts, for example to communicate about additional requests and to co-ordinate a trip.
    • Hosts: when you confirm a Booking, certain information will be made available to the Guest, such as your full name, Property address, e-mail address and phone number.
    • When a Guest invites accompanying Guests to a Booking, that Guests’ full name, his travel dates, the applicable Host name, Listing details and Property address will be shared with the accompanying Guests.
  2. The general public

    Some of the personal information you provide us with will be shared with and is accessible by the general public. This is partly necessary to perform our obligations under the contract we have with you so that we can offer all the functionalities in a proper manner. For the parts of your information this does not apply to, we rely on your consent.

    Such information includes the following:

    • Your profile information. In any case your first name, personal description and city of residence will be made public. You may choose to disclose additional information about yourself by giving us your consent to do so.
    • When a Host has published a Listing, the contents of this Listing are publicly accessible. The Listing may include, depending on your preferences, the description of your Property, the approximate or precise location of your Property’s address, your public profile photo and the availability calendar.
    • Ratings and reviews.
    • Whenever you use a feature on our Platform which enables you to communicate with other Users, the information you upload will be publicly accessible.

    Any information that is publicly accessible on our Platform may also be indexed by third-party search engine providers. We do not have any control over such third-parties.

  3. Additional service providers used by Hosts

    Sometimes Hosts will have the opportunity to use third-party services to assist them in the managing of their Property or to carry out obligations they have under their contract with Guests. In doing so, a Host may disclose certain personal information of a Guest to such third-party providers, such as your name and your phone number, for the purpose of coordinating such services.

  4. Selected third parties

    We will share your information with selected third parties including:

    • Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, such as the third-party payment provider we use (Stripe). When we share your information, we require such companies to take reasonable steps to safeguard your data.
    • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our Users (for example, we may inform them that 500 men aged under 30 have clicked on an advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
    • Analytics and search engine providers that assist us in the improvement and optimization of our site.
  5. Other circumstances in which we share your personal information

    We will also share your personal information in the following circumstances:

    • In the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets;
    • If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our Users will be one of the transferred assets;
    • If we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or investigation;
    • To enforce or apply our terms, agreements and policies;
    • To protect the rights, property, or safety of Lodgee, our Users or of others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

    In the event we receive a legal request to disclose personal information, we may notify you of such request before we do so, unless this is expressly prohibited by the authority making the request or if notifying you would be detrimental to us, the party requesting your personal information, or any other person affected, or to the investigation itself. If we can’t notify you of such requests beforehand for the reasons set out before, we will try to notify you afterwards.

USING LINKS ON OUR PLATFORM

Our Site may contain links to and from websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check such policies before you submit any personal data to these websites.

SOCIAL MEDIA AND OTHER FEATURES

Our Platform may include social media features, such as the Facebook Like button. Our integration of these features may allow third party social media to collect certain information about you such as your IP address, which page you are visiting when using our Platform, and to set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly through the use of our Platform. Your interactions with these features are governed by the privacy policy of the company providing them.

Our platform uses Google Maps and Google Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to the Google Privacy Policy.

STRIPE

If you make a purchase through our site, you will be using our third-party payment service provider Stripe. All information, such as financial information and credit or debit card information, collected by Stripe for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of our Platform. Personal information collected from you by Stripe is governed by their privacy policy. Please review their policy prior to submitting any information to Stripe.

SECURITY MEASURES

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We use encryption to safeguard your personal data. All personal information we collect or receive from you is stored on our secure servers, located in the UK.

Where we have given you - or where you have chosen - a password which enables you to access our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platform; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access and data breaches.

RETENTION OF YOUR PERSONAL DATA

We only retain your personal data for as long as your account is active or for as long as we need it to fulfil the purposes for which we have initially collected it. We may retain certain information for a longer period of time to comply with applicable laws, such as those on tax, or in our legitimate interests to prevent fraud and enhance safety. If you have provided information that is publicly accessible, such as a review or comments on a discussion board, this may continue to be publicly accessible. However, it will not be attributed or linked you or your profile anymore after your account has been deleted.

TRANSFER OF PERSONAL INFORMATION OUTSIDE THE EEA

Our services are directed to users located all over the world. The following applies to users located in the European Economic Area (EEA): the personal information we receive and collect from you may be transferred to, and stored at, a destination outside the EEA.

For example, if you use our Platform to make a Booking for a Property located in a country outside of the EEA, we will provide the Host of that Property with your personal details to enable that Host to perform any obligations to you.

Any non-EEA countries may not have the same data protection laws as the United Kingdom and EEA. In the event your personal information is transferred to such countries, we have ensured that appropriate safeguards are put in place to protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under data protection laws, you have the following rights, which you can enjoy free of charge. You can exercise some of these rights via your dashboard in your account. Others may require you to contact us. We may request you for proof of identity and address when you exercise your rights.

  1. Right of transparency and information about how we use your personal information.
  2. Right to ask us to confirm whether or not we hold any personal information from you and if we do, the right to ask us what information we have stored about you and for a copy of that information.
  3. Right to rectify any inaccurate personal data we hold about you or to complete any incomplete information.
  4. Right to have all personal data we keep from you erased in the following situations:
    • The personal data are no longer necessary in relation to the purpose for which it was collected;
    • You have withdrawn your consent to process your data and we do not have any other legal ground to keep processing your data;
    • You object to the processing of your data while we do not have any overriding legitimate grounds to do so;
    • Your data have been unlawfully processed.
  5. Right to ask us to restrict the processing of your personal data if any one of the following applies:
    • If you contest the accuracy of the personal data, for a period so long that we can verify the accuracy of your personal data;
    • If the processing is unlawful and you oppose the erasure of your data and ask for a restriction instead;
    • We do no longer need your personal data for the purpose for which it was collected, but you require your data for the purpose of establishment, exercise or defense of legal claims;
    • You have objected to the processing pending verification of the legitimate grounds to override such objection.
  6. Right to object to:
  7. Right to withdraw consent you have given us to process your personal data, where consent is being relied on as the lawful basis of such processing.
    • Processing of personal data concerning you based on legitimate interests or the performance of a task in the public interest. Such objection must be based on grounds relating to your particular situation. We are obliged to stop processing your data, unless either we can demonstrate that we have compelling legitimate grounds to override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of legal claims;
    • Direct marketing.
  8. Right to receive the personal data concerning you in a structured, commonly used, machine-readable format.
  9. Right not to be subject to automatic decision-making, including profiling.

MAKE A COMPLAINT

If you encounter any problems in relation to the use of your personal data, please contact us so we can try to resolve your issue or concern.

As an EU/EEA citizen, you also have the right to lodge a complaint with the supervisory authority in the EU/EEA member state where you work, normally live or where any alleged data infringement of data protection has occurred.

In the UK, this authority is the Information Commissioner who you can contact via https://ico.org.uk.

CHANGES TO THIS POLICY

Any changes we make to our Privacy Policy will be posted on our site accompanied by a statement that changes have been made. In addition, if we have collected your e-mail address, we will e-mail you our revised policy. Your continued use of our Platform will be deemed your acceptance of our revised Privacy Policy. If we need your renewed consent, we will ask you for it.

HOW TO CONTACT US

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to …@lodgee.com or to Two & Three Ltd, a private limited company registered in England and Wales under company number 10852514, with our registered offices at Maple House, 382 Kenton Road, Kenton, Harrow, Middlesex, HA3 8DP, United Kingdom.