Last updated on April 5, 2019.
Table of Contents
1.3. Data Controller
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 Placeholder Service.
We ask for and collect the following personal information about you when you use the Placeholder Service. 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 Placeholder Account, we require certain information such as your first name, last name, email address, and date of birth.
- Profile and Listing Information. To use certain features of the Placeholder Service (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address and phone number.
- Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
- Payment Information. To use certain features of the Placeholder Service, we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
- Communications with Placeholder and other Members. When you communicate with Placeholder or use the Placeholder Service to communicate with other Members, we collect information about your communication and any information you choose to provide.
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 Placeholder Service. This additional information will be processed based on our legitimate interest or when applicable, your consent.
- Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Placeholder Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us (such as through Host Stories), or use other features of the Placeholder Service.
2.1.3. Information We Collect from Your Use of the Placeholder Service.
When you use the Placeholder Service, we 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 Placeholder Service.
- Geo-location Information. When you use certain features of the Placeholder Website, 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.
- Usage Information. We collect information about your interactions with the Placeholder Service such as your searches for Listings, Bookings you have made, and other actions on the Placeholder Service.
- Usage Data. We may collect information how the Placeholder Website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
2.1.4. Information We Collect from Third Parties.
Placeholder may collect information, including personal information, that others provide about you when they use the Placeholder Service, or obtain information from other sources and combine that with information we collect through the Placeholder Service. We do not control, supervise or respond for how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Third Party Services. If you link, connect, or login to your Placeholder Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Referrals. If you are invited to Placeholder, the person who invited you may submit personal information about you such as your email address or other contact information.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.
2.2. Children’s Data.
Our website and the Placeholder Service are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.
We may use, store, and process personal information to (i) provide, understand, improve, and develop the Placeholder Service, (ii) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with our Terms of Service and Placeholder Policies) and (iii) provide, personalize, measure, and improve our advertising and marketing.
3.1. Provide, Improve, and Develop the Placeholder Service.
We may use the personal information to provide, improve, and develop the Placeholder Service such as to:
- enable you to access and use the Placeholder Service,
- enable you to communicate with other Members,
- operate, protect, improve, and optimize the Placeholder Service 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 Placeholder Service and experience, and personalize and customize your experience (such as making Listing suggestions), we conduct profiling based on your interactions with the Placeholder Service, your search and Booking history, your profile information and preferences, and other content you submit to the Placeholder Service.
We process this personal information for these purposes given our legitimate interest in improving the Placeholder Service 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,
- 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 Placeholder Service, your profile information and other content you submit to the Placeholder Service, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Placeholder Service if such processes detect activity that we think poses a safety or other risk to the Placeholder Service, 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 Placeholder Service, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing.
We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
- send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Placeholder or partner campaigns and services) and social media advertising through social media services such as Facebook or Google),
- personalize, measure, and improve our advertising,
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Placeholder or its third party partners,
- conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Placeholder Service, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you, and
- invite you to events and relevant opportunities.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
3.4. Your Choices
You have choices on the promotional messages that you choose to receive.
- You can limit the information you provide to Placeholder. Participation in promotions and marketing programs is voluntary.
- You can limit the communications that Placeholder 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 Placeholder Account.
You can update your notification settings within your Placeholder Account by visiting the Notifications section of your Placeholder 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.
4.1. Advertising and Social Media; Sharing with Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Placeholder Account or when you participate in promotional activities conducted by Placeholder partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our website or otherwise promote our products and services or the Placeholder Service. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.
The social media platforms with which we may share your personal information are not controlled or supervised by Placeholder. Therefore, any questions regarding how your social media service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask Placeholder to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
4.2. Sharing between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Guest submit a Booking Request, certain information about you is shared with the Host, including your profile, full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your Booking is confirmed, we will disclose additional information to assist with coordinating the Booking, such as your phone number.
- When you as a Host have a confirmed Booking, certain information is shared with the Guest to coordinate the Booking, such as your profile, full name, phone number, and address.
We do not share your billing and payout information with other Members.
4.3. Profiles, Listings, and other Public Information.
The Placeholder Service lets you publish information, including personal information, that is visible to the general public. For example:
- Parts of your public profile, such as your first name, your description, and city, are publicly visible to others.
- Listings are publicly visible and include information such as the Place address, description, calendar availability, photos, 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 and may also be surfaced elsewhere on the Placeholder Service.
Based on our legitimate interest to promote the Placeholder Service, we may display parts of the Placeholder Service on sites operated by Placeholder’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 may also be displayed.
Information you share publicly on the Placeholder Service 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.
4.4. Additional Services by Hosts.
Hosts may need to use third party services available through the Placeholder Service to assist with managing their Place or providing additional services. Hosts may use features on the Placeholder Service to share information about the Guest (like Start Dates, End Dates, Guest names, Guest phone numbers) with such third party service providers for the purposes of managing a Booking or providing other services. Hosts are responsible for third party service providers they use and ensuring those service providers process Guest information securely and in compliance with applicable law including data privacy and data protection laws.
4.5. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Placeholder 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 legal process and to respond to claims asserted against Placeholder, (iii) to respond to valid requests 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, (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 Placeholder, its employees, its Members, or members of the public.
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 Placeholder Service 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 Placeholder’s property, its Members and the Placeholder Service. In instances where we comply with legal requests without notice for these reasons, we will 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.
4.6. Service Providers.
Placeholder uses a variety of third party service providers to help us provide services related to the Placeholder Service. For example, service providers may 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 Placeholder Service through third party services and software tools, (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
Placeholder will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.
4.7. Managers and Owners.
We may share personal information and booking information with landlords, management companies, or property owners in order to facilitate working with these partners. For example, the Booking and Guest personal information may be shared with owners and property managers of the Building in the Listing to facilitate Host Services, security, billing, and other services that may be provided.
4.8. Business Transfers.
4.9. Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
5.1. Analyzing your Communications.
We may review, scan, or analyze your communications on the Placeholder Service for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. 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. However, occasionally we may need to manually review some 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.
These activities are carried out based on Placeholder’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
5.2. Linking Third Party Accounts.
You may link your Placeholder Account with your account at a third party social networking service. When you create this link:
- some of the information you provide to us from the linking of your accounts may be published on your Placeholder Account profile;
- your activities on the Placeholder Service may be displayed on that third party site;
- a link to your public profile on that third party social networking service may be included in your Placeholder public profile;
- the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
- the publication and display of information that you provide to Placeholder through this linkage is subject to your settings and authorizations on the Placeholder Service and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5.3. Third Party Partners & Integrations
The Placeholder Service may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Placeholder doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Placeholder, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information.
You may exercise any of the rights described in this section by sending an email to info@Placeholder.com. 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 may access and update some of your information through your Account settings. If you have chosen to connect your Placeholder Account to a third party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
6.2. 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 Placeholder Account).
6.3. Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request 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).
6.4. 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 Placeholder Account for fraud or safety reasons, we may retain certain information from that Placeholder Account to prevent that Member from opening a new Placeholder Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Placeholder and Placeholder Payments may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., Reviews) may continue to be publicly visible on the Placeholder Service, even after your Placeholder 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 Placeholder Service 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.
6.5. 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 Placeholder 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 defense 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 Placeholder override your own.
6.6. Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Placeholder not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing, Placeholder 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 defense of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask Placeholder to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com.
6.7. Lodging Complaints.
You have the right to lodge complaints about our data processing activities by sending a complaint to us directly at firstname.lastname@example.org or with a supervisory authority.
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 Placeholder Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Placeholder Account, please contact us following the instructions in the Contact Us section below.