This Policy describes the following:
1. INFORMATION WE COLLECT AND HOW IT IS COLLECTED
2. HOW WE USE THE INFORMATION WE COLLECT
3. SHARING & DISCLOSURE
4. LEGAL BASIS FOR PROCESSING THE INFORMATION
5. YOUR RIGHTS AND CHOICES
6. SECURITY AND STORAGE OF THE INFORMATION
7. THIRD PARTY WEBSITES
8. INFORMATION ABOUT INTERNATIONAL TRANSFERS
10. NOTICE FOR CALIFORNIA RESIDENTS
11. CHANGES TO THE POLICY
12. CONTACT US
INFORMATION WE COLLECT AND HOW IT IS COLLECTED
We collect the following information about you:
- Information that you have provided to us or one of our third-party suppliers, such as your name, email address, telephone number, passwords, postal address, date of birth, gender, and other personal information.
- Information you provide to us when you communicate with us as part of the Services offered on the Platform, such as when you call us, message us or email us.
- Information about you that you have made publicly available and which we use as part of the Services offered on the Platform.
- Information about you which we may have obtained from certain third parties. For example, Membership IDs and similar data.
You can decide not to provide certain personal information. However, if you choose not to provide it, you may not be able to use the Platform.
When you use the Platform, some information may also be automatically collected, such as:
- Information about other websites you have visited (for example, the address of a referring website) before using the Platform.
- Usage Information. We collect information about your interactions with our Platform such as the pages or content you view, your searches for Spots, how often, and other actions on the Platform.
- Information about your location and time zone. We use this information to provide our Services to you and offer you an improved user experience, to improve our Platform, and to send you information about products and services you may be interested in. When you use certain features of the Platform, we may collect information about your location as determined through data such as your IP address or mobile device’s GPS. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Spot2Nite may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
- We may collect log data and certain technical and device-specific information. That information includes, among other things: details about how you have used the Platform (including if you clicked on links to third party applications), IP address, hardware model, operating system version, unique device identifiers, crash data, cookie data, and mobile network information including your phone number.
- Payment Transaction Information. Spot2Nite may collect information related to your payment transactions through the Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Spot2Nite and to allow the provision of the payment services.
- Other personal information from third parties. For example, information obtained when you use social media accounts.
Our Cookies Policy
We may also employ the use of anonymous identifiers, which are random strings of characters that are used for the same purposes as cookies on platforms, including certain mobile devices, where cookie technology is not available.
We also use other technologies with similar functionality to cookies, such as web beacons, pixels, mobile identifiers, and tracking URLs, to obtain log data. Web beacons are small, invisible graphic images that may be used on our Platform or in emails relating to our Services to collect certain information and monitor user activity on our Platform, such as to count visits and understand usage effectiveness. For example, our email messages may contain web beacons and tracking URLs to determine whether you have opened a certain message or accessed a certain link.
Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device makes available to us, please check the policies of your device manufacturer or software provider.
Children’s Data and Privacy
HOW WE USE THE INFORMATION WE COLLECT
We may use the information that we collect about you, including personal information, to:
- Provide Spot2Nite Services. We will use your information to provide the Services on our Platform to you; to facilitate Spot bookings; to manage your account; to respond to your inquiries; and for other customer service and support purposes. We use the payment information you provide to us in order to alert you of past, current, and upcoming charges, book accommodations with a Park, and to perform internal finance processes, such as reviewing the status of a credit card charge. In the event of a credit card dispute, we also share account information with your bank to verify the legitimacy of a charge.
- Understand, provide, improve and develop our products and the Platform. We may use, store, and process personal information to: enable you to access and use the Spot2Nite Platform and communicate with other Members, operate, protect, improve, and optimize the Spot2Nite Platform and experience, such as by performing analytics and conducting research about your use of or interest in our products, services or content or products, services or content offered by others, provide customer service, send you service or support messages, updates, security alerts and account notifications, and personalize and customize your experience (such as making Park suggestions or ranking search results). If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your letters of introduction, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection. We do this to help make our products better and to develop new products.
- 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, comply with our legal obligations and ensure compliance with Spot2Nite Policies, resolve any disputes with any of our Members and enforce our agreements with third parties, and enforce our Terms and other policies.
- Provide, personalize, measure, and improve our advertising and marketing. We may use the personal information to send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Spot2Nite or partner campaigns and services) and social media advertising through social media platforms 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 Spot2Nite or its third party partners, conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Platform, 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 (for example, when you share your Spot2Nite experience, we may use the information provided to reach out to you to invite you to relevant events).
- Communicate with you.
- Service-related communications. We may send you service and administrative emails to ensure the Platform is working properly. We will also email you regarding your Park reservation. These messages are considered part of our Platform and you may not opt out of these messages.
- Promotional. Subject to your opt-out preferences, we may send you emails about new product features or other news about Spot2Nite or on topics we think would be relevant to you. You may opt out of receiving these communications at any time. Visit the Your Rights and Choices section below. Please note, enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Spot2Nite Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have a Spot2Nite Account.
- Responding to your requests. We will also use your information to respond to your questions or comments.
- Administrative. We may contact you to inform you about changes in our Platform, our service offerings and other important service-related notices, such as changes to the Policy or about security or fraud notices.
- Advertising. Subject to your opt-out preferences, we may develop and display content and advertising tailored to your interests on our Services and other sites. See Your Rights and Choices below.
- Legal compliance. We may use your information to comply with applicable legal or regulatory obligations, including informal requests from law enforcement or other governmental authorities.
- Other. We also may use your information to manage our business or perform functions as otherwise described to you at the time of collection subject to your consent. Please read all online agreements carefully before accepting them.
Opting In to a Text Message Service
- You expressly authorize Spot2Nite to use autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In (i.e., the number listed on the Opt-In form or instructions or, if none, the number from which you send the Opt-In or, if none, the number on file for your account). You also authorize Spot2Nite to include marketing content in any such messages. You do not have to Opt In or agree to Opt In as a condition of purchase.
- You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, request a free paper or email copy of the Opt-In, or to update our records with your contact information, please contact us via the methods described in the Contact Us section. To view and retain an electronic copy of these SMS Terms or the rest of your Opt-In, you will need (i) a device (such as a computer or cell phone) with Internet access, and (ii) either a printer or storage space on such device. If you withdraw your consent, certain features of our Service may not be available to you. To update information on how we would contact you electronically, visit your Notifications settings in your Account settings.
- You confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorized to Opt In.
- You consent to the use of an electronic record to document your Opt-In. To withdraw that consent or update our records with your contact information, please visit your Spot2Nite Account Notifications settings or contact customer support at email@example.com.
- These SMS Terms still will apply if you withdraw the consent mentioned above or opt out of the Text Message Service.
After Opting In, in addition to the main messages the service offers, you may receive one or more welcome messages or administrative messages, such as (in some cases) a request to confirm your Opt-In.
About the Text Message Services and Opting Out
Message and data rates may apply. Unless otherwise noted, Text Message Services send multiple, recurring messages. Spot2Nite may terminate any Text Message Service or your participation in it at any time with or without notice, including, for example, before you have received any or all messages that you otherwise would have received, but these SMS Terms still will apply. Text STOP to any promotional message to Opt Out or if applicable update your Notifications settings on your Spot2Nite Account.
For additional help, text HELP in response to a marketing message or contact customer service at firstname.lastname@example.org.
SHARING & DISCLOSURE
We do not share your personal information with others except as indicated within this Policy or when we inform you and give you an opportunity to opt out of having your personal information shared.
We will share information we collect about you, including personal information, in the following ways:
- With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing our products and services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services, such as infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We require our Service Providers to agree to take reasonable steps to keep the personal information that we provide to them secure. We do not authorize them to use or disclose your personal information, except in connection with providing their services.
- Parks. In order to provide our Services, we share your personal information with Parks you have booked, or with other third parties who carry out services on the Parks’ behalf.
- Sharing between Members and Parks. To help facilitate reservations, bookings or other interactions between Spot2Nite Members and Parks, we may need to share certain information, including personal information, with Parks, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Spot2Nite Member submit a reservation or booking request, certain information about you is shared with the Park, 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 reserved or booked service, like your phone number.
- When you as a Spot2Nite Member invite additional Spot2Nite Members and/or Guests to a booking, your full name, reservation dates, Offering details and address, and other related information will be shared with each additional Spot2Nite Member and/or Guest.
- We do not share your billing and payment information with other Spot2Nite Members.
- Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Policy.
- Other users. If you choose to include personal information (such as your email address, photo or other details) in forums and other interactive areas on the Platform, this may be viewed by others who use our Services. If you choose to participate in a forum, your IP address may be shared with forum moderators. Sometimes information you choose to share will be available to other users and in some cases may be publicly available (for example, where you share personal information as part of a review, photo submission or similar).
- Business transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transactions, customer information is typically one of the business assets that is transferred or acquired by a third party. If we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, in the unlikely event of a bankruptcy proceeding, or as part of any other similar business transfer, you acknowledge that such transfers may occur.
- Aggregate or De-identified Information. We may disclose aggregate, anonymous, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
LEGAL BASIS FOR PROCESSING THE INFORMATION
We rely on the following legal grounds to process your personal information:
- Consent. We may use your personal information as described in this Policy subject to your consent. To withdraw your consent, please contact us at email@example.com. You may also refrain from providing, or withdraw, your consent for cookies. Please see Your Rights and Choices below for more information on opt-outs.
- Performance of a contract. We may need to collect and use your personal information to perform our contractual obligations to you (e.g. processing payments for and providing the Services offered on the Platform).
- Legitimate interests. We may use your personal information for our legitimate interests to provide the products and services on our Platform and to improve our Platform. We process information on behalf of our customers who have legitimate interests in operating their businesses. We may use technical information as described in this Policy and use personal information for our marketing purposes consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law.
YOUR RIGHTS AND CHOICES
You can limit the information you provide to Spot2Nite. Participation in promotions and marketing programs is voluntary.
- Account. In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at firstname.lastname@example.org or the address set forth at the end of this Policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
- Email. You may “opt out” of receiving marketing or promotional emails or messages from us at any time by following the opt-out links contained in the emails or following the instructions in the messages, or by accessing the Notifications settings in your Spot2Nite Account. Please note that it may take up to ten (10) business days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may still need to contact you with important transactional information about your account and send you non-promotional, service-related emails that are not available for opt-out, such as emails about your account or our on-going business relations. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
- Text Messages and Push Notifications. To revoke permissions that you may have given to send promotional text messages, text STOP in response to any message. You can always update your Notifications settings within your Spot2Nite Account by visiting the Notifications section of your Spot2Nite Account.
- Cookies. You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time.
- Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
SECURITY AND STORAGE OF INFORMATION
We have taken reasonable steps to help protect the personal information we collect. These measures include using SSL encryption and two-factor authentication, and passwordless authentication. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information in all circumstances.
You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims. Alternatively, we may continue to use your personal information in anonymized form. When you close your account with us, we will generally delete your personal information. Sometimes, however, we may keep your personal information after you have closed your account. For example:
- We may retain personal information about how you have used our Platform in anonymized or aggregated form after you have closed your account with us so we can analyze how you have used our Platform and improve our users’ experience.
- We may also retain your personal information after you have closed your account so that we can send you information about products and services we think you may be interested in. You can “unsubscribe” to receiving such messages or tell us you are no longer interested.
- We may retain your personal information in order to protect our legal rights, or those of third party, or to comply with the law.
THIRD PARTY WEBSITES
INFORMATION ABOUT INTERNATIONAL TRANSFERS
Spot2Nite is a corporation based in the United States. If you are visiting our Platform from outside the United States, please be aware that your information, including personal information, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that the information, including personal information, will be transferred to and stored and processed in the United States. By submitting your personal information to Spot2Nite and using Spot2Nite, you expressly consent to having your personal data transferred to, processed, and stored in the United States or another jurisdiction whose laws might not be as comprehensive and may not offer the same level of privacy protection as those in the country where you reside or are a citizen.
Information-Sharing Disclosure. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you first agree to such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at email@example.com
NOTICE FOR CALIFORNIA RESIDENTS
For United States residents in California, personal data or personal information has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”). We will collect, store, use and disclose personal data in accordance with the CCPA. The CCPA may provide you with the following rights.
Information. You can request information about how we have collected, used and shared your personal information during the past 12 months. To do so, please email: DPO@spot2nite.com
Access. You can request a copy of the personal information that we maintain about you. To do so, please email: DPO@spot2nite.com
Deletion. You can ask us to delete the personal information that we collected or maintain about you. To do so, please email: DPO@spot2nite.com
Opt-out of sale of your personal information. If we sell your personal information, you can direct us to stop selling your information. To do so, please email: DPO@spot2nite.com. If you opt-out we will also stop sharing your personal information covered by that law with third parties.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. You will not receive discriminatory treatment by Spot2Nite for the exercise of rights conferred to you by the CCPA.
To request access to or deletion of personal information:
- visit the websites referred to above
- email DPO@spot2nite.com
CHANGES TO THE POLICY
If you have any questions about this policy or Spot2Nite’s information handling practices, you may email us at firstname.lastname@example.org.
If you have any questions or concerns regarding privacy or your data using the Services, please send us a detailed message to our Data Protection Officer (DPO) DPO@spot2nite.com.