Privacy Policy

VREASY PRIVACY POLICY – FRENCH V.

Vreasy and all its subsidiaries and affiliates expects its employees, including those of its subsidiaries worldwide and third parties with whom Vreasy does business, to maintain the highest standards of ethics and compliance with applicable laws and rules. Vreasy is committed to the highest standards of privacy and data protection compliance and expects all its employees and management to adhere to these standards.

Vreasy (hereinafter referred to as “Vreasy”, “we”, “us” or “our”) provides an online platform designed to help vacation rental owners and property managers (collectively known as “Owners”) create and manage vacation rental properties either through our website or our mobile applications (“Platform”).

We understand that privacy is important to our online visitors and users. We respect your privacy and will take all reasonable steps to safeguard and protect your information as if it was our own.

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your Vreasy Account.

This Policy applies to the Vreasy.com website, including all subpages and successor pages (collectively referred to as the “Website”), and also applies to all Services that we offer.

This Policy does not apply to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party company before deciding whether to provide any information (such as https://stripe.com/fr/privacy ).

By using our Website or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, please delete all cookies from your browser cache after visiting our Website and do not visit or use our Website or Services. Your continued use of our Website or Services will signify your acceptance of this Policy.

DEFINITIONS
Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Accommodation”, “Content,” “Services” etc.), it shall be given its definition as outlined in our our Terms of Service.

“Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Data Controller” means Vreasy, the company responsible for the use and processing of Personal Information.

“Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Vreasy.

“Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

WHAT TYPES OF INFORMATION DOES VREASY GATHER ABOUT ITS USERS?
Website Visitors
To simply browse our Website, you are not required to provide any Personal Data. However, we may gather non-personally-identifiable information solely for the purposes of monitoring and improving our Website and Services. We will not share this information with third parties or use it to target any advertisements to you.

We do not knowingly collect information from children under 15 years of age or have any reasonable grounds for believing that children under the age of 15 are accessing our Website or using our Services. If we learn that we have inadvertently collected Personal Data from a child under age 15, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 15, please contact us at privacy@vreasy.com.

Information that you give us
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;

access or use the Platform, such as to search for or post Accommodations, make or accept bookings, pay for Accommodations, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;

link your account on a Third-Party site (e.g. AirBnB, HomeAway, etc) to your Vreasy Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

communicate with Vreasy; and

share information with another Member.

Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

Mobile Data
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

Contact Information
You may use your contact information, such as your email address, phone number or account ID to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address, phone number or account ID, you agree to receive emails to that email address, text messages to that phone number or messages to that account, as the case may be. We may use your contact information to send you information about our Platform and Services, to market to you, and to help prevent spam, fraud, or abuse.

Log Data
We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Vreasy or logged in to your Vreasy Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

Cookies and other Tracking Technologies
Vreasy uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Vreasy services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.

Third Parties may not collect information about users’ online activities on the Platform except as described in this policy and our Cookie Policy.

COOKIE POLICY
Vreasy uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

Vreasy cookies and Third Party cookies
Vreasy may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.

Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

Other technologies
The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

Uses for Vreasy cookies
Vreasy uses cookies and similar tracking technologies for a number of purposes, such as the following:

to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.

to simplify your access to and use of the Platform and make it more seamless.

Third-Party social plugins
Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.

HOW VREASY USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process information about you for the following general purposes:

to enable you to access and use the Platform;

to enable you to communicate with other Owners or Guests, including but not limited to by sending them messages or other information before and during the vacation rental process;

to operate, protect, improve and optimize the Platform, Vreasy’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Vreasy, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your Vreasy Account;

to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Vreasy or our Third Party business partners; and

to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

How Vreasy Uses and Processes User Communications
We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Vreasy, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

WHEN VREASY DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM
IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries in accordance with this Privacy Policy.

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Platform, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

Vreasy, Inc. complies with the US-Swiss Safe Harbor Framework and principles, as described in its certification (https://safeharbor.export.gov/companyinfo.aspx?loc=swiss&id=32707).

Your Personal Information may be transferred, stored, used, processed and disclosed as follows:

Your public Listing page will always include some minimum information such as the city and neighborhood where the Accommodation is located, your listing description, your calendar availability, your public profile photo, your responsiveness in replying to Guests’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Accommodation’s approximate geographic location on a map, such that a user can see the general area of the Accommodation.

The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.

When you submit a request to book an Accommodation, your full name, and the full name of any confirmed Guests staying with you, and other Personal Information you agree to pass through to the Host(s) will become visible to the Host(s) of any Listing you Book or request to Book. We may also disclose parts of your public profile; your public Wish List; other Member reviews of you; and any additional information you share with other Members..

When your request to book an Accommodation is accepted by the Host(s) or when a Guest books your Accommodation, we will disclose some of your Personal Information to the Host(s) and any confirmed Guest(s). However, your billing and payout information will never be shared with another user.

When a Host accepts your request to book an Accommodation, the Host may elect to use Third-Party services available through the Vreasy platform to assist with managing the Accommodation, such as cleaning, check-in/check-out, and transportation services. The Host may use features on the Vreasy platform to share information about the Guest with that Third-Party service provider for the purposes of coordinating the stay or managing the Accommodation, including check-in and check-out dates, Guest name, Guest’s phone number, and the Guest’s anonymized email address.

We may distribute parts of the Platform (including your Listing) for display on sites operated by Vreasy’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

Vreasy may provide your Personal Information to its Affiliates, including VreasyPay which uses Stripe to process the credit card (https://stripe.com/fr/privacy ), and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. VreasyPay may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom VreasyPay has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your Vreasy account.

We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Stripe and Paypal). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

For any jurisdiction in which we facilitate the Collection and Remittance of Taxes, Hosts and Guests expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Accommodations and Taxes, including, but not limited to, personally identifiable information such as Host or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Hosts from Guests, or allegedly due, contact information and similar information, to the relevant Tax Authority.

You acknowledge, consent and agree that Vreasy may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Vreasy; (b) to comply with legal process (for example, subpoenas and warrants), including legal process associated with national security and law enforcement; (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy, and the Host Guarantee Terms and Conditions; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Vreasy, its users or members of the public.

We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or

we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Vreasy’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).

In instances where Vreasy complies with legal requests for user data without notice to the user for the reasons described above, Vreasy will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

STATE PRIVACY LAWS
For California & Vermont residents: VreasyPay will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.

HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR VREASY ACCOUNT
You may review, update, correct or delete the Personal Information in your Vreasy Account. If you would like to correct your information or cancel your Vreasy Account entirely, you can do so by logging in to your Vreasy Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Vreasy Account is cancelled.

SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
The Platform will contain links to other websites not owned or controlled by Vreasy. Vreasy does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located atwww.google.com/privacy.html), as may be amended by Google from time to time

CHANGES TO THIS PRIVACY POLICY
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Vreasy Account. You can find out more about how to deactivate your Vreasy Account at www.Vreasy.com/help.

GOT FEEDBACK?
Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at help@Vreasy.com.

FOR USERS RESIDING IN THE EU AND JAPAN ONLY: YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION
If you reside in the EU or Japan, you may request in writing copies of your Personal Information held by us. We will provide you with a copy of the Personal Information held by us as soon as practicable and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may also request proof of identification to verify your access request. All requests should be addressed to our Data Protection Compliance Officer, Vreasy, Calle Zamora 46, Barcelona 08005 Spain.

We endeavor to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your valid request that the relevant action has been taken.

You may also request the erasure of your Personal Information if you believe we are otherwise in breach of relevant data protection legislation. All requests should be addressed to our Data Protection Compliance Officer, Vreasy, Calle Zamora 46, Barcelona 08005 Spain. There is no charge for making such a request.

FOR USERS RESIDING IN THE EU: YOUR RIGHT TO SEE AND CHALLENGE INFORMATION PROVIDED TO US BY THIRD PARTIES
You are entitled to see and challenge any information that Third Parties may provide to us as part of our fraud detection, prevention and risk assessment efforts in circumstances where all of the following factors apply: (i) if we use Third Parties to carry out automated checks or risk assessments, and (ii) if we make a decision which has legal consequences for you or which significantly affects you, and (iii) if such decision is based solely on such automated checks or risk assessments. In order to request this, please address your request directly to Data Protection Compliance Officer, Vreasy, Calle Zamora 46, Barcelona 08005 Spain. Please state clearly in your request that you wish to see and/or challenge the information that Third Parties may have provided to Vreasy as part of our fraud detection, prevention and risk assessment efforts. We may request proof of identification to verify your request.

Vreasy is subject to the authority of the Federal Trade Commission and has certified with the Privacy Shield as required by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union member countries. Vreasy certifies that it adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. Consistent with these principles, where Vreasy uses service providers to process personal data of European Union residents, Vreasy shall remain liable where the agent processes such personal data of European Union residents in a manner inconsistent with the Privacy Shield principles, except where Vreasy establishes that Vreasy is not responsible for the damages caused by the agent. To learn more about the Privacy Shield program, and to view the list of entities who have current certifications under the Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield List.

If you have any questions or complaints about Vreasy’s privacy practices, you may contact Vreasy at Data Protection Compliance Officer, Vreasy, Calle Zamora 46, Barcelona 08005 Spain, and we will work with you to resolve your issue. As a resident of the European Union, you may also contact your appropriate European Data Protection Authority with questions or complaints about our privacy practices.

Residents of the European Union who are dissatisfied with the way in which we have addressed your concerns about our privacy practices may seek further assistance from our designated Privacy Shield independent recourse mechanism, JAMS.

Residents of the European Union who have unresolved complaints after: (1) contacting Vreasy to resolve the issue; (2) seeking assistance from our independent recourse mechanism; and (3) contacting the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and giving the Department of Commerce time to attempt to resolve the issue, may elect to arbitrate certain claims. See here for more details. Claims shall be arbitrated free of charge by our arbitration provider, the American Arbitration Association (“AAA”), though each party will be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles only with respect to the individual.