1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate inactivities on the Services or otherwise when you contact us.The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use.The personal information we collect may include the following:Personal Information Provided by You.
We collect names; phone numbers; email addresses; mailing addresses; contact preferences; billing addresses; debit/credit card numbers; and other similar information.Payment Data.
We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our booking channels (VRBO, AirBnb and Booking.com), our booking channel manager Octorate and PayPal. You may find their privacy notice link(s) here: VRBO:https://www.vrbo.com/legal/privacy-policyAirBnb:https://www.airbnb.com/help/article/2855/privacy-policyBooking.com:https://www.booking.com/content/privacy.en-gb.htmlOctorate: https://www.octorate.com/en/termini-e-condizioni/ PayPal: https://www.paypal.com/va/webapps/mpp/ua/privacy-fullHubspot: https://legal.hubspot.com/privacy-policy
7All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. Even if you do not purchase/book our service. This information does not reveal your specific identity (like your name or contact information)but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referringURLs, device name, country, location, information about who and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes: Log and Usage Data.
Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings). DeviceData.
We collect device data such as information about your computer, phone, tablet or other device you use to access the Services.Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information. LocationData.
We collect information data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information automatically collected through our App
In Short: We collect information regarding your geo-location, mobile device, and push notifications when you use our App.
If you use our App, we also collect the following information: Geo-LocationInformation.
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings. MobileDevice Access.
We may request access or permission to certain features from your mobile device, including your mobile device's contacts, social media accounts, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings. MobileDevice Data.
We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internetservice provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our App you accessed. PushNotifications.
We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.Information collected through our services In Short:
Once you use our services, we collect the information that you provide us, to deliver our services. TheInformation includes personal and payment data.
When you use or request our services, we collect information such as your name, address, contact details, birth date and payment information as well as your information about your stay at one of the apartments owned by MyCataleya LLC; including information about your personal preferences in terms of housing, vacations, leisure and business activities, which we might need in order to deliver or improve our services. Information collected from other sources
We may collect limited data from public databases, marketing partners, and other outside sources
In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), InternetProtocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information fort hese purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.In legal terms, we are generally the "data controller" under European data protection laws since we determine the means and/or purposes of the data processing we perform.However, if you are a business customer with whom we have entered into a dataprocessing agreement for the provision of corporate services to you, then you would be the "data controller" and we would be the "dataprocessor" under European data protection laws since we would be processing data on your behalf in accordance with your instructions.
We use the information we collect or receive:To send administrative information to you.
We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.To protect our Services.
We may use your information as part of our efforts to keep our Services safe and secure(for example, for fraud monitoring and prevention).To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.To respond to legal requests and prevent harm.
If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. Fulfill and manage your orders.
We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.Administer prize draws and competitions.
We may use your information to administer prize draws and competitions when you elect to participate in our competitions.To deliver and facilitate delivery of services to the user.
We may use your information to provide you with the requested service.To respond to user inquiries/offersupport to users.
We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services. To send you marketing and promotional communications.
We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).Deliver targeted advertising to you.
We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:Consent:
We may process your data if you have given us specific consent to use your personal information for a specific purpose.Legitimate Interests:
We may process your data when it is reasonably necessary to achieve our legitimate business interests.Performance of a Contract:
Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.Legal Obligations:
We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).Vital Interests:
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situationsBusiness Transfers.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.Business Partners.
We may share your information with our business partners to offer you certain products, services or promotions.Offer Wall.
Our App may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.
In Short: Yes, we use Google Maps for the purpose of providing better service, which is subject to Google's Terms of Service.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 2 years. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from ourServices is at your own risk. You should only access the Services within a secure environment.8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18years of age.
We do not knowingly solicit data from or market to children under 18 years of age.
By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contactdetails provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you are resident inSwitzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.htmlCookies and similar technologies:
MostWeb browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”)feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Atthis stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light”law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are aCalifornia resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.). CCPA Privacy Notice:
The CaliforniaCode of Regulations defines a "resident" as: (1) every individual whois in the State of California for other than a temporary or transitory purpose and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as "non-residents." If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months. In the following, you find category examples collected:
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name
B. Personal information categories listed in the California Customer Records statute, like Name, contact information, education, employment, employment history and financial information
C. Protected classification characteristics under California or federal law, like gender and date of birth
D. Commercial information, like transaction information, purchase history, financial details and payment information
E. Biometric information, like fingerprints and voiceprints
F. Internet or other similar network activity, like browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements
G. Geolocation data, like device location
H. Audio, electronic, visual, thermal, olfactory, or similar information, like images and audio, video or call recordings created in connection with our business activities
I. Professional or employment-related information, like business contactdetails in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us
J. Education Information, like student records and directory information
K. Inferences drawn from other personal information, like inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of: Receiving help through our customer support channels;Participation in customer surveys or contests; and Facilitation in the delivery of our Services and to respond to your inquiries. How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email email@example.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each serviceprovider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.This is not considered to be "selling" of your personal data.
MyCataleya LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12)months. MyCataleya LLC will not sell personal information in the future belonging to website visitors, users and other consumers.Your rights with respect to your personal dataRight to request deletion of the data -Request to delete
. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.Right to be informed - Request to know
.Depending on the circumstances, you have a right to know:whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information issued; whether we sell your personal information to third parties; the categories of personal information that we sold or disclosed for a business purpose; the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.Right to Non-Discrimination for theExercise of a Consumer's Privacy Rights
. We will not discriminate against you if you exercise your privacy rights.Verification process.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.Other privacy rights
. You may object to the processing of your personal data. You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the data you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.To exercise these rights, you can contact us by email at firstname.lastname@example.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time.
The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact ourData Protection Officer (DPO), Tobias Straube, by email email@example.com, by phone at +4915165743523, or by post to: TobiasStraube, Leipziger Str. 56, 60487 Frankfurt am Main, Hessen, Germany. If you are a resident in the European Economic Area, the "data controller"of your personal information is MyCataleya LLC. MyCataleya LLC has appointedTobias Straube to be its representative in the EEA. You can contact them directly regarding the processing of your information by MyCataleya LLC, bye mail at firstname.lastname@example.org, by visiting www.mycataleya.com, by phone at+4915165743523, or by post to: Tobias Straube, Leipziger Str. 56, 60487Frankfurt am Main, Hessen, Germany.HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?