1. Personal data, purpose and legal basis for processingOur priority is customer data security. We may process only minimal user data, only as much as it is necessary to maintain the Website, App and Services. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.You can access and use the Website, App and Services without leaving any kind of contact information. If, however, you wish to use some of the features on the Website, you may be asked to provide certain personal data (for example, your name, phone number and e-mail address). We receive and store any information you knowingly provide to us when you fill any online forms on the Website. When required, this information may include the following:
Some of the information we collect is directly from you via the Website, App and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website or App.Any of the information we collect from you may be used for the following purposes and processing activities:
Send marketing and promotional communications: If you have signed up for marketing or our newsletter, we may process your name, contact information etc. in order to submit such materials to you. Such processing is based on your consent (GDPR Article 6 (1) (a)) Contact information such as name, email address, address, etc. (GDPR Article 6 (1) f)) Phone number, in order to improve the booking process for both guest and host by including additional communication options. The phone number will only be disclosed when you as a guest are requesting a booking or making a direct booking towards the specific host. If you as a guest haven’t already included your phone number during the signup, we will require it once you are requesting a booking or making a direct booking (GDPR Article 6 (1) b) and f)).
Campanyon may, on a case-by-case-basis, process personal data for other purposes and rely on different legal grounds, such as consent or legitimate interest or, in accordance with applicable data protection law, as set forth in an applicable privacy notice.Campanyon will not use or in any other way process any personal data from files uploaded by users on the platform.
Campanyon may also use geo-targeting services from third parties (please see section 6 of this Policy) to identify the location via the App and Website, in order to provide you with the most suitable and seamless services. Such processing is based on your explicit consent (GDPR Article 6 (1) (a)). Legal obligations: Campanyon may process personal data due to legal obligations applicable to the operation of Campanyon (GDPR Article 6 (1) (c)).
2. Disclosure to third partiesWe will only disclose your personal data to third parties to the extent we have a legal basis for such disclosure.We rely upon affiliated and subsidiaries to assist in the operation of the Website, App and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements.Your phone number will be disclosed to hosts when you are requesting a booking or making a direct booking towards these.Campanyon will not process, store or disclose your personal data outside the EU/EEA.
3. Retention of informationWe will retain and use your personal data for the period necessary to achieve the purposes for which the personal data was collected. Once the retention period expires, Personal Information shall be deleted.The personal data will nevertheless be stored for as long as necessary for Campanyon to fulfill statutory requirements and legal obligations, including requirements for continued storage in accordance with accounting legislation, as well as to the extent necessary to safeguard Campanyon’s rights.
4. The rights of usersYou have the right to do the following: (i) withdraw consent where you have previously given your consent to the processing of your information; (ii) object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) verify the accuracy of your information and ask for it to be updated or corrected; (v) under certain circumstances, restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) under certain circumstances, obtain the erasure of your Personal Information from us; (vii) receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).Any requests to exercise your rights can be directed to Campanyon through the contact details provided in this document. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
7. AdvertisementsWe may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website or App. These companies may deliver ads that might place cookies and otherwise track user behavior.
8. Email marketingWe offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e- mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender.
9. Third party websitesThe Website, App and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website, App and Services and to read the privacy statements of each and every resource that may collect Personal Information.
10. Information securityWe secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody.
11. Data breachIn the event we become aware that the security of the Website, App and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website and App.
12. Changes and amendmentsWe reserve the right to modify this Policy or its terms relating to the Website, App and Services from time to time in our discretion and will notify you of any changes to the way in which we treat Personal Information, either by notification on the webpage, app or by use of your contact information.If we make changes to the processing of personal data that requires your consent, we will obtain your consent before we implement such changed processing.Any other updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified.
13. Privacy terms for users in AustraliaThe following terms will also apply if you access and use the Website and Services from Australia:
- References to ‘personal data’ have the same meaning as ‘personal information’ as defined in the Privacy Act 1988 (Cth).
- We will seek your consent before we collect, use or disclose any information that is sensitive information for the purpose of the Privacy Act 1988 (Cth) unless we are permitted or required to collect, use or disclose that information by law.
- Any concerns about how we handle your personal information can be directed to Campanyon through the contact details provided in this document. We will acknowledge your complaint and provide an estimated timeframe for when we will respond to your complaint. You also have the right to lodge a complaint with the Office of the Australian Information Commissioner.