In this policy, we use a few terms which are defined as follows: A “Supplier” is someone who offers services ( “Supplier Services” ) via listings on the HVN Platform ( “Listings” ). A “Guest” is someone who books, or seeks to book, Supplier Services. “Agent” means the one who arranges bookings for a Guest and is acknowledged as a formal representative with authorization to share Guest information and make payments on the Guest’s behalf via the HVN Platform ( Suppliers, Agents, and Guests are Collectively “Members” ). “Accommodation” means any property that may be booked for a temporary stay. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the HVN Platform.
1. Information We Collect
There are three general categories of information that we collect.
1.1. Information You Give Us.
We collect information you share with us when you use the HVN Platform in order to ensure the adequate performance of contracts between you and HVN, or between you and a Supplier. The provision of this information is necessary to use the HVN Platform and, without it, we will not be able to provide you with services that you request.
Member Information. When you submit a request for Accommodation booking information, we require certain information such as your first name, last name, email address and phone number. To use certain features within the HVN Platform, we may need to ask you for additional information which may include your address and date of birth.
Identity Verification Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identity verification information (such as images of your government-issued ID, passport, national ID card, or driving license) or other authentication information.
Payment Information. When you use the Payment Services (such as when booking Accommodation or a travel-related experience through us or establishing a Supplier relationship via us), we require certain financial information (like your bank account or credit card information) to process payments and comply with applicable law. If you are a Supplier, we may require identity verification information (such as images of your government issued ID, passport, national ID card, or driver’s license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and comply with applicable law. If you are a Guest, we may retain your financial information to assist you with booking travel-related experiences with third parties.
Communications with HVN. When you communicate with HVN, we collect information about your communication and any information you choose to provide.
You may choose to provide us with additional personal information in order to obtain a better user experience when using the HVN Platform. For example, you may choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate with an HVN representative, conduct a search, respond to surveys, participate in promotions, share your experience with us, or use other features of the HVN Platform.This additional information will be processed based on our legitimate interest or when applicable, your consent.
1.2. Information We Automatically Collect from Your Use of the HVN Platform.
When you use the HVN Platform, we collect information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the HVN Platform.
Usage Information. We collect information about your interactions with the HVN Platform, such as the pages or other content you view, your searches for villas, bookings you have made, the experiences and activities you book with others through us, and other actions on the HVN Platform.
Geo-Location Information. When you use certain features of the HVN Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. HVN may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Log Data. We automatically collect log data and device information when you access and use the HVN Platform, even if you have not created an HVN account or logged in. That information includes, among other things: details about how you’ve used the HVN Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information (e.g., crashes, browser type), unique identifiers, cookie data and the pages you’ve viewed or engaged with before or after using the HVN Platform.
Payment Transaction Information. We collect information related to your payment transactions on the HVN Platform or transactions made through the HVN Platform, including the payment instrument used, the date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, ACH information, your address and other related transaction details.
California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the HVN Platform for third party purposes. You may opt out with any of the following links: the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link; note that we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms. We do not recognize or respond to browser-initiated Do Not Track signals.
1.3. Information We Collect from Third Parties.
We may collect information that others provide about you when they use the HVN Platform, or obtain information from other sources and combine that with information we collect through the HVN Platform. HVN does not control, supervise and is not responsible for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to HVN should be directed to such third parties.
Background Information. For certain Members in the United States, to the extent permitted by applicable laws, HVN may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, HVN may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products (such as programs with property managers and owners or travel agents) may submit personal information to facilitate account management and invitations to use enterprise products.
Referrals. If you are invited to HVN, the person who invited you may submit personal information about you such as your email address or other contact information.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the HVN Platform through partnerships, or about your experiences and interactions from our partner ad networks. For example, if you book a catering service through HVN, the company may send information to us that you submitted to them, like your dining preferences or dining activity.
1.4. Children’s Data
Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us (see Section 10 below).
2. How We Use The Information We Collect
We use, store, and process information about you to (1) provide, understand, improve, and develop the HVN Platform, (2) create and maintain a trusted and safer environment, and (3) provide, personalize, measure, and improve our advertising and marketing.
2.1. Provide, Improve, and Develop the HVN Platform. We may use the personal information to provide, improve, and develop the HVN Platform such as to:
Enable you to access and use the HVN Platform;
Contact you about your booking requests, plan your stay at an Accommodation, and make and manage your bookings;
Enable you to communicate with other Members;
Operate, provide, improve and optimize the HVN Platform and experience, such as by performing analytics and conducting research;
Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier;
Provide customer service;
Send you service or support messages, such as updates, security alerts, and account notifications;
If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any other purpose you authorize at the time of collection;
To operate, protect, improve, and optimize the HVN Platform and experience, and personalize and customize your experience (such as making Accommodation suggestions and ranking search results) and facilitate claims with our Guest and Supplier protection programs, we conduct profiling based on your interactions with the HVN Platform, your search and booking history, any saved account preferences and other content you submit to the HVN Platform; and
Enable your use of our enterprise products.
We process this information given our legitimate interest in improving the HVN Platform and our users’ experience with it, and to ensure the adequate performance of our contract with you.
2.2. Create and Maintain a Trusted and Safer Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:
Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity; Conduct security investigations and risk assessments;
Verify or authenticate information or identification provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide);
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required;
Comply with our legal obligations (such as anti-money laundering regulations);
Resolve any disputes with any of our users and enforce our agreements with third parties.
In connection with the activities above, we may conduct profiling based on your interactions with the HVN Platform, your member information and other content you submit to the HVN Platform, and other information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the HVN Platform if such processes detect activity that we think poses a safety or other risk to the HVN Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us (see Section 10 below).
We process this information given our legitimate interest in protecting the HVN Platform, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about HVN or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google;
Personalize, measure, and improve advertising;
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HVN or its third party business partners;
Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the HVN 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.
Enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with your use of the Services. No fee is charged for sending promotional emails to you, but third-party data rates may apply.
We process this information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
2.4 SMS Terms
If you would like to receive text message communications from HVN, such as booking assistance, customer support or notifications about the Services you can provide your prior express opt in consent in written form (such as over chat). In doing so you expressly authorize HVN to use an autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In. By opting in you confirm that you are the subscriber to the relevant phone number or that you are otherwise authorized to opt in. Opt in is not a condition of purchase. Message and data rates may apply. You can opt out at any time by texting or replying STOP or by contacting us (see Section 10 below).
2.5 Your Choices
You have choices on the promotional messages that you choose to receive. You can limit the information you provide to HVN. Participation in promotions and marketing programs is voluntary. You can limit the communications that HVN sends to you. To opt-out of marketing emails, email [email protected] requesting to unsubscribe or simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of marketing emails, we may still send you booking information or fraud alerts.
Sharing & Disclosure
3.1. Advertising and Social Media: Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in promotional activities conducted by HVN partners or third parties.
Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the HVN Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest.
The social media platforms with which we may share your personal information are not controlled or supervised by HVN. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time, ask HVN to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).
3.2. Sharing between Suppliers, Agents, and Guests.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as a Guest (or representative Agent) submit a booking request, certain information about you may be shared with the Supplier (and Co-Supplier or property owner, if applicable) including your full name, the full name of any additional Guests and Agents, 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 trip, like your phone number.
When you as a Supplier (or Co-Supplier, if applicable) have a confirmed booking, certain information about you may be shared with the Guest (and the additional Guests they may invite and their representative Agent, if applicable) to coordinate the booking, such as your full name, phone number, and Accommodation address.
This information may also be shared with the corporate affiliates of a Member, such as the host agency or corporate travel company through which a Guest or Agent has been given access to the HVN Platform.
We don’t share your billing and payout information with other Members.
3.3. Listings and other Public Information.
The HVN Platform publishes information, including personal information that is visible to the general public. For example, Listing pages are publicly visible and include information such as the Accommodation’s approximate location (neighbourhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, aggregated demand information (like page views over a period of time), and any additional information the Supplier chooses to share.
Based on our legitimate interest to promote the HVN Platform, we may display parts of the HVN Platform (e.g. your Listing page) on sites operated by HVN’s business partners, using technologies such as widgets or APIs.
Information shared publicly on the HVN Platform may be indexed through third party search engines. We do not control the practices of third party search engines.
3.4. Service Providers.
We use a variety of third party service providers to help us provide services related to the HVN Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”).
For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the HVN services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.
3.5. Additional Services by Suppliers.
Suppliers may use third party services available through the HVN Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services, insurance or activities providers. Suppliers may share information about the Guest (like the Guest’s check-in and check-out dates, Guest name, Guest phone number) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services. Suppliers are responsible for third party service providers they use and ensuring those service providers process Guest information securely and in compliance with applicable law including data privacy and data protection laws.
3.6. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the HVN Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon HVN’s property, its Members and the HVN Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so.
3.7. Corporate Affiliates.
To help us provide the HVN Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Additionally, we share your information with our affiliates to support, integrate, promote, and improve the HVN Platform and our affiliates’ services. Our affiliates include Best Rate Villas Inc.
3.8. Tax Authorities.
In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers, Agents, and Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Suppliers’, Agents’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Agents’ or Guest’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.
3.9. Government Registration.
In jurisdictions where HVN facilitates or requires a registration, notification, permit, or license application of a Supplier with a local governmental authority through the HVN Platform in accordance with local law, we may share information of participating Suppliers with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Supplier’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.
3.10. Programs with Managers and Owners.
We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, Guest booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a Supplier lives and/or the Listing is to facilitate hosting services, security, billing, and other services that may be provided.
3.11. Business Transfers.
3.12. Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for industry and market analysis, regulatory compliance, research, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1. Analyzing your Communications.
We may review, scan, or analyze your communications on the HVN 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, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
4.2. Third Party Partners & Integrations
The HVN Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services ( “Third Party Partners” ). HVN doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, HVN, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
4.3 Google Maps/Earth.
5. Your Rights
You may exercise any of the rights described in this section before your applicable HVN Data Controller by contacting us (see Section 10 below). Please note that we may ask you to verify your identity and request before taking further action on your request.
5.1. Managing Your Information.
You may access and update some of your HVN information through your HVN account. You are responsible for keeping your personal information up-to-date.
5.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information about you and which you cannot update yourself.
5.3 Data Access and Portability.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
5.4 Data Retention and Erasure.
We generally retain your information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the HVN Platform to you, you can request that we erase your personal information by contacting us (see Section 10 below). Please note that if you request the erasure of your personal information:
Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the HVN Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
HVN may retain certain information to the extent necessary to comply with its legal obligations. For example, HVN may keep some of your information for tax, legal, reporting and auditing obligations.
HVN may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if HVN suspends a user for fraud or user safety reasons, HVN may retain certain information from that account to prevent that user from using the Services in the future.
5.5 Withdrawing Consent.
If we are processing your personal information based on your consent you may withdraw your consent at any time by contacting us (see Section 10 below) specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
5.6 Restricting Processing.
In some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.7 and pending the verification whether the legitimate grounds of HVN override your own.
5.7 Objecting to Processing.
In some jurisdictions, applicable law may entitle you to require HVN not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, HVN will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask HVN to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).
5.8 Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by HVN before competent data protection authorities.
6. Operating Globally and International Transfers
7. California Residents.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Contact us (see Section 10 below) for information on data subject rights requests and how to submit a request.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.