Kashtah Privacy Policy

“Kashtah” ("us", "we", or "our") operates the Kashtah mobile application (hereinafter referred to as the "Service"). This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. DEFINITIONS

Service Service means the Kashtah mobile application operated by Kashtah.
Personal Data Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies Cookies are small files stored on your device (computer or mobile device) We collect several different types of information for various purposes to provide and improve our Service to you.

2. PERSONAL INFORMATION WE COLLECT

2.1 Information needed to use the Kashtah Platform. We collect personal information about you when you use the Kashtah Platform. Without it, we may not be able to provide you with all services requested. This information includes:
• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:
• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the Kashtah Platform and our Payment Services.

When you use the Kashtah Platform and Payment Services, we automatically collect personal information. This information may include:
• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Kashtah Platform.
• Log Data and Device Information. Such as details about how you’ve used the Kashtah 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, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Kashtah Platform. We may collect this information even if you haven’t created a Kashtah account or logged in.
• Cookies and Similar Technologies. In order to ensure the improvement of User experience, User's web browser puts cookies on their hard drive for the sake of record-keeping and sometimes to track information about them. User may decide to set their web browser to decline cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:.
• Third-Party Services. If you link, connect, or login to the Kashtah Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information. For Members in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. 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 may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals and co-travelers. If you are invited to the Kashtah Platform such as a co-traveler on a trip, the person who invited you can 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 references, demographic data or information to help detect fraud and safety issues 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 or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Kashtah Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

3. HOW WE USE INFORMATION WE COLLECT

Kashtah may collect and use Users personal information for the following purposes: To improve customer service - Information you provide helps us respond to your customer service requests and support needs more efficiently. To personalize user experience - We may use information in the aggregate to analyse how our Users generally use the services and resources available on our Site. To enhance our Site - We may use feedback you present to us to enhance services. To process payments - We may use the information Users present to us about themselves when making an order only to provide service to that order. We don't share this information with outside parties unless to the degree necessary to provide the service. To run a promotion, contest, survey or other Site feature - To send Users information they consented to get about topics or information we believe will be of interest as well as relevant to them. To send periodic emails - We may use the email address to send User information and updates regarding their booking. It may also be used to provide response or feedbacks to their queries, and/or other requests. If User chooses to opt-in to our mailing list, they will get emails that may involve company news, updates, associated product or service information, etc. If at any time the User would want to unsubscribe from getting future emails, we incorporate unsubscribe instructions at the bottom of each email or User may simply contact us through our Site.

4. SHARING & DISCLOSURE

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Kashtah account or participating in promotional activities by Kashtah partners or third parties. Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Kashtah or otherwise promote our products and services.

4.2 Sharing Between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information such as:
• When a booking request is made or dispute is submitted, certain information may be shared between Guest(s) and Host(s), including profile, name, names of any additional Guests, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a booking is confirmed, additional information is shared to assist with coordinating the trip, like profile photo and phone number. When you as a Host have a confirmed booking, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Listing address.
• When you as a Host invite another Member to host with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, calendar, Listing information, Listing photos, and email address.
• When you as a Guest invite additional Guests to a booking, your full name, travel dates, Host name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest.

4.3 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:
• Your public profile page, which includes your profile photo, first name, description, and city.
• Listing pages that include information such as the Accommodation or Experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings and other public feedback.
• Content in a community or discussion forum, blog or social media post.

4.4 Host Service Providers.

Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Kashtah Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third-party service providers.

4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Kashtah, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our agreements with Members, or (v) to protect the rights, property or personal safety of Kashtah, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies. 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 or harm to Kashtah, our Members, or expose Kashtah to a claim of obstruction of justice. For jurisdictions where Kashtah facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, bookings, Accommodations and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information. In jurisdictions where Kashtah facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Kashtah in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.

4.6 Programs with Managers and Owners.

We may share personal information of Hosts and Guests such as booking information, and information related to compliance with applicable laws such as short-term rental laws with landlords, management companies, and/or property owners (the “Building Management”), in order to facilitate programs with Building Management. For example, guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located, to facilitate hosting services, compliance with applicable laws, security, billing, and other services.

4.7 Host Information Provided to Kashtah for Work Customers.

If a booking is designated as being for business or work purpose and (1) is made by a Guest affiliated with an Enterprise, (2) the Enterprise is enrolled in Kashtah for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Accommodation address, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of Kashtah’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.

4.8 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that 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 Kashtah Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Kashtah’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.9 Business Transfers.

If Kashtah undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.10 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the Kashtah Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:
• Sharing with Kashtah, Inc. information will be shared with Kashtah, Inc. which provides the technical infrastructure for the Kashtah Platform.
• Sharing with Kashtah Payments. In order to facilitate payments on or through the Kashtah Platform, certain information will be shared with the relevant Kashtah Payments entity.

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Kashtah Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. We use automated methods where reasonably possible. Occasionally we may need to manually review 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 messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

5.2 Linking Third-Party Accounts.

You can link your Kashtah account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:
• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Kashtah Platform may be displayed to your Friends on the Kashtah Platform and/or that third-party service,
• a link to your public profile on that third-party service may be included in your Kashtah public profile,
• other Kashtah users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Kashtah users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes,
• publication and display of information that you provide to the Kashtah Platform through this linkage is subject to your settings and authorizations on the Kashtah Platform and the third-party service.

5.3 Third-Party Partners & Integrations.

Users may see or notice advertising or other content on our Site that link to the sites and services of our advertisers, partners, suppliers, licensors, sponsors and other third parties. We don't control or manage the content or links that show on these sites and are not responsible for the methods used by websites associated to our Site. Also, these sites or services, including their content and links, may be continually changing. These sites and services may possess their own terms, privacy policies as well as customer service policies. Browsing and using any other website, including websites which have a link to our Site, is governed by that website's own terms and policies.

6. YOUR RIGHTS

6.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Kashtah Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

6.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

6.3 Data Erasure.

In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Kashtah Account for fraud or safety reasons, we may retain information from that Kashtah Account to prevent that Member from opening a new Kashtah Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Kashtah and Kashtah Payments may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Kashtah, even after your Kashtah Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we take measures to protect data 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.

7. SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.

8. CHANGES TO THIS PRIVACY POLICY

Kashtah reserves the right to update this privacy policy at any time based on sole discretion. When we do, we will post a notification on the main page of our Site, and also modify the updated date at the bottom of this page. We advise Users to regularly check this page for any modifications to stay informed about how we are helping to protect the personal information we acquire. You acknowledge and accept that it is your responsibility to go through this privacy policy regularly and become aware of any modifications.

9. YOUR ACCEPTANCE OF THESE TERMS

By using this Site, you represent your acceptance of this policy and the terms. If you do not accept this policy, please don't use our Site. Your continued use of the Site following the posting of changes to this policy will be regarded as your acceptance of those changes.