Last Updated: August 13, 2018

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Emparty Platform and the Payment Services.

If you see an undefined term in this Privacy Policy (such as “Listing” or “Emparty Platform”), it has the same definition as in our Terms of Service or our Payment Terms.

When this policy mentions “Emparty,” “we,” “us,” or “our,” it refers to Emparty Inc.

  1. INFORMATION WE COLLECT

There are three general categories of information we collect.

1.1 Information You Give to Us.

1.1.1 Information that is necessary for the use of the Emparty Platform.

We ask for and collect the following personal information about you when you use the Emparty Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

  • Account Information. When you sign up for an Emparty Account, we require certain information such as your first name, last name, and email address.
  • Profile and Listing Information. To use certain features of the Emparty Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
  • Payment Information. To use certain features of the Emparty Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
  • Communications with Emparty and other Users. When you communicate with Emparty or use the Emparty Platform to communicate with other Users, we collect information about your communication and any information you choose to provide.

1.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using Emparty Platform. This additional information will be processed based on your consent.

  • Additional Profile Information. You may choose to provide additional information as part of your Emparty profile (such as gender, city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
  • Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the Emparty Platform, like inviting them to use Emparty.
  • Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Emparty Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Emparty Platform.

1.1.3 Information that is necessary for the use of the Payment Services.

The Payment Entities need to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

  • Payment Information. When you use the Payment Services, the Payment Entities require certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.

1.2 Information We Automatically Collect from Your Use of the Emparty Platform and Payment Services.

When you use the Emparty Platform and the Payment Services, we automatically collect information, including personal 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 Emparty Platform and Payment Services.

  • Geo-location Information. When you use certain features of the Emparty 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. Emparty may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
  • Usage Information. We collect information about your interactions with the Emparty Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Emparty Platform.
  • Log Data and Device Information. We automatically collect log data and device information when you access and use the Emparty Platform, even if you have not created an Emparty Account or logged in. That information includes, among other things: details about how you’ve used the Emparty 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 Emparty Platform.
  • Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Emparty Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, the Emparty Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. For more information on our use of these technologies, see our Cookie Policy.
  • Payment Transaction Information. Emparty and the Payment Entities collectinformation related to your payment transactions through the Emparty Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Empartyand to allow the provision of the Payment Services.

1.3 Information We Collect from Third Parties.

Emparty and the Payment Entities may collect information, including personal information, that others provide about you when they use the Emparty Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Emparty Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • Third Party Services. If you link, connect, or login to your Emparty Account with a third-party service (e.g. Google, Facebook, Instagram), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  • 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 Emparty Platform through partnerships, or about your experiences and interactions from our partner ad networks.
  1. HOW WE USE INFORMATION WE COLLECT 

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Emparty Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

2.1 Provide, Improve, and Develop the Emparty Platform.  

  • Enable you to access and use the Emparty Platform.
  • Enable you to communicate with other Users.
  • Operate, protect, improve, and optimize the Emparty Platform and experience, such as by performing analytics and conducting research.
  • Provide customer service.
  • Send you service or support messages, updates, security alerts, and account notifications.
  • If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.
  • To operate, protect, improve, and optimize the Emparty Platform and experience, and personalize and customize your experience (such as making Listing suggestions or ranking search results), we conduct profiling based on your interactions with the Emparty Platform, your search and booking history, your profile information and preferences, and other content you submit to the Emparty Platform.

We process this information given our legitimate interest in improving the Emparty Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and Maintain a Trusted and Safer Environment. 

  • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
  • Conduct security investigations and risk assessments.
  • Verify or authenticate information or identifications 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.
  • Resolve any disputes with any of our Users and enforce our agreements with third parties.
  • Enforce our Terms of Service and other policies.
  • In connection with the activities above, we may conduct profiling based on your interactions with the Emparty Platform, your profile information and other content you submit to the Emparty Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Emparty Platform if such processes detect a User or activity that we think poses a safety or other risk to the Emparty Platform, other Users, or third parties.

We process this information given our legitimate interest in protecting the Emparty Platform, to measure 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. 

  • Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Emparty or partner campaigns and services) and social media advertising through social media platforms such as Facebook, Instagram, or Google).
  • Personalize, measure, and improve our advertising.
  • Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Emparty or its third party partners.
  • Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Emparty 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.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Emparty Account.

2.4 How the Emparty and the Payment Entities use the Information Collected.

  • Enable you to access and use the Payment Services.
  • Detect and prevent fraud, abuse, security incidents, and other harmful activity.
  • Conduct security investigations and risk assessments.
  • Conduct checks against databases and other information sources.
  • Comply with legal obligations (such as anti-money laundering regulations).
  • Enforce the Payment Terms and other payment policies.
  • With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

Emparty and the Payment Entities process this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

  1. SHARING & DISCLOSURE

3.1 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 authorize a third-party application or website to access your Emparty Account or when you participate in promotional activities conducted by Emparty partners or third parties.

3.2 Sharing between Users. 

To help facilitate bookings or other interactions between Users, we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate performance of the contract between you and us, as follows:

  • When you as an Organizer submit a booking request, certain information about you is shared with the Provider, including your full name, the full name of any additional Organizers, 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 event, like your phone number.
  • When you as a Provider have a confirmed booking, certain information is shared with the Organizer to coordinate the booking, such as your full name, phone number, and details related to your event.
  • When you as an Organizer invite additional Organizers to a booking, your full name, event dates, Provider name, event details, guest list, and other related information will be shared with each additional Organizer.

We don’t share your billing and payout information with other Users.

3.3 Profiles, Listings, and other Public Information. 

The Emparty Platform lets you publish information, including personal information, that is visible to the general public. For example:

  • Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
  • Listing pages are publicly visible and include information such as the Venue or business location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
  • After completing a booking, Organizers and Providers may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Emparty Platform (such as the Listing page).
  • If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Emparty Platform, that content is publicly visible.

Based on our legitimate interest to promote the Emparty Platform we may display parts of the Emparty Platform (e.g., your Listing page) on sites operated by Emparty’s business partners, using technologies such as widgets or APIs. Ifyour Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

Information you share publicly on the Emparty Platform may be indexed through third party search engines. We do not control the practices of third party search engines.

3.4 Additional Services by Providers. 

Providers may need to use third party services available through the Emparty Platform to assist with managing their Venue, Catering, Entertainment, Rental or providing additional services. Providers may use features on the Emparty Platform to share information about the Organizer (like event dates, Organizer name, Organizer phone number, guest information) with such third party service providers for the purposes of coordinating the stay, managing the event, or providing other services.

3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights. 

Emparty and the Payment Entities may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Emparty, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Users, or (v) to protect the rights, property or personal safety of Emparty, its employees, its Users, or Users of the public.

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 Emparty Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

Where appropriate, we may notify Users 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 Emparty’s property, its Users and the Emparty Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.6 Service Providers. 

Emparty and the Payment Entities uses a variety of third party service providers to help us provide services related to the Emparty Platform and the Payment Services.

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 Emparty Services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

Emparty and the Payment Entities will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.7 Corporate Affiliates. 

To enable or support us in providing the Emparty Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.

  • Sharing with Emparty PaymentsIn order to facilitate payments on or through the Emparty Platform, certain information as described above in Section 1.1.3, may be shared with the relevant Payment Entities. The data sharing is necessary for the performance of the contract between you and us.

 

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Emparty Platform and our affiliates’ services.

3.8 Social Media Platforms.

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 Emparty Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Emparty. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask Emparty to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@emparty.com.

 

3.9 Business Transfers. 

If Emparty 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.

3.10 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 regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

  1. OTHER IMPORTANT INFORMATION 

4.1 Analyzing your Communications. 

We may review, scan, or analyze your communications on the Emparty 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.

These activities are carried out based on Emparty’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2 Linking Third Party Accounts. 

You may link your Emparty Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.”  When you create this link:

  • some of the information you provide to us from the linking of your accounts may be published on your Emparty Account profile;
  • your activities on the Emparty Platform may be displayed to your Friends on the Emparty Platform and/or that third party site;
  • a link to your public profile on that third party social networking service may be included in your Emparty public profile;
  • other Emparty users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;
  • other Emparty 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;
  • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
  • the publication and display of information that you provide to Emparty through this linkage is subject to your settings and authorizations on the Emparty Platform and the third party site.

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

4.3 Google Maps/Earth. 

Parts of the Emparty Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

  1. THIRD PARTY PARTNERS & INTEGRATIONS

The Emparty 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”). Emparty 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, Emparty, 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.

  1. Account Settings

Youmay access and update some of your information through your Account settings. If you have chosen to connect your Emparty Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

  1. California & Vermont Residents. 

Emparty and the Payment Entities will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

  1. California Privacy Rights.

California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact” section for where to send such requests. Emparty and the Payment Entities do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.

  1. SECURITY 

We use technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are intended to provide a level of security appropriate to the risk of processing your personal information.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us or from our products or services.

  1. CHANGES TO THIS PRIVACY POLICY 

Emparty reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Emparty Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Emparty Platform will be subject to the revised Privacy Policy.

  1. CONTACT US

If you have any questions or complaints about this Privacy Policy or Emparty’s information handling practices, you may email us at privacy@emparty.com.