Last Update: March 18, 2019
Kazay.net respects your right to privacy and takes it seriously. Kazay.net is committed to protecting and securing all personal information that you entrust to us. This Privacy Policy explains who we are, how we collect, use and disclose your personal information, how you can manage the information you share with us and exercise your privacy rights, and how we protect your information. This Privacy Policy covers any personal information you share with us through our online services, including our website, our Application and our online booking APIs (i.e., the online booking tools used by our partners and Owners) (referred to as “Online Services”) or through any other means (collectively referred to as “Services”).
Kazay.net provides an online marketplace for people who are looking for and renting short term vacation properties or posting ads for their properties. It is possible to post ads on properties through our Online Services. Our Customer Service team is available to assist you with any issues you may have in creating listings or making reservations, including complaints.
In this Privacy Policy, the term “Owner” means the owner, lessor or manager of a property who has initiated a listing process for one or more properties on our Online Services. Traveler” means a user who uses the site to view rental properties.
We recommend that you read this entire Privacy Policy to be fully informed. However, if you only wish to access a particular section of this Privacy Policy, you may click on the corresponding quick link in the menu.
If you have any questions or concerns about our use of your personal information, please feel free to contact us through our Customer Service portal found at the end of this policy in the “Contact Us” section.
If any part of our Online Services links you to other websites or Applications, those new links are not covered by this Privacy Policy. Therefore, we encourage you to review the announcements/privacy statements/policies of those other online spaces to understand their practices regarding the collection, use and sharing of personal data.
The personal information we may collect about you falls primarily into the following categories:
We may ask you to share your personal information directly with us. For example, we may ask you to provide us with your contact information, including your full name, telephone number and e-mail address, so that we can :
You will also need to provide your billing information (including your credit card number, cardholder name and expiration date) in order to make your payment.
You may also be asked to provide information about any travelers on your reservation and your marketing preferences, as well as when you participate in a survey or contest. When creating your account, you will be asked to provide a username/email address and a password.
Your personal information may also be linked to cookies in order to ensure the proper functioning of our Online Services, to record your travel searches on our Online Services and to collect information about how you have used our Online Services. For more information, please see our Cookie Policy.
If you are an employee or corporate account, provider or other type of business partner, such as an Owner or travel agent, other information may be collected, including employer, employee identification number or other relevant details.
For Owners: additional personal data may be collected if you wish to place a listing, communicate with a user or Traveler, or when you set up your account data for payment processing.
Certain types of personal information, including certain government-issued identification numbers, your religion, health status or sexual orientation, are considered sensitive and require additional protection under applicable laws. We limit the circumstances in which we may collect sensitive personal information, such as:
If you make a reservation by telephone with our customer service team and, as part of that reservation, you wish to purchase additional travel products on behalf of another person, you will be asked for that person’s personal data. You will need to obtain the consent of any other person before providing us with their personal data. If your travel companions wish to change or delete their information themselves, they may contact us directly using the contact information in the “Contact Us” section at the end of this Privacy Policy.
When you use our Online Services, we may automatically collect certain information from your device. In some countries, including countries in the European Economic Area, this information may be considered personal and subject to applicable data protection laws.
Specifically, the information we collect automatically may include information such as your IP address, device type, unique device ID, browser type (such as Firefox, Safari or Internet Explorer), Internet Service Provider (ISP), operating system and carrier. For website users, details of any referring websites or exit pages, as well as broad geographic locations (for example, your country or city) are also collected.
We may also collect other technical information such as how your device interacted with our Online Services, including pages visited and links opened, i.e., trips taken, and the time and date of your visits.
Collecting this information allows us to better understand the visitors to our Online Services, where they come from, and what content on our Online Services they are interested in. We use this information for internal data analysis purposes and to improve the quality and relevance of our Online Services to our visitors by, for example, personalizing your user experience, tailoring your search results and showing you advertisements that may be of interest to you. We also use this automatic collection of information to prevent and detect fraud.
Some of this information may be collected using cookies and similar tracking technologies, as explained in more detail in the Cookies and Similar Tracking Technologies section.
When you use the App on your smartphone, the App on your tablet, or the App on any other platform (collectively referred to as the “App” or “Applications,” as applicable), we also collect:
information about the functionality of the Applications you access and use. This allows us to identify the parts of the Applications that are of interest to our customers, in order to further refine and improve the Application.
Each Application also sends us the unique device identifier, called a “UID,” a sequence of numbers or characters unique to your device. We will only use this identifier when you first open the Application to confirm to our advertising networks the number of downloads resulting from clicks on their respective banners and other marketing tools. When you provide us with an email address, we associate it with your current UID/cookie ID to provide you with a consistent experience across all of your devices.
Each Application sends us information so that we can analyze it in case of problems or downtime, and improve the Application accordingly. This allows us to study the error and improve the stability of the Application for future releases. In these error reports, the Application provides us with information about the type and version of the mobile device used, the UID/device ID, the time the error occurred, the functionality used, and the status of the Application at the time the error occurred. We use this information exclusively to understand the cause of the error and to find a solution.
You always have the ability to control what information an Application sends us. You can exercise this control by changing the settings on your Application or by changing the settings on your mobile device. You can also remove the Application from your device and choose to access our services through our website.
From time to time, we also legally obtain personal information about you from affiliated entities, business partners and other independent third parties, and add it to the information already in our account. Examples of information we may receive include: updated contact information including email address, purchase history and demographic information.
Social Media: When you use features of our social networks, whether through our Online Services or any other social network, we may access information about you according to the privacy policies of those social network platforms. For example, we offer you the ability to access your account on our website from your Facebook account through the “Facebook Connect” feature, which allows you to access our website without having to manually re-enter your user ID and password.
When you use a social media feature and it is stored in your social media account, we may access data such as your name, profile picture, gender (female/male), date of birth, email address, city of residence or other public information. Depending on your privacy settings, we access information you have provided to your social media outlet regarding your locations (“Location Data”) in order to provide you with relevant content. We do not store or use any data about your friends on social media.
We may also access information from social media through the use of an Application that we post on their site. Therefore, we encourage you to review the privacy policy of any social media you use.
Call Tracking and Recording: Calls to and from our Customer Service teams may be tracked and recorded for quality control, analysis, litigation protection and staff training. Call recordings will be retained in accordance with this Privacy Policy. Any personal information about you obtained during such a call will be handled in accordance with this Privacy Policy.
Other online communications:
Any interactions you may have with us or with Owners through our Online Services, such as chat, will be recorded and tracked for quality control, dispute protection and staff training purposes. Information will be processed and stored in a manner consistent with this Privacy Policy.
When you choose to communicate with an Owner through our Online Services, the relevant Owner will be able to see your name and other data you enter in order to respond to you. These communications are subject to the Travelers Terms and Conditions.
Games We reserve the right to offer games from time to time on our Online Services. These games may involve connectivity with other users or third parties. If this is the case, you consent to the transfer of your personal data accordingly.
We may collect written reviews by Travelers regarding a property in which they have stayed (“Traveler Reviews”) or by Owners regarding a Traveler’s stay (“Owner Reviews”). Traveler Reviews are posted on our site, while Owner Reviews will only be shown to Owners who receive an inquiry or reservation request from a Traveler. Both Owners and Guests must adhere to the Content Guidelines set forth in our Terms of Use. The reviews of the Owners enable the Owners to learn more about the Traveler who has contacted them and thus increase the trust in our platform. Owners must comply with the General Terms and Conditions for Owners and the applicable law. Among other things, they may not use any information about a Traveler for discriminatory purposes. We are not responsible if the Owner discovers your identity through the content of your comments and contacts you directly.
We use cookies and similar tracking technologies (collectively, “Cookies”) to collect and use personal information about you, including for the purpose of displaying advertisements related to your interests. For more information about the type of Cookies we and our service providers use, why, and how to control Cookies, please see our Cookie Policy. We may combine the information you share with us with information related to your transactions and information about you that we receive from third parties performing services on our behalf. Information received through cookies and similar technologies may allow us to cross-reference tracking devices and user click stream data associated with cookies.
In general, we will use the personal information we have collected about you only for the purposes described in this Privacy Policy or for purposes we explain to you at the time we collect your personal information.
We may share your personal information with the following categories of recipients:
If our Online Services have been referred to you through a link on one of our partner’s external sites, we will share your personal data, your browsing activity on our Online Services and your purchase data with them.
If you connect your Kazay.net account to a social media platform such as Facebook Connect, we may make available on that social media platform any information related to your use of our Services, such as rewards and loyalty programs we may have in place, or reviews you post on our online Services. Such information may also be posted on your social media sites or services. The information made available on this social media platform will be attributed to the social media account corresponding to the one that is linked to your Kazay.net account by the corresponding feature.
You will be able to choose to suppress any automatic posting from this social media platform by changing your privacy settings on this platform. We will not provide any access to your Kazay.net account number or account information to any social network provider. If you log in to Kazay.net through a social network account, certain data from that platform – such as your profile picture and your name – will be visible to other customers registered on Kazay.net. You can choose to prevent the sharing of such information by changing your privacy and security settings on your social media account.
We are unable to list all specific recipients in this Privacy Policy due to the number of recipients and the frequency with which this information changes. Categories of recipients are explained in more detail in the sub-paragraphs of the section above, such as travel suppliers such as properties, hotels, car rental companies, and activity providers that allow us to complete your reservation. If you have any questions regarding data sharing with third parties, you may contact us by following the instructions provided at the end of this Privacy Policy.
From time to time, we also share aggregated or anonymous information with third parties, including advertisers and investors. For example, we may share with our advertisers the number of visitors to our website or the most popular vacation properties and destinations. This data does not contain any personal information and is used to develop content and services that we hope will be of interest to our customers.
Our legal basis for processing personal information (EEA visitors only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information involved and the specific context of collection.
As a general rule, we will only collect your personal information (i) when we need your personal information in order to enter into a contract with you, (ii) when processing is in our legitimate interest and does not infringe your rights or (iii) when you have consented to it. In some cases, we will have a legal obligation to collect your personal information, such as when we need to use your transaction history to meet our financial and tax obligations as required by law.
If we ask you to provide us with your personal information in order to meet legal requirements or to enter into a contract with you, we will tell you at the appropriate time whether or not you are required to provide us with your personal information (and the possible consequences of not doing so).
If we collect or use your personal information based on our (or a third party’s) legitimate interests, those interests will generally be in the operation of our platform and the communications we establish with you, which are necessary for the provision of our services, for security screening purposes when you contact us, and for our legitimate business interests, including responding to your inquiries, improving our platform, conducting business, or to detect or prevent illegal activity. We may have other legitimate interests and, if so, we will tell you at the appropriate time what those legitimate interests are.
How do we determine what our legitimate business interests are ?
We conduct an assessment to ensure that:
(i) Our interest in using your data is legitimate (i.e. we have a clear business need); and
(ii) the business need, on balance, does not infringe on your right to privacy.
To do this, we assess the potential impact that a specific use of the data may have on you as a customer and weigh it against our own business needs to ensure that we strike the right balance. We also apply a series of security measures to minimize any potential risk.
For example, we may, in practice, consider the collection of our customers’ business preferences during a booking to be a legitimate business interest for an online e-commerce company. We believe that this practice does not unduly impact your right to privacy, as it is more than likely that you will want to know more about our products and services in the future. However, in order to protect your right to privacy, we ensure that you are able to unsubscribe from these communications at any time, either in the email itself or through our Customer Service department.
In accordance with the above legal basis, we use the information we collect to:
If you have any questions or would like more information about the legal basis on which we collect and use your personal information, you may contact us using the contact information at the end of this Privacy Policy.
It is important to us that you feel secure when using our Online Services to plan your travels, and we are committed to protecting the information we collect. While no Online Service can guarantee you absolute security, we have implemented appropriate technical and organizational measures to protect the personal information about you that we collect and process. For example, we use encryption technology when transmitting your sensitive personal information from your system to ours, and we use firewalls and intrusion detection systems to prevent unauthorized access to your information. In addition, only authorized employees may access personal information, and they may do so only for authorized business purposes.
Your personal information may be transferred to and processed in countries other than the country in which you reside and outside the EEA. These countries may have data protection laws that are different from the laws in your country (and may not offer the same level of protection).
Specifically, our Online Services servers are located in the United States and our group companies and third parties operate worldwide. This means that when we collect your personal information, we may process it in all of these countries.
We have put in place appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy when transferred outside the EEA. All transfers between our group companies are subject to a group agreement which incorporates strict conditions on data transfer and has been approved by the European Commission (known as the Standard Contractual Clauses) and requires all group companies to protect personal information from the EEA that they process in accordance with European Union data protection law.
We ensure that all our third party service providers to whom data is transferred have appropriate safeguards in place to protect your personal information. The appropriate mechanism may be: i an adequate country status, i.e., based in a country deemed “adequate” by the European Commission because its data protection standards are aligned with those of the European Union; ii Standard Contractual Clauses; or iii the EU-U.S. and Switzerland-U.S. Data Protection Shield.
We retain the personal information about you that we collect in case we have a legitimate ongoing business need (for example, to provide a service you have requested or to comply with legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize your data or, if that is not possible (for example, if your personal information has been stored in a backup archive), we will keep your personal information secure and separate from any further processing until it can be deleted.
We will anonymize or aggregate your data if we intend to use it for analysis or trend analysis over longer periods.
You can access or update your contact information in the Account section of our Online Services. You may deactivate your account at any time by contacting us through the Customer Service Portal. Please note that if you deactivate an account, you will not be able to log in or access your personal information. However, you can always open a new account at any time.
If you wish to delete your data, please contact us via the Customer Service Portal.
If you wish to contact us regarding a personal data that does not appear in your account, you can contact us via the Customer Service Portal.
Your data protection rights [EEA residents].
If you reside in the European Economic Area, you have the following data protection rights:
The easiest way to send us your request is through the Customer Service Portal found in the “Contact Us” section at the end of this Privacy Policy.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Data collected by this website to provide you with relevant advertisements. We want to provide you with relevant content and information. To do this, we may collect information about your travel-related searches, such as property or hotel searches, through cookies and other technologies. We use this information, in combination with other information we collect about you, to provide you with more relevant advertisements on our website, on the Internet and on other devices you may use. For example, if you search for a property in London on this website, you may see an advertisement for a London package when you visit our website or another website.
You can opt out of receiving personalized advertisements on other websites based on your travel-related searches on this website and learn more if you opt out of having your information used for personalized advertisements by accessing one of the following resources:
that if you choose not to receive targeted advertisements, advertisements will still be displayed, but they will be more general and less relevant.
Data collected by business partners and ad networks to serve you relevant ads. The ads displayed on this website are served by us or our service providers. However, we may also allow certain third parties to collect information about your online activities through cookies and other technologies. These include (1) business partners who collect data when you view or click on one of their advertisements on our websites; and (2) ad networks, which collect data about what you are interested in when you view or click on one of the advertisements they serve on various websites. The data collected by these third parties is used to predict what you are like, interested in, or prefer, and to serve targeted advertisements based on your interests on our websites and elsewhere on the Internet. For more information, please see our Cookie Policy.
Please be aware that we do not have access to or control over cookies and other technologies used by these third parties to collect data about your interests. In addition, the data practices of these third parties are not covered by this Privacy Policy. Some of these companies belong to the Network Advertising Initiative, which provides a single page where you can opt out of targeted advertising from member companies.
Data collected by companies using cookie-based exchanges to serve you relevant advertisements. Like other companies operating online, we participate in cookie-based trading. This is the collection of anonymous data about your browser activity using cookies and other technologies, and then segmented into different areas of interest (such as travel). These interests are then shared with certain third parties, including advertisers and ad networks, to enable them to serve you ads that are tailored to what you seem to be interested in. We do not allow these companies to collect personal data (such as your e-mail address) on our website, nor do we share any of this data with them. Please click here for more information about cookie-based exchanges, including how to access cookie-related interest information on your computer and how to opt out of these programs.
Do Not Track” signals and similar mechanisms. Some browsers may transmit a “Do Not Track” signal to websites during navigation. Because of differences in how browsers manage and enable this feature, it is sometimes difficult to know whether users are sending these signals voluntarily or are even aware of them. The participants in the main Internet standards body that are interested in this problem are currently working to define the behavior that websites should adopt if they receive this type of signal. Currently, we are not responding to these signals. If a standard were to be established and accepted, we would redefine our response to these signals accordingly.
Updates to this Privacy Policy
Changes to this Privacy Policy will be made, as appropriate, in response to local, technical or business developments. We will take appropriate steps to notify you of updates to our Privacy Policy, taking into account the significance of the changes. We will seek your consent to any changes to our Privacy Policy if and where required by applicable data protection laws.
You can see when this Privacy Policy was last updated by looking at the “Last Updated” date at the top of this Privacy Policy.
If you have any questions about changes to this Privacy Policy, you can contact us through the Customer Service Portal.
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