Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Text with EEA relevance).
Protecting your privacy is important to Naples Villas. We strive to keep your personal information confidential.
Please take a moment to read the following policy to learn how we handle your personal information.
Last Updated: May 2018
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 Naples Villas’ Platform.
We ask for and collect the following personal information about you when you use the Naples Villas 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 a Naples Villas’ Account, we require certain information such as your first name, last name, email address.
Profile Information. To use certain features of the Naples Villas’ Platform (such as booking), we may ask you to provide additional information, which may include your address, phone number.
Payment Information. To use certain features of Naples Villas’ Platform (such as booking), 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 Naples Villas and other Members. When you communicate with Naples Villas, 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 Naples Villas’ Platform. This additional information will be processed based on your consent.
1.1.3 Information that is necessary for the use of the Payment Services.
Payment System 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 system requires 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 Naples Villas’ Platform and Payment Services.
When you use Naples Villas’ 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 Naples Villas’ Platform and Payment Services.
Geo-location Information. When you use certain features of Naples Villas’ 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. Naples Villas 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 Naples Villas’ Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on Naples Villas’ Platform.
Log Data and Device Information. We automatically collect log data and device information when you access and use Naples Villas’ Platform. That information includes, among other things: details about how you’ve used Naples Villas’ 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 Naples Villas’ Platform.
Payment Transaction Information. Naples Villas’ Payments collects information related to your payment transactions through Naples Villas’ Platform, including the 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. This information is necessary for the adequate performance of the contract between you and Naples Villas’ Payments and to allow the provision of the Payment Services.
1.3 Information We Collect from Third Parties.
Naples Villas’ Payments may collect information, including personal information, that others provide about you when they use Naples Villas’ Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through Naples Villas’ 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 or connect to Naples Villas’ with a third party service (e.g. Google, Facebook, Live Chat, Whats App, Twitter or other Social Networks), 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.
Your References. If someone has written a reference for you, it will be published on Naples Villas’ website with your consent. To learn more, use ‘contact us’ on our website.
Background Information. For Members in the United States, to the extent permitted by applicable laws, Naples Villas 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, Naples Villas 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.
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 Naples Villas’ Platform through partnerships, or about your experiences and interactions from our partner ad networks.
2. HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop Naples Villas’ Platform, create and maintain a trusted and safer environment and comply with our legal obligations.
2.1 Provide, Improve, and Develop Naples Villas’ Platform.
Enable you to access and Naples Villas’ Platform.
Operate, protect, improve, and optimize Naples Villas’ 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 contact information, we may process this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any purpose you authorize at the time of collection.
To operate, protect, improve, and optimize Naples Villas’ Platform and experience, and personalize and customize your experience (such as ranking search results), we conduct profiling based on your interactions with Naples Villas’ Platform, your search and booking history, your profile information and preferences, and other content you submit to Naples Villas’ Platform.
We process this information given our legitimate interest in improving Naples Villas’ Platform and our Members’ 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.
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.
Enforce our Terms and Conditions and other policies.
In connection with the activities above, we may conduct profiling based on your interactions with the Naples Villas’ Platform, your profile information and other content you submit to Naples Villas’ Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to Naples Villas’ Platform if such processes detect a Member or activity that we think poses a safety or other risk to Naples Villas’ Platform, other Members, or third parties.
We process this information given our legitimate interest in protecting Naples Villas’ 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 Naples Villas or partner campaigns and services) and social media advertising through social media platforms such as Facebook 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 Naples Villas or its third party partners.
Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with Naples Villas’ 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.
2.4 How the Payment System uses 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.
The Payment System processes 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.
3. 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 Naples Villas’ Account or when you participate in promotional activities conducted by Naples Villas’ partners or third parties.
3.2 Sharing between Affiliates.
To help facilitate bookings, we may need to share certain information, including personal information, with other affiliates, as it is necessary for the adequate performance of the contract between you and us, as follows:
When you as a Guest submit a booking request, certain information about you is shared with the Owner, including your full name, the full name of any additional Guests, 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 Guest initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, as well as the booking details is shared among all participants of the Group Payment Booking Request.
We don’t share your billing and payout information with other Guests.
The Naples Villas’ Platform lets you publish reviews that are visible to the general public. For example:
Your first name, your review and city, are publicly visible to others.
After completing a booking, Guests may write Reviews.
If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Naples Villas’ Platform, that content is publicly visible.
Based on our legitimate interest to promote the Naples Villas’ Platform we may display parts of the Naples Villas’ Platform (e.g., your review) on sites working alongside Naples Villas using technologies such as widgets or APIs. If your reviews are displayed on 3rd party sites, your first name, your review and city, are publicly visible to others.
Information you share publicly on Naples Villas’ Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.4 Additional Services by Owners.
Owners may need to use third party services available through Naples Villas to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services, excursions or transfers. Owners may use features on Naples Villas’ 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 for the purposes of coordinating the stay, managing the Accommodation, or providing other services.
3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Naples Villas and Payment Services 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 Naples Villas, (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 and Conditions, the Payment Terms or other agreements with Owners, or (v) to protect the rights, property or personal safety of Naples Villas’, owners, affiliates or members 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 Naples Villas’ Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
Where appropriate, we may notify you 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 Naples Villas’ property, its Guests and Naples Villas’ Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Guest 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.
Naples Villas and Naples Villas’ Payments use a variety of third party service providers to help us provide services related to the Naples Villas’ Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”).
Naples Villas’ and Naples Villas’ Payments 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 Naples Villas’ 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 Lodgify. Even if your Country of Residence is not the United States, your information may be shared with Lodgify which provides the technical infrastructure for the Naples Villas’ Platform, product development and maintenance, customer support, trust and safety and other business operation services to other Naples Villas’ entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing Naples Villas’ Platform globally.
Sharing with Naples Villas’ Payments. In order to facilitate payments on or through the Naples Villas’ Platform, certain information as described above in Section 1.1.3, may be shared with the relevant Naples Villas’ Payments entity. The data sharing is necessary for the performance of the contract between you and us.
3.8 Collection and Remittance of Occupancy Taxes.
In jurisdictions where Naples Villas facilitates the Collection and Remittance of Occupancy Taxes for example ‘Tourist Tax’, as described in the “Taxes” section of the Terms and Conditions, Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose 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 Guest’s name, accommodation addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) from Guests, and contact information.
3.9 Guest Information Provided to Naples Villas.
If you have booked a property marketed by Naples Villas through a 3rd party site, we may disclose information related to the booking to the extent necessary for the adequate performance of the services. Typically, this includes your name, dates of the booking, number of guests, pricing, the Accommodation address, and other related information. At the request of you, we may also disclose this information to service providers engaged by it, such as companies that provide additional services.
3.10 Business Transfers.
3.11 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.
4. OTHER IMPORTANT INFORMATION
4.1 Analyzing your Communications.
We may review, scan, or analyze your communications on Naples Villas’ 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 Naples Villas’ 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.
5. THIRD PARTY PARTNERS & INTEGRATIONS
The Naples Villas’ 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”). Naples Villas 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, Naples Villas, 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.
6. YOUR RIGHTS
You may exercise any of the rights described in this section by sending an email to firstname.lastname@example.org Please note that we may ask you to verify your identity before taking further action on your request.
6.1 Managing Your Information.
You may access and update some of your information through your Account settings. If you have chosen to connect your Naples Villas’ 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.
6.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Naples Villas’ Account).
6.3 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).
6.4 Data Retention and Erasure.
We generally retain your personal 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 Naples Villas’ Platform to you, you can request that we erase your personal information and close your Naples Villas’ Account. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Naples Villas’ Account for fraud or safety reasons, we may retain certain information from that Naples Villas’ Account to prevent that Guest from opening a new Naples Villas’ Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Naples Villas’ Payment System may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on Naples Villas’ Platform, even after your Naples Villas’ Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain Naples Villas’ 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.
6.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by Naples Villas you may withdraw your consent at any time by changing your Account settings or by sending a communication to Naples Villas 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. Additionally, 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 6.6 and pending the verification whether the legitimate grounds of Naples Villas override your own.
6.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require Naples Villas and Naples Villas’ Payment Systems not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing Naples Villas and Naples Villas’ Payment Systems 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 Naples Villas to cease processing your data for these direct marketing purposes by sending an e-mail to email@example.com
6.7 Lodging Complaints.
You have the right to lodge complaints about the data processing activities carried out by Naples Villas and Naples Villas’ Payment Systems before the competent data protection authorities.
7. OPERATING GLOBALLY
7.1 Other Means to Ensure an Adequate Level of Data Protection.
If Naples Villas is the Data Controller and your information is shared with corporate affiliates or third party service providers outside the EEA, we have - prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on 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. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Naples Villas’ Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Naples Villas’ Account, please contact us following the instructions in the Contact Us section below.
10. CONTACT US
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