The Platform offers online travel-related services through our own websites and mobile apps, as well as through other online Platforms such as partners' websites and social media. All the information that follows applies to not one, not two, but all of these platforms. Several platforms, one privacy statement. This Policy applies to any kind of information we collect through these Platforms or other means connected to these Platforms (such as contacting our customer service team via email).
The information that's shared with us helps us to provide a great experience with the Platform. We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of the Members. We are firmly committed to protecting the privacy and confidentiality of personal information with various physical, electronic and procedural safeguards. If Members' disagree with this Policy, use of the Platform and our services should be discontinued immediately.
If you see a capitalized and undefined term in this Policy (such as "Platform" or "Member"), it has the same definition as in our Terms and Conditions ("Terms").
2. What personal information do we collect?
Generally, the type of personal information we collect about Members is the information that is needed to facilitate the travel arrangements and bookings and to arrange the Services and other travel related services and/or products on the Member's behalf.
We therefore typically process the following types of personal information about Members:
- Account Information. When Members' sign up for a Platform Account, we require certain information such as first name, last name, email address, and date of birth.
- Profile and Listing Information. To use certain features of the Platform (such as booking or creating a listing), we may ask Member to provide additional information, which may include address, phone number, and a profile picture.
- Payment Account Information. To use certain features of the Platform (such as booking or creating a listing), we may require Member to provide certain financial information (like Member's bank account or credit/debit card information, including card type, card number, security number and expiry date) in order to facilitate the processing of payments;
- Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information. For a Host, during the payments process, we may require identity verification information (such as images of government issued ID, passport, national ID card, or driving license) or other authentication information, such as date of birth, address, email address, phone number and other information in order to verify the identity and to provide the payment services to the Host, and to comply with applicable law.
- Information about dietary requirements and health issues (if any);
- Communications with Ibex Smart Communications and other Members. When Members make contact with us for other purposes or use the Platform to communicate with other Members, we may also collect personal information about Members in relation to those purposes. For example, we may collect personal information so we can respond to an enquiry or feedback that has been sent to us.
- Additional Profile Information. Members may choose to provide additional information as part of the Platform profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in the Platform Account settings is part of the public profile page, and will be publicly visible to others.
- Address Book Contact Information. Members may choose to import their address book contacts or enter the contacts' information manually to access certain features of the Platform, like inviting them to use the Platform.
- Other Information. Members may otherwise choose to provide us information when Members fill in a form, update or add information to the Platform Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share experiences with us, or use other features of the Platform.
We also collect information that is required for use in the business activities of Ibex Smart Communications for the Platform including for example, financial details necessary in order to process various transactions and other relevant personal information Members may elect to provide to us.
In some circumstances, we may collect personal information from Members which may be regarded as sensitive information. Sensitive information may include (without limitation) racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, and health information. We will only collect sensitive information with Member's explicit consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorized to do so by law. To the extent permitted or required under applicable laws, Member's consent to us using and disclosing sensitive information for the purpose for which it was collected, unless we subsequently receive consent to use it for another purpose.
3. How do we collect personal information?
We will only collect personal information in compliance with applicable data protection laws. We usually collect personal information from the information submitted during the course of the Member's relationship with us. Generally, this collection will occur when Members:
- Contact us in person, by telephone, letter, email;
- Visit our websites;
- Connect with us on social media.
We may collect personal information about Members when:
- Purchases or enquiries are made about travel arrangements or other products and Services;
- Competitions are entered into or registrations for promotions;
- Subscribing to receive marketing from us (e.g. e-newsletters);
- Requesting brochures or other information from us; or
- Providing information, using our services, or on social media.
3.1 Information We Automatically Collect from Use of the Platform and payment services.
When Members use the Platform and the payment services, we automatically collect personal information about the Services used and how they are used. This information is necessary for the adequate performance of the Services, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Platform and payment services.
- Geo-location Information. When using certain features of the Platform, we may collect information about the precise or approximate location as determined through data such as the IP address or mobile device's GPS to offer an improved Member experience. Most mobile devices allow the control or disable the use of location services for applications in the device's settings menu. Ibex Smart Communications may also collect this information even when Members are not using the app if this connection is enabled through the settings or device permissions.
- Usage Information. We collect information about interactions with the Platform such as the pages or content viewed, searches for listings, bookings made, and other actions on the Platform.
- Log Data and Device Information. We automatically collect log data and device information when Members' access and use the Platform, even if they have not created a Platform Account or logged in. That information includes, among other things: details about how the Platform is being used (including clicking 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 viewed or engaged with before or after using the Platform.
- Payment Transaction Information. Ibex Smart Communications collects information related to payment transactions through the Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, address and other related transaction details. This information is necessary for the adequate performance of the Services and to allow the provision of the payment services.
3.2 Information We Collect from Third Parties.
In some circumstances, it may be necessary for us to collect personal information about Members from a third party including personal information, that others provide when they use the Platform and the payment services, or obtain information from other sources and combine that with information we collect through the Platform and the payment services. Such scenarios, inter alia, may include where a person makes a travel booking on a Member's behalf which includes travel arrangements to be used by the said Member, and vice versa (i.e. a group booking made for the Member by a friend or a group booking made for a friend by the Member). Where this occurs, we will rely on the authority of the person making the travel booking as the ‘Lead Member' to act on behalf of any other Member/guest on the booking. The Lead Member agrees to have obtained the consent of the other person for Ibex Smart Communications to collect, use and disclose the other person's personal information in accordance with this Policy.
We do not control, supervise or respond for how the third parties providing the Member's information process the personal information, and any information request regarding the disclosure of the Member's personal information to us should be directed to such third parties.
- Third Party Services. If Member links, connect, or login to the Platform Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by the Member via the privacy settings at that service.
- Member References. If someone has written a reference for a Member, it will be published on the Member's Platform public profile page with consent.
- Background Information. To the extent permitted by applicable laws and with Member consent where required, Ibex Smart Communications may obtain the local version of police, background or registered sex offender checks. We may use the information, including the full name and date of birth, to obtain such reports.
- Referrals. If a person is invited to use/join the Platform, the person who invited the other person may submit personal information such as the email address or other contact information.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about Members, such as 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. For example, we may receive background check results (with Member 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 Members and the activities on and off the Platform through partnerships, or about Member experiences and interactions from our partner ad networks.
3.3 Children's Data.
Our Platform(s) are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. We only process information about children with the consent of the parents or legal guardians or when the information is provided to use by the parents or legal guardians. If a Member believes that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge the said Member to contact us using the information provided under the "Contact Us" section available on our Platform.
Members should let us know immediately if they become aware that their personal information has been provided to us by another person without their consent or if the Member did not obtain consent before providing another person's personal information to us.
We strive to maintain the accuracy of the Member's personal information that we store, however, Member can assist us with this considerably by promptly contacting us if there are any changes to the personal information or if Members become aware that we have inaccurate personal information relating to them. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that a Member, or a person acting on the Member's behalf, provides to us.
4. How do we use Member's personal information?
We may use, store, and process personal information where:
- consent has been provided to such processing
- the processing is necessary to provide our services, i.e., to provide, understand, improve, and develop the Platform;
- the processing is necessary for compliance with our legal obligations and our Policies such as creating and maintaining a trusted and safer environment;
- the processing is necessary for the provision, personalization, measurement, and improvement our advertising and marketing; and/or
- the processing is necessary for our legitimate interests or those of any third party recipients that receive such personal information.
In detail, when Members contact us in relation to a travel booking or query, we collect personal information generally to provide travel advice and/or to assist Members with booking travel and/or travel related products and the Services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Policy (e.g. collection of personal information for the purpose of participation in a competition, provision of feedback, etc.).
When Members book or when Members otherwise arrange travel related products and Services through us, we usually act as an agent for the relevant travel service providers/Hosts (e.g. for a hotel). In this case, we process personal information as necessary so as to provide the Services that have been requested from us. This usually includes collecting personal information both for our internal purposes as described in this Policy and for the travel service provider/Host for whom we act as an agent (e.g. to provide the booked Services). For example, if Members book pre-accommodation through us, then we use the personal information to enable the accommodation to be booked and disclose it to the hotel solely for this purpose.
We may therefore share Member information with our travel service providers/Hosts such as hotel, airline, car rental, or other providers, who fulfil the travel bookings. We encourage Members to review the privacy policies of any third-party travel service providers/Hosts whose products Members purchase/book through us.
The purposes for which we collect personal information further, inter alia, include:
- Providing Members with the Services and tools (for example, saving travel preferences on our Platform(s) to a wish list or saving personal information to allow for pre-population of online forms);
- Developing and improving our products and Services and those of our related entities;
- Servicing our relationship with the Member by, among other things, providing customer service and creating and maintaining a customer profile to enable our brands to service Members better or presenting options on our Platform we think may interest Members based on their browsing and preferences;
- Involving Members in market research, gauging customer satisfaction and seeking feedback regarding our relationship with the Member and/or the service we have provided to optimize the Platform and experience;
- To facilitate Member participation in loyalty programs and online competitions;
- For internal research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations and use of our Platform(s);
- Internal accounting and administration;
- Identification of fraud or error;
- Regulatory reporting and compliance;
- Compliance with our legal obligations and any applicable customs/immigration requirements relating to the travel;
- enable Members to access and use the Platform,
- enable Members to communicate with other Members,
- send Members service or support messages, updates, security alerts, and account notifications,
- to facilitate referral invitations and to send Member requests for references,
- detect and prevent spam, abuse, security incidents, and other harmful activity,
- conduct security investigations and risk assessments,
- verify or authenticate information or identifications provided by Members (such as to verify the accommodation address or compare the identification photo to another photo a Member has provided),
- conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with Member consent where required,
- Resolve any disputes with any of our Members and enforce our agreements with third parties,
- enforce our Terms and other Policies,
- send promotional messages to Members, marketing, advertising, and other information that may be of interest to Member based on Member's preferences (including information about Ibex Smart Communications or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google), unless Member have requested not to receive such information, and
- enable Members to access and use the payment services.
We process this personal information for these purposes given our legitimate interest in protecting the Platform, improving the Platform and our Members' experience with it, to measure and for the adequate performance of the Services, in undertaking marketing activities to offer Members products or services that may be of interest and to comply with applicable laws.
5. Is personal information disclosed to third parties?
We do not and will not sell, rent or trade Member personal information. We may only disclose personal information to third parties in the ways set out in this Policy and, in particular, as set out below, and in accordance with local data protection laws. Note that, in this Policy, where we say "disclose", this includes to transfer, share (including verbally and in writing), send, or otherwise make available Member personal information to another person or entity.
Member personal information may be disclosed, inter alia, to the following types of third parties:
- our contractors, suppliers and service providers, including without limitation:
- in each of the circumstances set out in section 4 ("How do we use Member personal information?");
- suppliers of IT based solutions that assist us in providing services to Members (such as any external data hosting providers we may use);
- publishers and distributors of marketing material;
- event and expo organizers;
- marketing, market research, research and analysis and communications agencies; and
- external business advisers (such as lawyers, accountants, auditors and recruitment consultants);
- travel service providers/Hosts such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
- any third party to whom we assign or novate any of our rights or obligations;
- a person making travel bookings on a Member's behalf (i.e. a family member, friend or work colleague);
- where the Member is not contactable, a person who can verify to us that they have a relationship with the Member (e.g. a family member) through correctly answering our required security questions and the request is, in our opinion, in the Member's interest (for example, where the person is concerned for the Member's welfare or needs to undertake action on the Member's behalf due to unforeseen circumstances);
- as required or authorized by applicable law and to comply with our legal obligations;
- to comply with a valid and authorized request by government agencies and public authorities, including a court order or other valid legal process;
- various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes;
- enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter;
- To enable or support us in providing the Platform and the payment services, we may share Member information, including personal information, within our corporate affiliates (if any) and our Support Companies;
- the Platform allows Members to publish information, including personal information, that is visible to the general public; and
- To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the Services (we do not share billing or payout information with other Members).
On our websites, Members may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with us. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. The social media platforms with which we may share personal information are not controlled or supervised by Ibex Smart Communications. We strongly suggest that Members review the third parties' privacy policies if the Member uses the relevant features.
Hosts may need to use third party services available through the Platform to assist with managing their accommodation or providing additional services requested by the Member, such as cleaning services or lock providers. Hosts may use features on the Platform to share information about the Member (like check-in and check-out dates, Member name, Member phone number) with such third party service providers for the purposes of coordinating the stay, managing the accommodation, or providing other services. Hosts are responsible for third party service providers they use and ensuring those service providers process Member information securely and in compliance with applicable laws.
6. Security of Information
We are committed to safeguarding and protecting Member personal information via continuously implementing and updating various physical, electronic and managerial and technical security procedures in order to protect the personal information from loss and misuse, and from unauthorized access, modification, destruction, disclosure and interference. Ibex Smart Communications regularly reviews security technologies and strives to protect personal information as fully as is reasonably possible. Ibex Smart Communications is not responsible for any third party's actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise. We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law. Some of the safeguards we use to protect the information are firewalls and data encryption, and information access controls. If Members know or have reason to believe that their Platform Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of the Platform Account, please contact us.
7. Social Media Integrations
Our Platform(s) including the mobile applications and websites may use social media features and widgets (such as "Like" and "Share" buttons/widgets). These are provided and operated by third party companies (i.e. Facebook, Twitter etc.) and either hosted by a third party or hosted directly on our Platform. Such features may collect information such as the page being visited on our Platform, IP address and may also set cookies to enable the feature to function properly.
If Members are logged into the respective account with a third party company, then the third party company may be able to link information about the visit to and use of our Platform to the social media account with them. Similarly, a Member's interactions with the social media features may be recorded by the third party company. In addition, the third party company may send us information in line with their policies, such as the name, profile picture, gender, friend lists and any other information Members have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to the Member via the third party social media platform. Members can manage the sharing of information and opt out from targeted marketing via their privacy settings for the third party social media platform.
8. Tracking Technologies & Cookies
We may use third-party web analytics services on our Platform (such as Google, Facebook, affiliate tracking etc.), cookies and similar technologies to help us analyze how visitors use our Platform and to help provide, protect and improve the Platform.
When Member accesses our Platform, open electronic correspondence or communications from us, our servers may record data regarding the device and the network a Member is using to connect with us, including the IP address. An IP address is a series of numbers which identify the computer, and which are generally assigned when a person accesses the internet. We may use IP addresses for system administration, investigation of security issues and compiling anonymized data regarding usage of our Platform. We may also link IP addresses to other personal information we hold about Members and use it for the purposes described above (e.g. to tailor online advertising, provided Members have opted in for the same).
Our Platform may also contain links to third party websites over which we have no control over. We are not responsible for the privacy practices or the content of such websites and encourage Members to read the privacy policies of any linked third party websites visited.
What is a Cookie?
A Cookie is small data file that is stored on a Member's device (e.g. phone or computer) or other internet-connected device to uniquely identify a Member's browser or to store information or settings in the browser. While a Member visits a particular website, a cookie may be used to track the activities of the browser in order to provide the Member with a consistent, more efficient experience. They keep a record of a Member's preferences. Cookies may store a variety of information, including, the number of time a site is accessed, registration information and the number of times that a particular page or other item on the site is viewed.
9. Changes to our Policy