1. General

Holiday Innovation SA (whose registered office is at via arch. Rino Tami 18, 6924 Sorengo, Switzerland) and Holiday Innovation Italia S.r.l. (whose registered office is at via della Zecca 1, 40121 Bologna, Italy) (jointly referred to as “WowHomes”, “we”, “our” or “us”), acting as data controllers, are committed to protecting and respecting your privacy. This notice (the “Privacy Notice”) is designed to tell you about our practices regarding the collection, use and disclosure of information that you may provide via this website (the “Website“).

This Privacy Notice (together with our Terms and Conditions, any other documents referred to in it and our Cookie Notice) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. What information do we collect from you and for how long?

We may collect and process the following data about you:

2.1. Information you give us

You may give us information, including information that can identify you (“Personal Data“), when you use our Website, by filling in forms on the Website (such as the sign-up form), when you enter into any of our competitions, promotions or surveys, when you correspond with us by phone, e-mail or otherwise, and when you report a problem with our Website.

The information you give us may include:

• 2.1.1. Mandatory information required to register for the service we provide on our Website or to access other services provided by us, including your name, email address, date of birth, gender, mobile phone number and a password. All these fields are mandatory. WowHomes will not be able to provide you with the services offered on our Website if the required information is not provided, consequently you will not be able to register for a user account on our Website;

• 2.1.2. Mandatory information that is required by the public authorities (e.g. police) for registration purposes;

• 2.1.3. A record of any correspondence between you and us;

• 2.1.4. A record of any bookings you have made or trip related advertisements you have placed with or through our Website;

• 2.1.5. Details of accounting or financial transactions including transactions carried out through our Website or otherwise. This may include information such as your payment card or bank account details;

• 2.1.6. Details of your visits to our Website and the resources that you access;

• 2.1.7. Your replies to any surveys or questionnaires. Such information may be used for analytic & user understanding purposes;

• 2.1.8. Information we may require from you when you report a problem with our Website or our service, such as the subject of your request for support;

• 2.1.9. Location information when you have given consent to the collection and processing of these data; and

• 2.1.10. Passport, Driving Licence, ID Card and such other documents that you have agreed to provide to us.

2.2. Information we collect automatically

2.2.1. If you sign up via social media authentication methods, WowHomes will access certain Personal Data (e.g. first name, surname, picture, email, number of Facebook friends, etc.) in your social media account pursuant to the applicable terms and conditions of these social media Website. We may also collect some of your Personal Data when you interact with third party social media features, such as “Like” functions.

2.2.2. With regard to each of your visits to our Website we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Website, products you viewed or searched for, download errors, length of visits to certain pages, page interaction and any phone number used to call our customer service number. We collect this information through the use of various technologies including cookies (for further information please refer to our Cookie Notice).

2.3. Data retention

2.3.1. Except regarding the categories of Personal Data mentioned in clauses 2.3.2 and 2.3.3 below, your Personal Data will be stored for the duration of your relationship with us and then put beyond use:

• 5 years after your last use of our Platform, if you did not close your account;
• 1 year after the closing of your account.

2.3.2.The following categories of Personal Data may be stored for different durations:

• Financial data (e.g. payments, reimbursements, etc.) is stored for the duration required by applicable tax and accounting laws;
• All user-generated content (e.g. comments and ratings) is anonymised but remains available on our Website.

2.3.3. In the event that your account is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our Website.

3. How do we use the information we collect from you?

We will use the information we collect:

PURPOSES		LEGAL BASIS
3.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you requested from us;		This processing is necessary for the performance of our mutual contractual obligations.
3.2. to send you service-related information by email and/or text message and/or any other communication means (e.g. your booking confirmation);		This processing is necessary for the performance of our mutual obligations and/or carried out with your consent.
3.3. to collect payments from you or to transfer to you the payments we collect on your behalf;		This processing is necessary for the performance of our mutual contractual obligations.
3.4. to report your stay in one of our properties to public authorities (e.g. police) as requested by law;		This processing is mandatory by law.
3.5. to give you access to our support services and to enable you to communicate with our customer service;		This processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent and/or (iii) necessary for the establishment, exercise or defence of legal claims.
3.6. to ensure compliance with (i) applicable laws, (ii) our Terms and Conditions, and (iii) our Privacy Notice. Certain breaches that we regard as inappropriate may lead to the suspension of your account;		This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations and/or (iii) for the establishment, exercise or defence of legal claims.
3.7. to send you, in accordance with applicable laws and where required, with your consent, marketing materials and information necessary to facilitate the service or the booking process and to make you suggestions and recommendations about goods or services related to our services that may interest you. We also use your data to target you in order to serve our ads on social media Website. You can learn more about how these features work, and the data that we obtain about you, by visiting the relevant sections of the third party social media Website; and		This processing is based on your consent and/or our legitimate interest (i.e. providing  you with meaningful advertising).
3.8. to notify you about changes to our services;		This processing is necessary (i) for the performance of our mutual contractual obligations, (ii) for compliance with our legal obligations and/or (iii) the establishment, exercise or defence of legal claims.
3.9. to verify the information contained in your Passport, Driving Licence, ID Card and other identity documents that may be collected from you at the time of registration or at any other time during your use of our Website;		This processing is based on (i) your consent, (ii) carried out for the establishment, exercise or defence of legal claims and/or (iii) for compliance with our legal obligations.
3.10. to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, analytic and survey purposes;	This processing is based on our legitimate interest (i.e. ensuring the security of our Website and improving its features).
3.11. to improve our Website to ensure that content is presented in the most effective manner for you and for your device;	This processing is based on our legitimate interest (i.e. providing  you with meaningful content).
3.12. to allow you to participate in interactive features of our service, when you choose to do so;	This processing is necessary (i) for the performance of our mutual contractual obligations and/or (ii) based on your consent.
3.13. as part of our efforts to keep our Website safe and secure; and	This processing is based on (i) our legitimate interest (ensuring the security of our Website), (ii) carried out for the establishment, exercise or defence of legal claims and/or (iii) for compliance with our legal obligations.
3.14.    to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.	This processing is based on (i) our legitimate interest (i.e. measuring and optimising the efficiency of our advertising campaigns) and/or (ii) your consent.

4. Who are the recipients of the Information we collect from you and for which purposes?

4.1. When you use our services, your Information is shared between Holiday Innovation SA and Holiday Innovation Italia S.r.l. The latter is Holiday Innovation SA’s fully owned Italian subsidiary company; it manages our properties located in Italy and acts as your landlord for any booking you make on our Website.

4.2. We are also working closely with third parties which may be the recipients of your Personal Data such as:

• our business partners who provide the software solutions we use to run this Website and to manage the bookings we receive;
• our business partners who are social media Website and which may provide you with connecting services, such as the connection of the information of your profile, from their social media Website to our Website;

• our business partners who may advertise their services on our Website and to which you may decide to sign up for: these services may be any service related to our services such as insurance services, banking services, rental services, etc.;

• our business partners who may advertise our services on their websites;

• our sub-contractors in technical, payment, identity verification and delivery services, or analytics providers.

4.3. We only share  your Personal Data with any of these third parties in the following cases:

• 4.3.1. Where it is necessary to involve a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. if we charge you any fees or collect any money from you in relation to any services on the Website);

• 4.3.2. We use analytics and search engine providers to assist us in the improvement and optimisation of our Website;

• 4.3.3. It is explicitly requested by you (e.g. with when using social media authentication methods);

• 4.3.4. Whenever you ask us to order extra services for you or your group from one of our partner companies, such as cleaning services or airport transfers;

• 4.3.5. WowHomes may also disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (i) respond to claims asserted against WowHomes, (ii) to comply with legal proceedings, (iii) to enforce any agreement with our users such as our Terms and Conditions and our Privacy Notice, (iv) in the event of an emergency involving the danger of public health, death or physical injury to a person (v) in the framework of investigation or (vi) to protect the rights, property or personal safety of WowHomes, its members or others ;

• 4.3.6. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; and

• 4.3.7. If WowHomes or all or part of its assets are acquired by a third party, in which case Personal Data held by it about its members will be one of the transferred assets.

4.4. In accordance with applicable laws and where required with your consent, we may combine information about you, including your Personal Data and cookie information, we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above.

4.5. We draw your attention on the fact that if you decide to share your information, including Personal Data, with us through our business partners’ connecting services, any of our business partners’ privacy policies and/or notices may also be applicable to you, in addition to this Privacy Notice. We do not control the collection and/or the processing of your information eventually made by our business partners on their own websites.

5. Targeted ads on social media Website and our communications sent by e-mail and/or text messages

In accordance with applicable laws and where required with your consent, we may use the information you give us on our Website for electronic direct marketing purposes (e.g. (i) receiving our newsletters, invitations to our events or other communications that we think may interest you or (ii) serving you with targeted advertising on social media Website or third parties websites).

For electronic marketing communications: You can withdraw your consent at any time by (i) unticking the relevant box in your member account, (ii) clicking on the unsubscribe link we provide in each WowHomes communication sent to your attention or (iii) contacting us using the contact details provided in section 12 below.

For targeted ads and content:

• on social media (e.g. Facebook and Twitter): you can object at any time by configuring your settings regarding advertisement via your social media account;

• on third party websites: please refer to our Cookie Policy to see how to object.

6. Is your Information being transferred? how and where?

In principle, we store the Personal Data that we hold about you in the European Union (“EU“) and in Switzerland. However, since for example some of our service providers are based in countries outside of the European Union (“third countries”), we also transfer some of your data to third countries. This may include third countries where the European Commission has not taken the decision that such third country ensures an adequate level of protection (for example the United States). In that case, we ensure that the transfer is performed in accordance with the applicable legislation and that appropriate safeguards have been put in place (especially standard contractual clauses as issued by the European Commission) in order to guarantee a sufficient level of protection of individuals’ private life and fundamental rights.

By sending a request to the Data Protection Officer (dpo .at. WowHom.es), we can provide you with the details regarding such appropriate safeguards (for example, the standard contractual clauses issued by the European Commission).

7. What are your rights in respect of your personal data?

7.1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).

7.2 You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so (e.g., our legitimate interest to keep the platform safe and secure).

7.3 You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) to the processing of your personal data for other purposes on grounds relating to your particular situation (your right to object to processing). Please note that in the latter case, this right only applies if the processing of your personal data is based on our legitimate interest.

7.4 You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether our legitimate grounds to process your personal data in that case override your interests, rights and freedoms; or (iii) your personal data has been processed by us in an unlawful way but you either oppose the erasure of the personal data or want us to keep your personal data in order to establish, exercise or defend a legal claim.

7.5 You have the right to receive and/or have us transfer to another data controller a subset of personal data, that concern you and that you provided us with, and which we process for the performance of our contract or because you previously consented to it, in a structured, commonly used and machine-readable format (your right to data portability).

7.6 To exercise your rights, please contact the Data Protection Officer.

7.7. You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.

8. Cookies & similar technologies

To find out more, please see our Cookie Notice.

9. Confidentiality of your password

Where you have chosen a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. Links to other websites and social media

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

11. Changes to our Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. Where appropriate, we will notify you or seek your consent. Please check back frequently to see any updates or changes to our Privacy Notice.

12. Contact & Data Protection Officer

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data, please send an email to our Data Protection Officer under dpo .at. wowhom.es.