Urbandoor Terms of Service – Privacy Policy

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Urbandoor last updated our Terms of service on August 29th, 2018 and our Privacy Policy on May 31st, 2018, our Copyright Policy on May 8th, 2018, and our Cookie Policy and Authorized Subcontractors on September 24, 2018

Last Updated Date: 05/30/2018

We at UrbanDoor know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Remember that your use of UrbanDoor’s Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.

As noted in the Terms of Use, we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at info@urbandoor.com.

Will UrbanDoor ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the UrbanDoor.com website by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What Information does UrbanDoor Collect?

Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Information such as your name, email address, phone number. Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by adjusting your user settings and/or clicking “unsubscribe” from any communication we send you.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Will UrbanDoor Share Any of the Personal Information it Receives?

We do not rent or sell your Personal Information in personally identifiable form to anyone. We may share your Personal Information with third parties as described in this section:

Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). For example, you may be able to request that our affiliates deliver goods and/or services to you and in order to facilitate such requests, we may share your location, address, and contact information with our affiliates for the purpose of responding to your request. You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing partner at UrbanDoor to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances, and would be subject to the terms of the “Information that’s been de-identified” section in that regard.

User Proles and Submissions: Certain user profile information, including your name and location may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments through the Services and other users can contact you through messages and comments.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Protection of UrbanDoor and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of UrbanDoor, our employees, our users, or others.

Is Personal Information about me secure?

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing or after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What Personal Information can I access?

Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:

name and password
email address
location
user prole information, including but not limited to stay dates, personal information you submit and/or other user-submitted information intended to help us provide the Services.

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on le about you, please contact us at info@urbandoor.com.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us atinfo@urbandoor.com.

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us at info@urbandoor.com or, when available, deleting via your account settings. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

Privacy Shield Framework

Urbandoor complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Urbandoor has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Urbandoor commits to resolve complaints about our collection or use of your personal information. There is, under certain conditions, the possibility for an individual to invoke binding arbitration. Individuals in the European Union (EU) with inquiries or complaints regarding our Private Shield policy should first contact Urbandoor at: info@urbandoor.com.

Urbandoor has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to leave a complaint. The services of EU DPAs are provided at no cost to you. Transferred personal data may only be processed for limited and specified purposes consistent with the data subject’s consent. Third parties agree to provide the same level of protection, and our organization will take reasonable and appropriate steps to ensure the agent upholds the Principles, to stop and remediate any unauthorized processing. Our organization remains liable if its agent processes personal data in a manner inconsistent with the Privacy Shield principles, unless Urbandoor proves that it is not responsible for the event giving rise to the damage.

We use Stripe for some banking-related services

Stripe’s Privacy Policy may be found here.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@urbandoor.com and we will try to resolve your concerns.

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EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. UrbanDoor will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at gdprcompliance@urbandoor.com.

What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

First and last name
Email address
Mailing address
Telephone number
Social security number Government ID number/Passport Number Date of birth
Credit/debit card number

Information we receive from third party sources: Some third parties such as your employer or sponsoring organization and our vendors and service providers provide us with Personal Data about you, such as the following:

· Profile information from your employer: Your employer or sponsoring organization may provide us with your contact and employment information to assist with setting up and registering your account with the Services.

· Background check and identity verification information: We may receive information about you from some of our service providers, such as Checkr and CIC, who assist us with background checks/credit checks or identify verification as required by certain housing providers who use the Services.

· Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Google Single Sign-On (SSO)), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The

information we receive will depend on the policies and your account settings with the third party service.

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

IP address
Device identifiers
Web browser information
Page view statistics
Browsing history
Usage information
Transaction information (e.g. transaction amount, date and time such transaction occurred) Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) For more

information, please review our Cookies Policy Location information (e.g. IP address)

Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

Create and manage user profiles
Enable you to book accommodations through the Services
Fulfill bookings made through the Services
Communicate with you about the Services
Enable you to communicate with housing providers regarding accommodations booked through the Services
Contact you about announcements, updates or offers regarding the Services

Verify or authenticate information or identification provided by you Provide support and assistance for the Services
Communicate with your emergency contact in the event of an emergency Personalize website content and communications based on your preferences Meet contract or legal obligations
Respond to user inquiries
Comply with our legal or contractual obligations
Resolve disputes
Protect against or deter fraudulent, illegal or harmful actions
Enforce our Guest Terms of Service

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Guest Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

First and last name
Email address
Mailing address
Telephone number
Social security number Government ID number/Passport Number Date of birth
Credit/debit card number Electronic lease execution

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

User content, for example, comments and posts you submit publicly, photographs you upload.
Customer support communications
Contact information for your emergency contact
Automatically collected information (such as your transaction information and log data)

Examples of these legitimate interests include:

Operation and improvement of our business, products and services Marketing of our products and services
Provision of customer support
Detection and prevention of fraud, abuse, security incidents, and other harmful activity Verification and authentication of your identity and other information you provide for the protection of other users of the Services
Compliance with legal obligations
Completion of corporate transactions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or the Guest Terms of Service. These parties include:

Payment processors Ad networks Analytics service providers Hosting service providers

Co-location service providers Telecommunications service providers

We also share Personal Data when necessary to complete a booking transaction initiated or authorized by you or to facilitate your stay in accommodations booked through the Services. In addition to those set forth above, these parties also include:

Housing providers whose accommodations you book or with whom you communicate through the Services

Your employer or sponsoring organization (e.g. relocation or travel management companies)

Fraud prevention, ID verification, and background check service providers (and we may share the results of such ID verification or background check reports with housing providers)
Other users (where you post information publicly or as otherwise necessary to select a transaction initiated or authorized by you through the Services)
Third party service providers (such as cleaning staff, unit managers, furnishers, etc.) who you access through the Services Other parties authorized by you

We also share Personal Data when we believe it is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies

Protect us, our business or our users, for example to enforce our Guest Terms of Service and Accommodation Agreement, prevent spam or other unwanted communications and investigate or protect against fraud Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services and for 7 years after you close your account, as set forth on our Data Retention Policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. 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.

Personal Data of Children: We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at gdprcompliance@urbandoor.com.

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email gdprcompliance@urbandoor.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

 

Erasure: You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

 

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing gdprcompliance@urbandoor.com.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by emailing gdprcompliance@urbandoor.com. You can correct some of this information directly by adjusting the information in Account Settings on the Services.

Right to File Complaint: You have the right to lodge a complaint about UrbanDoor’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through UrbanDoor and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to UrbanDoor in the U.S. and will be hosted on U.S. servers, and you authorize UrbanDoor to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-US Privacy Shield Framework, the details of which are further set forth below.

UrbanDoor has certified to the EU.-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. For more information about the Privacy Shield Program, and to view UrbanDoor’s certification, please visit www.privacyshield.gov. UrbanDoor is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). UrbanDoor’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Please contact us at gdprcompliance@urbandoor.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/le-an-eu-us-privacy- shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:

Name:

Urbandoor, Inc.

Physical address:

500 Sansome Street, Suite 100
San Francisco, CA 94111
Email address for contact: gdprcompliance@urbandoor.com Designated representative and contact information:

Erik Eccles, CEO

Data Protection Officer and contact information:

Aphaia
Studio 5
155 Commercial Street London E1 6BJ