Tramona Privacy Policy

1. Personal Information We Collect

2. How We Use the Information We Collect

3. Sharing and Disclosure

4. Third-Party Partners and Integrations

5. Your Rights

6. Security

7. Changes to This Privacy Policy

8. Contact Information and Responsible Tramona Entities

9. Definitions

1. PERSONAL INFORMATION WE COLLECT.

1.1 Information Needed to Use the Tramona Platform. We collect personal information about you when you use the Tramona Platform. Without it, we may not be able to provide all services requested. This information includes:

1.1.1 Contact, Account, and Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

1.1.2 Identity Information. Where appropriate, we may ask you for an image of your government-issued ID (in accordance with applicable laws) or other verification information, and/or a selfie when we verify your ID. If a copy of your ID is provided to us, we will obtain information from your ID.

1.1.3 Payment Information. Such as payment account or bank account information. If you are not a Tramona user, we may receive payment information relating to you, such as when a Tramona user provides your payment card to complete a booking.

1.2 Information You Choose to Give Us. You can choose to provide us with additional personal information, including:

1.2.1 Additional Profile Information. Such as gender, preferred language(s), city, and personal description.

1.2.2 Information About Others. Such as a payment instrument or contact information belonging to another person or information about a co-traveler. By providing us with personal information about others, you certify that you have permission to provide that information to Tramona for the purposes described in this Privacy Policy and you have shared the Tramona Privacy Policy with them.

1.2.3 Biometric Information. Such as facial recognition data derived from photos and identification documents you submit for verification, where offered and with your consent where required by applicable law.

1.2.4 Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with Tramona Support and other Members, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us. This may include health information if you choose to share it with us.

1.3 Information Automatically Collected by Using the Tramona Platform and Our Payment Services. When you use the Tramona Platform and Payment Services, we automatically collect certain information. This information may include:

1.3.1 Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.

1.3.2 Usage Information. Such as searches for Listings, bookings you have made, additional services you have added, access dates and times, the pages you’ve viewed or engaged with before or after using the Tramona Platform, and other actions on the Tramona Platform, including the pages or content you view and links you click to third-party applications. We may collect this information even if you haven’t created a Tramona account or logged in.

1.3.3 Device Information. Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data, and read receipts. We may collect this information even if you haven’t created aTramona account or logged in.

1.3.4 Payment Transaction Information. Such as 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.

1.4 Information We Collect from Third Parties. We may collect personal information from other sources, such as:

1.4.1 Third-Party Applications. If you choose to link, connect, or login to the Tramona Platform with a third-party service, such as Google, Facebook, and WeChat, you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service. If you choose to connect a smart lock to your Tramona account, we may collect information about the smart device, such as log or event information and device information.

1.4.2 Background Information Providers. For Members in the United States, To the extent permitted by applicable laws, we may obtain, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. For Hosts in India, to the extent permitted by applicable laws, we may perform criminal background checks. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we may obtain police, background, or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

1.4.3 Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.

1.4.4 Referrals and Co-Travelers. If you are invited to the Tramona Platform, for example, as a co-traveler on a trip, the person who invited you can submit personal information about you.

1.4.5 Guest Travel Insurance Partners. If you make a claim under a Guest Travel Insurance Policy, we may receive information regarding your claim in order to provide you with customer service and improve our platform.

1.4.6 Complainants. If a Host, Guest, or any third party submits a complaint about you, we may receive information relating to the specific complaint made in order to understand and, where relevant, address the complaint.

1.4.7 Financial Institutions. If you elect to pay with funds from your bank account, we may receive certain information from your financial institution, such as bank account details and account balance.

1.4.8 Flexible Payment Plans and Financing Providers. If you elect to purchase a reservation and pay on an installment plan, we may receive certain information from the third-party provider, such as the payment schedule and actual payments on authorized payment plans.

1.4.9 Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues from (i) third-party service providers, other third parties, and/or partners, or (ii) Members and any other individuals, entities, and authorities, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention, security investigation, and risk assessment efforts. We may receive information about you and your activities on and off the Tramona Platform, including from users of Tramona, members of the public, or governmental, public, or tax authorities, or about your experiences and interactions from our partners. We may receive health information including, but not limited to, health information related to contagious diseases.

2. HOW WE USE INFORMATION WE COLLECT. We use personal information as outlined in this Privacy Policy.

2.1 Provide, Improve, and Develop the Tramona Platform. We may process this information to:

• enable you to access the Tramona Platform and make and receive payments,
• enable you to communicate with others,
• process your request,
• perform analytics, debug, and conduct research,
• develop and improve our products and services,
• provide customer service training,
• send you messages, updates, security alerts, and account notifications,
• process, handle, or assess insurance claims or similar claims,
• determine your country of residence based on automated review of your account information and your interactions with the Tramona Platform,
• personalize and customize your experience based on your interactions with the Tramona Platform, your search and booking history, your profile information and preferences, and other content you submit, and
• enable your use of our products and accommodation services.

2.2 Safeguard the Tramona Platform and Community. We may process this information to:

• study and combat discrimination consistent with our Nondiscrimination Policy,
• detect, prevent, assess, and address fraud and security risks,
• verify or authenticate information provided by you, including identity information, as described in Information Needed to Use the Tramona Platform,
• conduct checks against databases and other information sources, including background checks,
• comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees, and members of the public,
• resolve disputes with our Members, including sharing information with your co-Host(s) or additional Guests about disputes related to your role as a co-Host(s) or additional Guests,
• enforce our agreements with third parties,
• determine eligibility for certain types of bookings, such as Instant Book,
• comply with law, respond to legal requests, prevent harm, and protect our rights (see Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights),
• enforce our Terms and other policies
• assess or evaluate your interactions with the Tramona Platform and information obtained from third parties.

In certain cases, automated processes, which analyze your account and activities on the Tramona platform as well as information in relation to activities on and off the Tramona platform that can be associated with you, could restrict or suspend your access to the Tramona Platform if such processes detect activity that may pose a safety or other risk to Tramona, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may process this information to:

• send you promotional and marketing messages, and other information,
• show, personalize, measure, and improve our advertising on advertising platforms,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Tramona or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.

2.4 Analyze and Share Your Communications. We may review, scan, or analyze your communications on the Tramona Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our Terms of Service, 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 sites and, subject to applicable law, we scan and analyze all images uploaded by users to the Tramona platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities – such as evidence of child exploitation – for the purpose of identifying and reporting content violations to appropriate authorities. 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. Occasionally we may need to manually review 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 messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications. We may also share your communications as set out in the “Sharing and Disclosure” section.

2.5 Provide Payment Services. Personal information is used to enable, or authorize third parties to use, Payment Services, such as to:

• detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
• comply with legal and compliance obligations, such as anti-money laundering regulations and sanctions enforcement,
• enforce the Payment Terms and other payment policies, and
• provide and improve Payment Services.

3. SHARING AND DISCLOSURE. If you reside outside of the United States, learn about safeguards we rely on for transferring personal information to recipients outside of certain jurisdictions.

3.1 Sharing With Your Consent or at Your Direction. Where you provide consent or direct us to share your information, we share your information as described at the time of consent or choice, such as when authorizing a third-party application or website to access your Tramona account, processing an insurance claim, applying for flexible payment and financing products, or participating in promotional activities by Tramona partners or third parties.

3.2 Who We Share With. We may share your information with:

3.2.1 Other Members. To help facilitate bookings or other interactions between Members (who may be located in, or use service providers located in, jurisdictions with varying levels of data protection), we may share information in certain situations

3.2.2 Members’ Service Providers. Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Tramona Platform to share information about the Guest with such third-party service providers. Other Members may use services other than Tramona to process your data, including email or reservation management software. Such services are outside of Tramona’s control and will be subject to applicable law.

3.2.3 Building Management. We may share personal information of Hosts and Guests with the owner(s) of an Accommodation, a homeowners’ association, and/or their agent, such as a building operator or property management company (“Building Management”), including booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. Guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located to facilitate hosting services, compliance with applicable laws, security, billing, and other services.

3.2.4 Tramona for Work Partners. If a booking is designated as being for a business or work purpose and is made by a Guest affiliated with an Enterprise enrolled in Tramona for Work, we may disclose information related to the booking to the Enterprise to the extent necessary for the adequate performance of Tramona’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.

3.2.5 Service Providers. We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the Tramona Services through third-party platforms and software tools, (vi) provide customer service, advertising, or payments services(vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, (ix) review, scan, and analyze communications on the Tramona Platform for certain purposes, such as evidence of child exploitation, or (x) offer flexible payment plans and financing provided by a third-party credit provider see the Analyzing and Sharing Your Communications section for additional information. These providers are contractually bound to protect your personal information, have access to your personal information to perform these tasks, and may also disclose your information where required by law.

3.2.6 Corporate Affiliates. To support us in providing, integrating, promoting and improving the Tramona Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies, including:

3.2.6(i) Tramona, Inc. Even if your country of residence is not the United States, your information will be shared with Tramona, Inc., which provides the technical infrastructure for the Tramona Platform.

3.2.6(iii) Tramona Insurance Agent Affiliates. If you elect to purchase travel insurance and assistance services or reservation insurance, in order to furnish the policy and market insurance offerings, certain information, such as booking details and guest name and contact information, will be shared with (i) Tramona Insurance Agency LLC, if you reside in the United States, or (ii) the relevant Tramona insurance agent affiliate, if you reside outside of the United States.

3.3 Why We May Share Your Information. We may share your information in order to:

3.3.1 Build Your Public Profile. Information you share publicly on the Tramona Platform may be indexed through third-party search engines. In some cases, you may opt-out of this sharing in your account settings. We may make certain information publicly visible to others, such as:

• your profile and account information and information derived from them
• listing pages that include information such as the Accommodation or Experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information, and additional information you choose to share,
• reviews, ratings, and other public feedback, and
• content in a community or discussion forum, blog, or social media post, and content you make available to the public, including Listing details on third-party sites, platforms, and apps.

3.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights.

3.3.2(i) Disclosure. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against Tramona, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability (iv) enforce and administer our agreements with Members, including our Terms(v) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning Tramona and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of Tramona, its employees, its Members, or members of the public.

3.3.2(i)(a) To Tax Authorities. Where legally required or permissible according to applicable law, we may disclose Hosts’ and/or Guests’ information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations.

3.3.2(i)(b) To Governmental Authorities for Registrations, Notifications, Permits, or License Applications or Numbers. In jurisdictions where Tramona facilitates or requires a registration, notification, permit, or license application or number of a Host with a governmental authority, we may share information of participating Hosts with the relevant authority, during the application process, when the Listing is published, and periodically thereafter.

3.3.2(ii) Notification. Where appropriate and/or legally required, we may notify Members 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 or harm to Tramona, our Members, or expose Tramona to a claim of obstruction of justice.

3.3.3 Effectuate Business Transfers. If Tramona undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction, such as due diligence. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4. THIRD-PARTY PARTNERS AND INTEGRATIONS.

4.1 Linking Third-Party Services. You can link your Tramona account with certain third-party services, such as social networks. When you direct the data sharing by creating this link:

• some of the information provided to us from linking accounts may be published on your public profile,
• information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention, security investigations, and risk assessment purposes,
• we share information about your reservation with third-party travel partners and reward programs, and
• publication and display of information that you provide to the Tramona Platform through this linkage is subject to your settings and authorizations on the Tramona Platform and the third-party service.

4.2 Third-Party Service Terms. Parts of Tramona may link to third-party services. Tramona does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information), Stripe Privacy Policy.

5. YOUR RIGHTS. You can exercise any of the rights described in this section consistent with applicable law.

5.1 Managing Your Information. You can access and update some of your personal information through your Account settings. you are responsible for keeping your personal information up to date.

5.2 Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider, where technically feasible.

5.3 Erasure. In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

5.4.1 Legitimate Business Interests. We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Tramona Account for fraud or safety reasons, we may retain information from that Tramona Account to prevent that Member from opening a new Tramona Account in the future.

5.4.2 Legal, Tax, Reporting, and Auditing Obligations. We may retain and use your personal information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations.

5.4.3 Shared Information. Information you have shared with others, such as Reviews and forum postings, may continue to be publicly visible on Tramona, even after your Tramona Account is canceled.

5.4.4 Residual Copies. Because we take measures to protect data 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. SECURITY. While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

7. CHANGES TO THIS PRIVACY POLICY. We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Tramona Platform will be subject to the revised Privacy Policy.

8. CONTACT INFORMATION AND RESPONSIBLE Tramona ENTITIES. For questions or complaints about this Privacy Policy or Tramona’s handling of personal information (i) If you reside in the United States contact Tramona, Inc or by emailing us at info@Tramona.com (ii) for payments related matter please use the contact info@tramona.co,

9. DEFINITIONS. Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).