Privacy Policy for the United States

This Privacy Policy describes how Serentio, LLC and its affiliates (“ we ,” “ us ,” or “ Serentio”), process personal information in relation to your use of the Serentio Platform. Depending on where you live and what you are doing on the Serentio Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information describing how we process personal information for those regions and services.

1. DEFINITIONS

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

2. PERSONAL INFORMATION WE COLLECT

2.1 Information needed to use the Serentio Platform.

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

• Contact Information, Account, 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.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information. ​​If you are not an Serentio user, we may receive payment information relating to you, such as when a Serentio user provides your payment card to complete a booking. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• **Information About Others. ** Such as a payment instrument 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 Serentio for the purposes described in this Privacy Policy, have shared the Serentio Privacy Policy with them, and they have read and understood that it applies to them.
• 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 our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the Serentio Platform and our Payment Services.

When you use the Serentio Platform and Payment Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS 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.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Serentio Platform.
• Log Data and Device Information. Such as details about how you’ve used the Serentio Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Serentio Platform. We may collect this information even if you haven’t created an Serentio account or logged in.
• 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.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

• Third-Party Services. If you link, connect, or login to the Serentio Platform with a third party service (e.g. Google, Facebook, 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.
• Background Information. 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 Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background, or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
• Referrals and co-travelers. If you are invited to the Serentio Platform, such as a co-traveler on a trip, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, 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 about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Serentio Platform, 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.

3. HOW WE USE INFORMATION WE COLLECT

If you reside outside of the United States, click here to learn about our legal bases for collection and processing personal information. We use personal information as outlined in this Privacy Policy.

3.1 Provide, Improve, and Develop the Serentio Platform. Such as to:

• enable you to access the Serentio Platform and make and receive payments,
• enable you to communicate with other Members,
• process your request,
• perform analytics, debug and conduct research,
• provide customer service, training,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, such as your friends or co-travelers, we may process this information: (i) to facilitate your referral invitations, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Serentio Platform, your search and booking history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.

3.2 Create and Maintain a Trusted and Safer Environment. Including to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• study and combat discrimination,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our anyone we work with,
• resolve disputes,
• enforce our agreements with third parties,
• comply with law, respond to legal requests, prevent harm, and protect our rights (see section 4.5),
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Serentio Platform, your profile information and other content you submit to Serentio, and information obtained from third parties.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. For example to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Serentio 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.

3.4 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,
• conduct security investigations and risk assessments,
• comply with legal obligations (such as anti-money laundering regulations),
• enforce payment policies,
• with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences, and,
• provide and improve Payment Services.

4. SHARING & DISCLOSURE

If you reside outside of the United States, learn about safeguards we rely on for transferring personal information to recipients outside of the EEA here.

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Serentio account or participating in promotional activities by Serentio partners or third parties.

Where permissible under applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Serentio, or otherwise promote our products and services.

4.2 Sharing Between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information such as:

• When you as a Guest invite additional Guests to a booking, your name, travel dates, Host name, Listing details, Accommodation address, and other related information will be shared with each additional Guest.

4.3 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

• Your public profile page, which includes your profile photo, first name (or initials where applicable), description, and city.
• Listing pages that include information such as the accommodation or experience’s approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings, and other public feedback.
• Content in a community or discussion forum, blog, or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.

Information you share publicly on the Serentio Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, 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 Serentio, (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 (iv) enforce and administer our agreements with Members, or (v) protect the rights, property or personal safety of Serentio, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, tax information may be shared with tax authorities or other governmental agencies.

Where appropriate, 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 Serentio, our Members, or expose Serentio to a claim of obstruction of justice.

Where legally required or permissible according to applicable law, we may disclose Guests’ or property owners’ information to tax authorities for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations. Relevant tax obligations include Serentio’s tax obligations on its service fees, its facilitation of taxes on accommodations and withholding taxes, and property owners’ individual tax obligations. Information that may be disclosed includes, but is not limited to, Property owner/manager and Guest names, listing addresses, Property owner/manager addresses, tax/business identification number(s), date of birth, and/or contact information, property parcel identification numbers, payout information, transaction dates and amounts, number of nights and Guests booked, gross and net booking value and payout amounts, taxes collected by Serentio on behalf of Guests and Property owner/managers, to the extent any of this information is known by Serentio.

In jurisdictions where Serentio facilitates or requires a registration, notification, permit, or license application or number of a property owner/manager with a governmental authority, we may share information of participating property owner/managers with the relevant authority, both during the application process, when the Listing is published, and periodically thereafter, such as the property owner/manager’s full name and contact details, accommodation address, tax identification number, registration, permit, or license number, Listing details, reservation information, and number of nights booked subject to applicable laws.

4.6 Programs with Managers and Owners.

We may share personal information of Guests with landlords, management companies, and/or property owners (“ Building Management”), such as booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. For example, guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a property owner/manager lives and/or the listing is located to facilitate property owner/management services, compliance with applicable laws, security, billing, and other services.

4.7 Property owner/manager Information Provided to Serentio for Work Customers.

If a booking is designated as being for a business or work purpose and (1) is made by a Guest affiliated with an enterprise and (2) the enterprise is enrolled in Serentio, we may disclose information related to the booking to the enterprise (e.g., name of the Property owner/manager, accommodation address, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of Serentio’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.

4.8 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business and for their compliance purposes, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Serentio Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or similar claims. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.9 Business Transfers.

If Serentio 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 (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.10 Corporate Affiliates.

To support us in providing, integrating, promoting and improving the Serentio Platform, payment services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:

• Sharing with Serentio, LLC. Even if your country of residence is not the United States, your information will be shared with Serentio, LLC which provides the technical infrastructure for the Serentio Platform.

Our service providers may also disclose your information where required by law.

5. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. Email legal@serentio.com for information on data subject rights requests and how to submit a request. We may ask you to verify your identity and request before taking further action on your request.

5.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Serentio Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

5.2 Data 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 Data 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:

• 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 an Serentio Account for fraud or safety reasons, we may retain information from that Serentio Account to prevent that Member from opening a new Serentio Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Serentio may keep information for tax, legal reporting, and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Serentio, even after your Serentio Account is canceled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• 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.

7. 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 unauthorized access, loss, destruction, or alteration.

8. 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 Serentio Platform will be subject to the revised Privacy Policy.

9. CONTACT INFORMATION AND RESPONSIBLE SERENTIO ENTITIES

For questions or complaints about this Privacy Policy or Serentio’s handling of personal information (i) If you reside in the United States contact Serentio, LLC, Attn: Office of General Counsel, 3807 Glen Arbor, Atlanta, GA, 30319, USA; (ii) for payments related matter please use the contact information provided in the payment terms, and (iii) if you reside outside the United States, please use the contact information for your controller provided in the Outside of the United States page.

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