PRIVACY POLICY
(Automatic translation via Google translation, any typos or ambiguities will be referred to the original version in Portuguese)This Privacy Policy describes how GC 84 Apartments treats personal data in relation to its use. Last Updated: 06/08/2024
1. PERSONAL DATA WE COLLECT.
1.1 Information required to use our website.
We collect personal data about you when you rent an apartment or check rental availability on our website. Without this information, we may not be able to provide you with all the services you request. This information includes:1.1.1 Contact information.
Such as first name, last name, phone number, postal address, email address, date of birth and profile picture, some of which will depend on the features you use.1.1.2 Identity information.
Where appropriate, we may request an image of your government-issued identification document (in accordance with applicable laws) or other verification information and/or a selfie when we verify your identification document. If a copy of your identification document is provided to us, we may obtain information from your document to verify your identity.1.1.3 Payment information.
Such as payment account or bank account information. If you are not a user of the Website, we may receive payment information related to you, such as when a user of the Website provides their payment card to complete a booking.
1.2 Information you choose to provide to us.
You may choose to provide us with additional personal data, such as:1.2.1 Additional profile information.
Such as gender, preferred language(s) and personal description.1.2.2 Information about other people.
Such as a payment instrument or contact information of another person or information about a fellow traveler. By providing personal data about other people, you warrant that you have permission to provide that information to us for the purposes described in this Privacy Policy and that you have shared the Privacy Policy with them.
1.3 Information collected automatically when you use our website and our Payment Services.
When you use our website and Payment Services, we automatically collect certain information. This information may include:1.3.1 Geolocation information.
Such as precise or approximate location determined based on your IP address, mobile or other device GPS, or other information you share with us, depending on your device settings.1.3.2 Usage Information.
Such as searches for Listings, reservations you have made, additional services you have purchased, dates and times of access, the pages you have viewed or interacted with before and after using our website, and other actions on our website, including the pages or content you view and links you click to third-party applications. We may collect this information even if you have not created or logged in to an account on our website.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 have not created or logged in to an account on our website.1.3.4 Cookies and similar technologies,
GC 84 Apartments uses cookies, mobile identifiers, tracking URLs, log data, and similar technologies to help provide, protect, and improve our website. When you visit our website, we may place cookies on your device. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a personalized experience and may enable us to detect certain types of fraud. In many cases, the information we collect using cookies and other tools is used only in a non-identifiable form, without reference to personal information.1.3.4(i)Why we use these technologies
We use these technologies for a number of purposes, including:
- to enable you to use and access our website and the Payment Services
- to enable, facilitate and speed up the operation of and your access to our website
- to better understand how you navigate and interact with our website and to improve it
- to offer personalized advertising
- to monitor and analyze the performance, operation, and effectiveness of our advertisements and our website
- to enforce legal agreements regarding your use of our website
- for fraud detection and prevention, for trust and safety purposes, and for investigations
1.3.5 Payment Transaction Information.
Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing zip code, PayPal email address, IBAN information, your address and other details related to the transaction.
1.4 Information we collect from third parties.
We may collect personal data from other sources, such as:1.4.1 Complaints.
If a guest or any third party submits a complaint about you, we may receive information relating to the complaint made in order to understand and, where relevant, resolve the complaint.1.4.2 Financial institutions.
If you choose 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.1.4.3 Flexible payment plans and financing providers.
If you choose to purchase a reservation and pay using an installment plan, we may receive certain information from the third-party provider, such as the payment schedule and amounts for authorized plans.1.4.4 Other sources.
As permitted by applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and security issues, from (i) third-party service providers, other third parties and/or partners, or from (ii) Customers and any other individuals, entities and authorities, and combine it with the information we have about you. For example, we may receive background check results or fraud warnings from service providers who perform identity verification for use in our fraud prevention, security investigations and risk assessment efforts. We may receive information about you and your activities on and off our website, including from other website users, members of the public or government, public or tax authorities, or about your experiences and interactions with our partners. We may receive health information, including but not limited to health information related to communicable diseases.
2. HOW WE USE THE INFORMATION WE COLLECT.
We use personal data as described in this Privacy Policy. If you reside outside of the United States, click here to learn more about our legal bases for collecting and processing personal data.2.1 Provide, improve and develop our website.
We may process this information to:- allow you to access our website and make payments;
- process your requests;
- carry out analysis, debugging and research;
- develop and improve our products and services,
- provide training to customer service staff;
- send messages, updates, security alerts and account notifications to you; process, address or evaluate coverage or similar requests;
- determine your country of residence based on automated analysis of your account information and your interactions with our website,
- personalize and customize your experience based on your interactions with our website, your search and booking history, your profile information and preferences, and other content you submit; and
- allow your use of our corporate products and accommodation services.
2.2 Protect our website.
We may process this information to:- detect, prevent, assess and address fraud and security risks;
- verify or authenticate information provided by you, including identity information, as described in the Information Required to Use Our Website section;
- perform checks on databases and other sources of information, including background checks;
- comply with our legal obligations, protect the health and well-being of our Guests, our employees and other guests;
- resolve disputes with our guests, including sharing information with co-hosts or additional guests about disputes related to your role as a co-host or additional guest;
- enforce our contracts with third parties;
- determine eligibility for certain types of bookings, such as direct booking;
- comply with the law, respond to legal requests, prevent harm, and protect our rights
- enforce our Terms and other policies; and
- evaluate your interactions with our website and information obtained from third parties.
2.3 Provide, personalize, measure, and improve our advertising and marketing.
We may process this data to:- send you promotional and marketing messages and other information;
- display, 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 us or our third party business partners;
- analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we believe may be of interest to you; and
2.4 Analyze and share your communications.
We may review, examine, or analyze your communications on our website for the reasons described in the “How We Use the Information We Collect” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcement of our Terms of Service, and customer service purposes. For example, as part of our fraud prevention efforts, we may review and analyze messages that attempt to mask contact information and references to other websites, and, subject to applicable law, we may review and analyze all images submitted by users to our website in messaging exchanges, profiles, advertisements, and experiences for certain illegal or inappropriate activities (such as evidence of child exploitation) in order to identify and report violating content to law enforcement authorities. In some cases, we may also review, evaluate, or analyze messages to debug, improve, and expand our product offerings. We use automated methods when reasonably possible. Occasionally, it may be necessary for us to manually review communications, such as for fraud investigations, customer service purposes, or to evaluate and improve the functionality of such automated methods. We will not screen, examine, or analyze your communications to send you third-party marketing messages, and we will not sell analytics and evaluations of those communications. We may also share your communications as set forth in the “Sharing and Disclosure” section.2.5 Provision of payment services.
Personal data is used to enable or authorize third parties to use the Payment Services, such as:- detect and prevent money laundering, fraud, abuse and security incidents, as well as perform risk assessments;
- comply with legal and compliance obligations, such as anti-money laundering regulations and sanctions enforcement;
- enforce the terms of the Payment Terms and other payment policies; and
- provide and improve the Payment Services.
3. SHARING AND DISCLOSURE.
If you reside outside of Brazil, learn more about the safeguards we rely on to transfer personal data to recipients outside certain jurisdictions here.3.1 Sharing with your consent or at your direction.
When you give your consent or direct us to share your information, we share your information as described at the time of consent or choice, to process an insurance claim, apply for flexible payment and financing products, or participate in promotional activities of our partners or third parties.3.2 Who we share with.
We may share your information with:3.2.1 Service providers.
GC 84 Apartments may use third party services to help manage or provide its services, such as cleaning services or locksmiths. GC 84 Apartments may use features on the Website to share information about guests with these third party service providers. Other Customers may use services other than ours to process your data, including email or reservation management software. These services are outside of our control and will be subject to applicable law.3.2.2 Condominium Administration.
We may share guest personal data with the owner(s) of an Accommodation managed by us, a homeowners association, and/or their agent, such as a condominium manager or property management company (“Condominium Management”), including reservation information and information related to compliance with applicable laws, in order to facilitate programs involving the Condominium Management. The Guest’s reservation and personal data, including contact information, may be shared with the Condominium Management of the building, complex, or community where the Host lives and/or where the listing is located, in order to facilitate guest services, compliance with applicable laws, security, billing, and other services.3.2.4 Service Providers.
We share personal data with affiliated and unaffiliated service providers (including your service providers) to facilitate the administration of our business and for compliance, including those who help us: (i) verify your identity or authenticate your identification documents; (ii) check information against public databases; (iii) perform background checks, fraud prevention, security investigations, and risk assessments; (iv) perform product development, maintenance, and debugging; (v) enable the provision of the Services through third-party software platforms and tools; (vi) provide customer service, advertising, or payments services (see the billing services’ Privacy Policy for more information); (vii) offer additional services that you select; (viii) process, handle, or evaluate insurance or similar claims; (ix) review, examine, and analyze communications on our website 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 obligated to protect your personal data, have access to it to perform these tasks, and may also disclose your data when required by law.
3.3 Why we may share your information.
We may share your information to:3.3.1 Comply with the law, respond to legal requests, prevent harm, and protect our rights.
3.3.1(i) Disclosure.
We may disclose your information to courts, law enforcement, government or public authorities, tax authorities, authorized third parties or other Customers if and for as long as we are required or authorized to do so by law or where disclosure is necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or respond to claims made against us, (iii) respond to a valid legal request in connection with a criminal investigation, to address reported or suspected illegal activity, or to respond to or address any other activity that may expose us, you or any other of our Customers to legal or regulatory liability, (iv) enforce and administer our Customer agreements, including our Terms, Additional Legal Terms and Policies, (v) respond to requests for or in connection with current or prospective legal actions or legal proceedings relating to us and/or third parties, in accordance with applicable law, or (vi) protect the rights, property or personal safety of us, our employees, our Customers or the public.3.3.1(i)(a) For tax authorities.
Where legally required or permitted under applicable law, we may disclose Guest information to relevant tax authorities or other government entities, depending on where you are based, for the purposes of determining proper compliance with relevant tax obligations.3.3.1(i)(b) To government authorities for registrations, notifications, permits and applications or license numbers.
We may share guest information with the appropriate authority during the stay, the application process, and periodically thereafter.3.3.1(ii) Notification.
When appropriate and/or legally required, we may notify Customers of legal requests unless: (i) notification is prohibited by the legal proceeding itself, by a court order we receive, or by applicable law; or (ii) we believe that notification would be futile, ineffective, create a risk of injury or physical harm to an individual or group, create or increase a risk of fraud or harm to GC 84 Apartments or our customers, or expose us to a claim of obstruction of justice.3.3.2 Make business transfers.
In the event GC 84 Apartments undergoes or is involved in any merger, acquisition, restructuring, sale of assets, bankruptcy or insolvency event, we may sell, transfer or share some or all of our assets, including your information related to or contemplated by such transactions, such as a collection of data. In such an event, you will receive notice before your personal data is transferred and becomes subject to a different privacy policy.
4. INTEGRATIONS AND THIRD PARTY PARTNERS.
Portions of our website may link to third-party services. We do not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing them with your information. Your use of these services is subject to the privacy policies of these providers, such as the Google Maps/Earth Additional Terms of Use, the Google Privacy Policy, the PayPal Privacy Statement, the Mercado Pago Privacy Policy, and the Stripe Privacy Policy.5. YOUR RIGHTS.
You may exercise any of the rights described in this section in accordance with applicable law. We may ask you to verify your identity and your request before taking any action on it.5.1 Residents in Brazil.
They should inform themselves about the rights provided for in the General Data Protection Law (Law No. 13,709/2018), a federal law that regulates the processing of personal data, including in digital media, with the aim of protecting their fundamental rights to freedom and privacy and the free development of their personality. The LGPD provides for their rights to the protection of personal data, as well as establishing general principles and obligations that must be observed by those who process personal data.5.2 Managing your information.
You can access and update some of your personal data by requesting it through the contact form. You are responsible for keeping your personal data up to date.5.4 Access and Portability.
In some jurisdictions, applicable law may give you the right to request certain copies of your personal data or information about how we handle your personal data, request copies of personal data you have provided to us in a structured, commonly used and machine-readable format, and/or request that we send this information to another service provider, where technically feasible.5.5 Exclusion.
In some jurisdictions, you may request that your personal data be deleted. Please note that if you request that your personal data be deleted, or if your account is suspended, terminated or voluntarily cancelled:5.5.1 Legitimate commercial interests.
We may retain some personal data as necessary for our legitimate business interests, such as anti-money laundering, fraud detection and prevention, and security improvements.5.5.2 Legal, tax, reporting and audit obligations.
We may retain and use your personal data to the extent necessary to comply with our legal, tax, reporting and audit obligations.5.5.3 Residual copies.
We take steps to protect data against accidental or malicious loss and destruction, residual copies of your personal data may remain on our backup systems for a limited period of time.