Last Updated: September 28, 2018
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
Our primary goals in collecting information are to provide and improve our Site, Application, services, features and content (collectively, the “Service”), to administer your use of the Service and to enable users to enjoy and easily navigate the Service.
When you register with us through the Service and become a Member and when you choose to post a Listing or book an Experience, or when you wish to contact another Member, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Identity Information”). Identity Information includes, but is not limited to, your name, phone number, email address, social security number (SSN), government-issued identification card, and home postal address, but does not include your credit card number or billing information. In order to process some of your transactions through the Service, we may also ask for your credit card number and other billing information (“Billing Information”). We may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Localie may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. (Identity Information, Billing Information and geolocation information together, “Personal Data”). If the address associated with a Listing you post matches that of your credit card billing address, that address would be considered Identity Information. Some Personal Data may be required, like your name and email address, and other Personal Data may be optional, like your date of birth. We use your Personal Data to provide the Service and administer your inquiries.
We collect Personal Data in connection with your registration to join the Service. You can register to join via the Service by completing the required forms.
You may also be permitted to register by logging into online accounts you may have with third party service providers (“SNS”) (e.g. Facebook); each such account, a “Third Party Account”, via the Service as described below. As part of the functionality of the Service, you may link your Localie Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to Localie through the Service; or (ii) allowing Localie to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to Localie and/or grant Localie access to your Third Party Account (including, but not limited to, for use for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating Localie to pay any fees or making Localie subject to any usage limitations imposed by the applicable SNS. If you decide to register by logging into a Third Party Account via the Service, we will obtain the Personal Data you have provided to the applicable SNS (such as your name, email address, profile picture, names of SNS friends, names of SNS groups to which you belong, other information you make publicly available via the applicable SNS and/or other information you authorize Localie to access by authorizing the SNS to provide such information) from your Third Party Accounts and use that information to create your Localie Account and Localie Account profile page and you will become a Member. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available and store (if applicable and as permitted by the SNS and authorized by you) the information in your Third Party Accounts so that it is available on and through your Localie Account on the Service. If there is information about your “friends” your Third Party Account, the information we obtain about those friends, may also depend on the privacy settings such people have with the applicable SNS.
We may also collect the other information that you provide as part of registration and the administration and personalization of your Localie Account profile (e.g., without limitation, zip code (on its own) and individual preferences or demographic information) (“Non-Identifying Information”).
We use your Personal Data (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Data if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your demographic information). We may combine your Personal Data with Non-Identifying Information and aggregate it with information collected from other Localie Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how the Service is used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We also use your Personal Data to contact you with Localie newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or contact us as detailed in the “Changing or Deleting Information” section, below. Please note that we may also use your Personal Data to contact you with information related to your use of the Service; you may not opt out of these notifications.
When you visit the Service, whether as a Member or a non-registered user just browsing (any of these, a “Localie User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to the Service, pages of the Service that you visit, the time spent on those pages, information you search for on the Service, access times and dates, and other statistics. We use this information to monitor and analyze use of the Service and for the Service’s technical administration, to increase the Service’s functionality and user-friendliness, and to better tailor the Service to our visitors' and users’ needs. We also use this information to verify that visitors to and users of the Service meet the criteria required to process their requests. We do not treat Log Data as Personal Data or use it in association with other Personal Data, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Our Site and Application may contain electronic images known as Web beacons (sometimes called single-pixel gifs), which would be used along with cookies to compile aggregated statistics to analyze how the Service is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This would allow us to gauge the effectiveness of our customer communications and marketing campaigns.
As part of the Service, Localie Users may communicate with Localie Members through the Service. The chat rooms always contain not just addresser and addressee but also Localie Customer Care specialist to support them with all service related questions. You must admit that content of your communications within the platform is always visible by Localie Customer Care specialists, thus should be only related to the Service use and must not contain any private data.
The Service can be used to facilitate the listing and booking of Experiences. Listings for such Experiences are made available via the Service by Providers. Listings posted by Providers, ratings and reviews of Members, and the Profile Information (as defined below) of Members, are visible to any Localie User.
To enable or support us in providing the Service, we may share your information, including Personal Data, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
When you create a Localie Account, we will set up a Localie Account profile page for you. Your Localie Account profile page will include your first name and last name as you filled them in during registration. You can select the other items of Personal Data that you wish to be included in your Localie Account profile page – including, but not limited to, a profile picture. We will display your Profile Information in your Localie Account profile page publicly via the Service, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be publicly visible to all Localie Users and consequently should reflect how much you want other Localie Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage members to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your Profile Information at any time.
We may share aggregated information that does not identify you personally and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not identify you personally.
Social Media Platforms. Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our Service. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest. Social media platforms with which we may share your personal data are not controlled or supervised by Localie. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider. Please note that you may, at any time ask Localie to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected]
With Laws and Law Enforcement; Guarantee Program Localie cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Localie or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or appropriate to protect the property and rights of Localie or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
All Members may review, update, correct or delete the Personal Data in their registration profile by contacting us at [email protected] or editing the relevant part of their profile. If you would like us to cancel your Localie Account, please contact us and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your Localie Account. Please note that, if you cancel your Localie Account, any reviews you have posted via the Service will remain publicly viewable via the Service. Please see below for privacy contact information.
Localie takes reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Localie via the Internet.
We may review, scan, or analyze your communications on the Service for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, 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 websites. 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. However, occasionally we may need to manually review some 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 communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
These activities are carried out based on Localie’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
Our Site and Application may contain links to other websites. If you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Data from you. Other websites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
With your consent we may post your testimonial on the Service along with your name. If you want your testimonial removed please contact us.
You may exercise any of the rights described in this section by sending an email to [email protected] Please note that we may ask you to verify your identity before taking further action on your request.
You may access and update some of your information through your Account settings. If you have chosen to connect your Localie Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Localie account).
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine- readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure. We generally retain your Personal Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Service to you, you can request that we erase your Personal Data and close your Localie account. Please note that if you request the erasure of your Personal Data:
Where you have provided your consent to the processing of your Personal Data by Localie you may withdraw your consent at any time by changing your Account settings or by sending a communication to Localie specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where: (a) you contest the accuracy of your Personal Data; (b) the processing is unlawful and you oppose the erasure of your Personal Data; (c) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (d) you have objected to the processing as described here and pending the verification whether the legitimate grounds of Localie override your own.
In some jurisdictions, applicable law may entitle you to require Localie not to process your Personal Data for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Localie will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your Personal Data is processed for direct marketing purposes, you may, at any time ask Localie to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected]
You have the right to lodge complaints about the data processing activities carried out by Localie before the competent data protection authorities.
The Service is not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us. If we become aware that a child under 13 has provided us with Personal Data, we will delete such information from our files.