1. INFORMATION WE OBTAIN
1.1 Using our website and software platforms
Our website and software platforms may collect your name, address, email address, and phone number. If you contact us, we may keep a record of that correspondence. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in promotions or competitions.
Cookies are used on our website and software platforms. Most browsers now alert you when a cookie is offered on the webpage and permit you to refuse or accept it. Cookies provide information regarding the computer used by a visitor. We use a persistent cookie to identify you when you return to our website and software platforms and improve your experience. The cookie is downloaded to your computer and stored on the computer’s hard drive. You can adjust the settings on your computer to decline any cookies if you wish. For more information please visit https://www.aboutcookies.org/.
We may use third-party web analytics services on our website and software platforms, such as Google Analytics etc. These service providers help with our analysis of how visitors use the website and software. The information gathered by these means (including data points such as your IP address) will be disclosed to or collected directly by these third-party service providers. If you would like to learn how to opt out of Google Analytics, please click here.
The providers of third-party plug-ins and widgets on our website and software platforms, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the website and your interactions with the plugins and widgets. We may also receive information you have made available to those third party services, including the geographic location of your mobile device and other information about you (such as name, email address, gender, locale, time zone). This information is subject to the privacy policies or notices of the third-party providers of the plugins and widgets.
1.2 Using the Lavanda platforms (Lavanda PMS, Home by Lavanda, Lavanda Agent and Lavanda Residential)
We ask for and collect the following personal information about you when you use any Lavanda Platform (Lavanda PMS, Home by Lavanda, Lavanda Agent and Lavanda Residential). This information is necessary for the adequate performance of the contract between you and Lavanda, and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.
- Account Information: When you sign up for a Lavanda Account, we require certain information, such as your first name, last name, email address and date of birth.
- Profile and Listing Information: To use certain features of the Lavanda service (such as booking or creating a listing with our third party partners), we may ask you to provide additional information, which may include your address, phone number and a profile picture.
- Identity Verification Information: To help create and maintain a trusted environment, we may, from time to time, and with your express consent, collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
- Payment Information: We may require you to provide certain financial information (like your bank account details) in order to facilitate the processing of payments.
- Communications with Lavanda and other Members: When you communicate with Lavanda, we collect information about your communication and any information you choose to provide.
- Safety Certificates: When applicable we may collect evidence of safety checks on your properties (such as Gas Safety Certificates and Electrical safety certificate).
1.2.1 Information you choose to give us
You may choose to provide us with additional personal information in order to obtain a better user experience when using Lavanda Platform. This additional information will be processed based on your consent.
- Additional Profile Information: You may choose to provide additional information as part of your Lavanda profile (Employment Information). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.
- Other Information: You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Lavanda Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Lavanda Platform.
1.2.2 Information that is necessary for the use of the Payment Services
The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services.
- Payment Information: When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account details) in order to process payments and comply with applicable law.
- Identity Verification and Other Information: If you are an user of Home by Lavanda, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
1.3 Information We Collect from Third Parties
Lavanda may collect information about you, including personal information, that others provide when they administer services to fulfil our contract with you (such as managing bookings or payments), or obtain information from other sources and combine that with information we collect about you. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
- Background Information: If you are a Home by Lavanda user or a guest, to the extent permitted by applicable laws and with your consent where required, Lavanda 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.
- Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, 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 (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts.
- Third Party Services: If you book accommodation with a property under Lavanda’s management, the third party platform where you booked may send us information such as your registration and profile information for that service. This information varies and is controlled by that third party or as authorised by you via your privacy settings with that third party. We may pass this information to our guest hosts who may be a third party contractor.
- Third Party Service Providers: Lavanda Uses a range of Third Party Providers to perform specific business tasks for our Guests, Owners and Agent Partners.
Your personal information may, when required, be passed to the following third party service providers. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations.
- Host Contractors
- Maintenance Contractors
- House Keeping Contractors
The information you provide is considered Personal Data and you therefore become a Data Subject in accordance with the The General Data Protection Regulation (GDPR) (EU) 2016/679 (the “Act”).
2. HOW WE USE THIS INFORMATION
We use, store, and process information about you, including personal information, to provide, understand, improve, and develop the Lavanda service, create and maintain a trusted and safer environment, offer marketing services, improve our website and software platforms, and comply with our legal obligations.
If we intend to use the information in any other way, we will provide specific notice of its usage when the information is collected.
2.1 Provide, Improve, and Develop the Lavanda service
- Enable you to access and use the Lavanda service.
- Operate, protect, improve, and optimise the Lavanda service and experience, such as by performing analytics and conducting research.
- Provide customer service.
- Send you service or support messages, updates, security alerts, and account notifications.
- If you provide us with your contact information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorise at the time of collection.
We process this information given our legitimate interest in improving the Lavanda service and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.
2.2 Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
- Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
- Comply with our legal obligations.
- Resolve any disputes with any of our Owners and enforce our agreements with third parties.
- Enforce our Terms of Service and other policies.
2.3 Marketing and our website and software platforms
- To send you information, news and updates about Lavanda. Information about promotions and offers will only be sent to you in accordance with the marketing preferences that you set.
- To ensure that content from our website and software platforms is presented in the most effective manner for you and for your device.
- To send information about, and/or manage your participation in any promotions, surveys, offers, focus groups and market research.
- To respond to any inquiries.
3. INFORMATION WE SHARE
We may disclose information we collect in the following circumstances:
3.1 Third Party Service Providers
We may share your information with third-party service providers who support us in providing our service, such as software vendors and website developers. These business partners will be given limited access to your information under reasonable confidentiality terms.
We may share information about website and mobile app usage (collected through web technologies such as log files and clear gifs) with our third-party business partners who perform services on our behalf, which may include identifying and serving targeted advertisements, content or service fulfilment, or providing analytics services.
We may aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, or anonymised data with third parties.
3.2 Direct Marketing
3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Lavanda may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Lavanda, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, or (v) to protect the rights, property or personal safety of Lavanda, its employees, its Members, or members of the public.
These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Lavanda Platforms secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.
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 Lavanda’s property, its Members and the Lavanda Platforms. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
4. YOUR CHOICES AND RIGHTS REGARDING YOUR INFORMATION
You may exercise any of the rights described in this section before your Lavanda Data Controller 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.
4.1 Managing Your Information
You may access and update your information by contacting your Account or Partner Manager via the intercom chat on our platforms or via the contact details provided directly to you.
You can unsubscribe from email communications from us at any time by clicking on the unsubscribe link provided in each email.
4.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Lavanda Account).
4.3 Data Access and Portability
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).
4.4 Data Retention and Erasure
We generally retain your personal information 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 a Lavanda Platform to you, you can request that we erase your personal information and close your Lavanda Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Lavanda Account for fraud or safety reasons, we may retain certain information from that Lavanda Account to prevent that Member from opening a new Lavanda Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Because we maintain the Lavanda Platforms to protect 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.
4.5 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by Lavanda you may withdraw your consent at any time by contacting your Account or Partner Manager. 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 (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Lavanda override your own.
4.6 Objection to Processing
In some jurisdictions, applicable law may entitle you to require Lavanda not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, Lavanda will no longer process your personal information 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 information is processed for direct marketing purposes, you may, at any time ask Lavanda to cease processing your data for these direct marketing purposes by sending an email to [email protected].
4.7 Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Lavanda before the competent data protection authorities (the Information Commissioner’s Office).
5. DATA TRANSFERS
In the event that Lavanda is merged with or acquired by another company your personal information may be disclosed to our advisers, or any prospective acquirer and their advisers. In the event of a successful transaction, your personal information will be passed on to the new owners of the business.
6. LINKS TO THIRD PARTY SITES
Our website and software platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or third-party partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. CHILDREN’S DATA
We do not knowingly collect information from children under 13. If we discover that we have inadvertently collected information from a child under 13, we will delete that information as soon as possible. Please find our contact details in the ‘How to Contact Lavanda’ section at the bottom of the page if you have any questions about our privacy practices or to let us know if you have reason to believe that we have collected information from a child under 13.
8. HOW WE PROTECT YOUR INFORMATION
Lavanda cares about the security of your information and uses commercially reasonable safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable. We cannot guarantee the security of our servers, nor can we guarantee that information that users supply will not be intercepted while being transmitted to us over the Internet.
If you know or have reason to believe that your Lavanda Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Lavanda Account, please contact us following the instructions in the How to Contact Lavanda section below.
10. HOW TO CONTACT LAVANDA
Last revised 26th June 2019.