We are serious about protecting the privacy of our users. This Privacy Policy describes how we use and protect your personal data. It applies to SleepingTown.com, SleepingRome.com, SleepingVenice.com and any other websites managed by us where this policy is linked to in the footer of the page (which we have collectively called the “Site” in this policy).

The Site is operated by Hollistay Inc. 

The terms “users” or “you” as used in this Privacy Policy, refer to both travelers, who use the Site to look for properties to rent, and members who join the Site and list their properties for rent. It also applies to other visitors to our site - for example our investors or those applying for a job through the site.

We use information collected about you as explained in this Privacy Policy. The Site may contain links to third parties' websites. We're not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those websites before either agreeing to their terms or using those websites. Unless we explain otherwise in this policy, the words and phrases used in this policy have the same meaning as in the Terms and Conditions of Use - available at Terms & Conditions.

We may occasionally amend this Privacy Policy to reflect regulatory requirements, advances in technology, Site updates and changes in our information collection and disclosure practices. Any new policy will automatically be effective when it is published on the website. You should therefore return here regularly to view our most up to date Privacy Policy. You should also print a copy for your records.

Who processes your personal data, and where?

Your personal data (also referred to as personal information) - that is, data that identifies you, or from which you are identifiable - will be collected, processed, stored and used by us, and/or  passed to and processed other data processors acting under our instructions. Personal data contributed by or collected from users may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using our Site, you acknowledge and agree that you may be transferring your personal data outside of the country in which you have contributed it (“your country”), and that you consent to any transfer of information outside of your country.

The information we gather

At various times you may give your personal data to us. For example, in order to process a request or inquiry from you, we may need to know all or some of the following: your full name, address, telephone number, e-mail address, your current location, and, in the case of a member's listing, a method of payment. You may also give personal data to us at other times, such as when registering on the Site or when submitting an advert for a property. We may also gather information from web cookies. You can find out more about they operate in the relevant section of this policy below. We also can collect IP addresses, mobile device identifier details, your location, navigation and click-stream data, the time of accessing the website, homes you viewed, what you searched for, the duration of your visit, and other details of your activity on the Site. If you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information that way too. For further details on how we collect personal data, see Surveys and Newsletters below. We obtain data from you either by you inputting your personal details, by the automatic collection of information about you as you use the Site, when we speak to you, or from third parties. Third party information may include credit information which we use to prevent and detect fraud, information from your mobile provider if you are accessing the Site over a mobile device or information from a third party such as a social media or travel opinions site where you have asked us to share your data with them. 

How we use your personal data

Our primary purpose in collecting your personal data is to provide you with the services you request and those which we believe will optimize your use of the Site. You agree that we may use your personal data for the following purposes:

• For the services or to support your request; 

• To contact you from time to time with user or service updates; 

• To send other messages that help us provide our services on the Site;

• To assist people you have done business with. For example if you are an owner and a traveler who has booked or inquired   with you needs your details we may pass them on; if you are a traveler and an owner you have booked with needs to contact you we may give them your details; 

• To customize, measure, report on and improve our services, content and advertising; 

• To promote services related to the Site or those of the Hollistay group and/or our affiliates; 

• To compare information for accuracy, and verify it with third parties; 

• To prevent, investigate or prosecute activity we think may be potentially illegal, unlawful or harmful and 

• To enforce our Privacy Policy and/or our Terms or any other purpose referenced herein or therein.

We collate statistics about site traffic, sales and other commercial information which we pass onto third parties to assist us in improving the services we provide to you. We also use demographic information to tailor the Site and we share that information with third parties so that they can build up a better picture of our customer base and general consumer trends.

If you are a member, we will also be able to contact you about your account and your use of our services.

How We May Disclose Your Personal Data

We may disclose your personal data to enforce our policies, or where we are permitted to do so by applicable law, such as in response to a request by a law enforcement or governmental authority, or in connection with actual or proposed litigation, or to protect our property, people and other rights or interests.

We may also share your personal data with:

•  One of our partners if you've requested their services or if you’ve requested to be provided with information by them;

•  Another member if you have done business with them;

•  A third party performing services on our behalf; 

•  Other services in the Hollistay group and/or affiliates; or 

•  Other companies or business entities, for example if we are thinking of a merger with or sale to that company or business entity; or

•  Other companies we work with to feature all or part of our member's property listings or otherwise provide promotional or other services related to our or Hollistay group’s business. This might include featuring your listings and photographs on other websites; or

•  Any third party you have asked us to share your personal data with – such as Facebook if you have asked us to connect with your Facebook account.

You may have accessed our website through a hyperlink from the website of one of our trading partners. If so, you consent to your personal details and purchase information, including behavioral patterns, being shared with that trading partner in accordance with our contractual relationship with them.

In the unlikely event that We or some of Hollistay Inc. assets transferred to a third party, your personal information, as a valuable asset, may also be transferred. Potential purchasers and their advisors may have access to data as part of the sale process. However, use of your personal information will remain subject to this Privacy Policy. Similarly, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy, or administration. Our customer database could be sold separately from the rest of the business, in whole or in a number of parts. It could be that the purchaser's business is different from ours, too.

Newsletters

If you sign up as a owner on the Site, you will receive our Owner newsletter, which is an integral part of the services we provide. Traveler users of the Site will be given the option to receive our Traveler newsletter when they register with us. We may offer different newsletters from time to time intended to enhance the services we offer. Users may cancel their subscription to these newsletters at any time, although it may take a short while for the changes in your preferences to become effective.

Surveys

We also use surveys to collect information about our users. From time to time, we request users' input in order to evaluate potential features and services. The decision to answer a survey is completely yours. We use information gathered from surveys to improve our services.

Games

From time to time we may run games on the Site. These games may allow for connectivity with other users or third parties. If that is the case you consent to your personal data being transferred accordingly.

Telephone Calls

As well as collecting data online and from correspondence we may also speak with you face to face (for example at an Owner’s meeting) or by telephone. We frequently record telephone conversations. Those recordings are also governed by this Privacy Policy and we keep this data in the same way that we keep other data. Recordings of calls may also be transferred to locations or processed worldwide.

How Do We Protect Your Personal Information Once We Have It?

We take reasonable technical and organizational measures to guard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by the Site reduce our vulnerability to security problems to a level appropriate to the type of data involved. We have security measures in place to protect our user database and access to this database is restricted internally. 

If you have asked us to share data with third party sites, however (such as Facebook) their servers may not be secure. Credit card information is generally stored by our credit card processing partners and we ask them to keep that data secure. We also use third parties to help us optimize our website flow, content and advertising (see below). 

Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data. 

 

Phishing or False emails

If you receive an unsolicited email that appears to be from us or one of our members that requests personal information (such as your credit card), or that asks you to verify or confirm your account or other personal information by clicking on a link, that email was likely to have been sent by someone trying to unlawfully obtain your information, sometimes referred to as a "phisher" or "spoofer." We do not ask for this type of information in an email. Do not provide the information or click on the link. Please contact us at Customer Support if you get an email like this.

Job applicants, current and former employees

If you use the Site to apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example where we want to take up a reference, will not do so without informing you beforehand unless the disclosure is required by law. Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalized statistical information about applicants to help inform our recruitment activities, but individuals should not be identifiable from that data. 

Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give you more details about how we hold employee details.

How do I correct or update my information?

You can see any personal information processed by us. The best way of seeing this if you are an Owner is to log on to your account by using the ‘Owner Login’ tab at the top of the screen. You can see your basic details and correct or update them there at any time to suit you. We also want to give you the opportunity to identify any inaccuracies in any other information we hold about you. Where possible, if we're told about the inaccuracy of any personal information, we will make appropriate corrections. You can ask to see, update or amend any information we hold on you by contacting us. 

 

How do I opt-out of receiving marketing communications from you?

We will contact you from time to time for marketing purposes. Unless you have opted out, this could include contacting you by phone or email. 

You may opt-out of receiving marketing communications from us by the following means:

1.  Contact us at Customer Support;

2.  Follow the instructions included in each communication or newsletter;

3.  Use the Unsubscribe function; 

Please remember that if you change your preferences it may take a short time for those preferences to become effective.

How long will we keep your personal data?

We will retain your personal data only as long as is necessary for the purposes to which you consent under the Terms and Conditions and this Privacy Policy, or as is required by applicable law, and then we will delete it.

How do I contact you?

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, we encourage you to contact us at Customer Support.