1. INFORMATION WE COLLECT
1.1 Information You Give to Us.
1.1 Information that is necessary for the use of the Carma Share Platform.
We ask for and collect the following personal information about you when you use the Carma Share Platform. 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. Without it, we may not be able to provide you with all the requested services.
- Personal Details. When you fill the Carma Share form, 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 Carma Share Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number.
- Identity Verification Information. To help create and maintain a trusted environment, we may 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.
- Communications with Carma Share and other Members. When you communicate with Carma Share or use the Carma Share Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.
2. HOW WE USE INFORMATION WE COLLECT
We may use, store, and process personal information to (1) provide, understand, improve, and develop the Carma Share Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Carma Share Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.
2.1 Provide, Improve, and Develop the Carma Share Platform. We may use the personal information to provide, improve, and develop the Carma Share Platform such as to:
- enable you to access and use the Carma Share Platform,
- enable you to communicate with other Members,
- operate, protect, improve, and optimize the Carma Share Platform 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 contacts’ 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 authorize at the time of collection,
- to operate, protect, improve, and optimize the Carma Share Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), Owners Protection Insurance or other similar Owner protection programs, we conduct profiling based on your interactions with the Carma Share Platform, your search and booking history, your profile information and preferences, and other content you submit to the Carma Share Platform, and
- enable your use of our enterprise products.
We process this personal information for these purposes given our legitimate interest in improving the Carma Share Platform 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. We may use the personal information to create and maintain a trusted and safer environment such as to:
- 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 Members and enforce our agreements with third parties,
- in connection with the activities above, we may conduct profiling based on your interactions with the Carma Share Platform, your profile information and other content you submit to the Carma Share Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Carma Share Platform if such processes detect activity that we think poses a safety or other risk to the Carma Share Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.
We process this personal information for these purposes given our legitimate interest in protecting the Carma Share Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:
- send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Carma Share or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google),
- personalize, measure, and improve our advertising,
- Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Carma Share or its third party partners,
- conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Carma Share Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
- enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Carma Share Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have an Carma Share Account, and
- invite you to events and relevant opportunities (for example, when you share your Owner story, we may use the information provided to reach out to you to invite you to relevant events).
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
2.4 Your Choices
You have choices on the promotional messages that you choose to receive.
- You can limit the information you provide to Carma Share. Participation in promotions and marketing programs is voluntary.
- You can limit the communications that Carma Share sends to you.
- To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your Carma Share Account.
- To revoke permissions that you may have given to send promotional text messages, text STOP in response to any message.
- You can always update your notification settings within your Carma Share Account by visiting the Notifications section of your Carma Share Account. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Carma Share Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your a Carma Share Account, please contact us following the instructions in the Contact Us section below.
4. CONTACT US
5. SHARING & DISCLOSURE
5.1 Advertising and Social Media; Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Carma Share Account or when you participate in promotional activities conducted by Carma Share partners or third parties.
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 products and services or the Carma Share Platform. 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.
The social media platforms with which we may share your personal information are not controlled or supervised by Carma Share. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.
Please note that you may, at any time ask Carma Share to cease processing your data for these direct marketing purposes by sending an e-mail to firstname.lastname@example.org.
5.2 Sharing between Members.
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:
- When you as a Renter submit a booking request, certain information about you is shared with the Owner (and Co-Owner, if applicable), including your profile, full name, the full name of any additional Renters, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
- When you as a Owner (or Co-Owner, if applicable) have a confirmed booking, certain information is shared with the Renter (and the additional Renters they may invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Accommodation or Experience address.
- When you as a Owner invite another Member to become a Co-Owner, you authorize the Co-Owner to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, calendar, Listing information, Listing photos, and email address.
- When you as a Renter invite additional Renters to a booking, your full name, travel dates, Owner name, Listing details, the Accommodation address, and other related information will be shared with each additional Renter.
- When you as a Renter initiate a Group Payment Booking Request certain information about each participant such as first name, last initial, profile picture as well as the booking details is shared among all participants of the Group Payment Booking Request.
We don’t share your billing and payout information with other Members.
5.3 Profiles, Listings, and other Public Information.
The Carma Share Platform lets you publish information, including personal information, that is visible to the general public. For example:
- Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.
- Listing pages are publicly visible and include information such as the Accommodation or Experience’s approximate location (neighborhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, your public profile photo, aggregated demand information (like page views over a period of time), and any additional information you choose to share.
- After completing a booking, Renters and Owners may write Reviews and rate each other. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Carma Share Platform (such as the Listing page).
- If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Carma Share Platform, that content is publicly visible.
Based on our legitimate interest to promote the Carma Share Platform we may display parts of the Carma Share Platform (e.g., your Listing page) on sites operated by Carma Share’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.
Information you share publicly on the Carma Share Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
5.4 Additional Services by Owners.
Owners may need to use third party services available through the Carma Share Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services or lock providers. Owners may use features on the Carma Share Platform to share information about the Renter (like check-in and check-out dates, Renter name, Renter phone number) with such third party service providers for the purposes of coordinating the stay, managing the Accommodation, or providing other services. Owners are responsible for third party service providers they use and ensuring those service providers process Renter information securely and in compliance with applicable law including data privacy and data protection laws.
5.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.
Carma Share and Carma Share Payments may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax 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 Carma Share, (iii) to respond to valid 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, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Carma Share, its employees, its Members, or members of the public. For example, Owner tax information may be shared with tax authorities or other governmental agencies.
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 Carma Share Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud 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 Carma Share’s property, its Members and the Carma Share Platform. 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.
5.6 Corporate Affiliates.
To enable or support us in providing the Carma Share Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.
- Sharing with Carma Share. Even if your country of residence is not Greece, your information may be shared with Carma Share, Inc. which provides the technical infrastructure for the Carma Share Platform, product development and maintenance, customer support, trust and safety and other business operation services to other Carma Share entities. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Carma Share Platform globally.
- Sharing with Carma Share Payments. In order to facilitate payments on or through the Carma Share Platform, certain information as described above in “Information that is necessary for the use of the Payment Services” section above, may be shared with the relevant Carma Share Payments entity. The data sharing is necessary for the performance of the contract between you and us.
Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve the Carma Share Platform and our affiliates’ services.
5.7 Information Provided to Enterprise Customers.
If you have linked your Carma Share Account to the Carma Share Account of a company or other organization (an “Enterprise”), added your work email address, or have a booking facilitated via another party (such as the future employer or other entity) or used a coupon in a similar capacity in connection with an Enterprise (such as using a coupon to pay for an accommodation for an enterprise related event like employment onboarding, orientation, meetings, etc.) through one of our Enterprise products, that Enterprise will have access to your name, contact details, permissions and roles, and other information as required to enable use by you and the Enterprise of such Enterprise products.
5.8 Owner Information Provided to Carma Share for Work Customers.
If a booking is designated as being for business purposes and made by a Renter affiliated with an Enterprise, and the Enterprise is enrolled in our Carma Share for Work , such as a booking made for business purposes using a coupon provided by an Enterprise, we may disclose information related to the booking to the Enterprise, such as the name of the Owner, the Accommodation address, booking dates, pricing, Listing details, and other related information, to the extent necessary for the adequate performance of Carma Share’s contract with the Enterprise and to provide the services. . At the request of the Enterprise or the Renter, we may also share this information with third parties engaged by the Enterprise to provide travel management, travel planning, financial reporting, personnel management, crisis management, or other services.
5.9 Renter Information Provided to Carma Share for Work Customers.
If you have linked your Carma Share Account with an Enterprise, and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to the Enterprise to the extent necessary for the adequate performance of Carma Share’s contract with the Enterprise. Typically, this includes information related to the booking, such as your name, dates of the booking, number of Renters, pricing, Listing details, the Accommodation address, and other related information. At the request of you or your Enterprise, we may also disclose this information to service providers engaged by it, such as companies that provide travel management, financial reporting, personnel management, crisis management, or other services. In the event of a dispute, emergency, or similar situation involving a booking identified as being for business purposes, Carma Share may also share additional relevant information it believes is necessary to safely and quickly address the situation.
5.10 Programs with Managers and Owners.
We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, Renter booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a Owner lives and/or the listing is to facilitate Ownering services, security, billing, and other services that may be provided.
5.11 Business Transfers.
5.12 Aggregated Data.
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.