Privacy and Data Protection

Thank you for wanting to know more about the way we handle and treat your data - it is extremely important to us and so we are delighted you want to know more about it.

Our terms and conditions, and the privacy notices below, are all written to be fully compliant with European privacy and data regulations (GDPR). It's all written in language that is designed to be understood and read by a 'normal' (apologies lawyers) person.

But to help you along, here are the basics - for us it isn't just the letter of the law that applies here, it is the spirit and principles we take seriously, to protect your data and your relationship with us:

OVO Network respects your right to privacy and takes your privacy seriously. We are committed to protecting and securing any personal information you give us. We don't sell or share data and we will try and only contact you on things you actually care about.

We only hold your data because you have given it to us - if you don't want us to do that, we won't. If you are worried about it - don't collect or send any sensitive data through our system. You have control over how long we keep data for, and when you want us to automatically delete it.

We are law-abiding citizens, and comply with all the laws that apply to us - that means, if you want to use our service, you have to too :-). If you have any questions please email us at privacy@ovonetwork.com

Enjoy!

OVO Network Privacy Policy

Last updated: 24/5/2018

Introduction

This Privacy Policy relates to our use of any personal information we collect from you via our online services including our Website, App and online booking APIs (i.e., online-booking tools used by our partners and Owners) ("Online Services") or give us in any other way (together, the “Services”).

What does OVO Network do?

OVO Network provides an online marketplace for people to search for and rent short-term vacation properties or list their properties to be rented. Properties can be listed via our Online Services. We offer customer support to you through our customer services team to deal with any issues you have with your listing or booking such as complaints.

As used in this Privacy Policy, the term “Owner” refers to a property owner, lessor or property manager who is, or in the process of, listing one or more properties on our Online Services. The term “Guest” refers to a user who is using the site to look for properties to rent.

Key things you should know about how we use your information:

We use your information (and the information of those travelling with you) for purpose of enabling travel bookings.
This includes sharing your booking information with our Suppliers or Owners in order for them to fulfil your booking.
We also engage other third-party vendors who provide services or functions on our behalf.
Where you choose to receive marketing information, we will let you know about any special offers that may be of interest to you, including our loyalty programs. You are able to opt-out at any time by sending an email to privacy@ovonetwork.com or unsubscribing as instructed in our communications.
You can contact us about updating or accessing your information by sending an email to privacy@ovonetwork.com
We use cookies and similar technology to enable the functionality of some parts of Online Services. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Online Services may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
From time to time and usually following an interaction with us, we will ask you for your feedback to ensure we are providing the best service we can.
The data controller of your personal information is OVO Network Software Services Limited. We recommend that you read this Privacy Policy in full to ensure you are completely informed. However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant quick link in the menu.

If you have any questions or concerns about our use of your personal information, then please contact us by sending an email to privacy@ovonetwork.com.

External Links

If any parts of our Online Services link you to other websites or Apps, those newly opened links do not operate under this Privacy Notice. We therefore recommend you examine the privacy notices/statements/policies posted on those other online areas to understand their procedures for collecting, using, and disclosing personal information.

What personal information do we collect and why?

Information that you provide directly to us

We may ask you to provide personal information directly to us. For example, we may ask you to provide your contact details such as full name, telephone number and email address in order to:

enable your travel booking;
create or register an account with us;
provide the services and information you request such as details about your booking;
have an emergency contact number for you;
update OVO Network membership information;
subscribe you to our marketing communications; and/or
submit your enquiries.

You will also need to provide your billing information (such as credit card number, cardholder name and expiration date) to make a payment.
You may also provide information about any Guests on your booking, your marketing preferences and when you participate in a survey or competition. When creating an account, you will provide a login name/member ID as well as a password.
Your personal information may also be linked to Cookies to enable the proper operation of our Online Services, store your travel searches on our Online Services, and collect information on how you used our Online Services. For more information, please see our Cookie Policy.
For Owners, additional personal information may be collected for listing a property, communicating with a user or Guest and when you set up financial account information for payment processing.

Special Categories of Personal Information

Certain types of personal information, such as some government-issued identification numbers, religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:

Health-related information may be needed for you to arrange or book appropriate travel accommodation and accessibility or facility requirements.
Government-issued identification numbers like passport or driver’s license number may be required for vehicle rental or other travel reservation.
Other information that you can specify at your option and which may imply or suggest information like religion, health or other information, such as dietary needs.

Information Voluntarily Provided About Your Travel Companion(s)

If you make a reservation with our customer service team over the phone, and if as part of that reservation you wish to purchase additional travel products on behalf of someone else, we will request personal information about that individual. You should obtain the consent of any other individual(s) prior to providing us with their personal information. Should your travel companion want to amend or delete their information themselves they can contact us directly by sending an email to privacy@ovonetwork.com

Information that we collect automatically

When you visit us on our Online Services, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type (such as Firefox, Safari, or Internet Explorer), your Internet Service Provider (ISP), your operating system and carrier. For website users, details of any referring website or exit pages as well as broad geographic location (e.g., country or city-level location) are also collected. We may also collect other technical information such as how your device has interacted with our Online Services, including the pages accessed and links clicked, i.e., trips viewed and the time and date of these.
Collecting this information enables us to better understand the visitors who come to our Online Services, where they come from, and what content on our Online Services is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Online Services for our visitors, for example, to customize your user experience, tailor your searches and show you advertisements that may be of interest. We also use this automatic information to prevent and detect fraud.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology”

Information we collect when you communicate with us via the following methods

Social Media:

If you make use of any of our social media features on our Online Services or otherwise through a social media provider, we may access information about you via that social media provider in accordance with their privacy policy. For example, we offer the option to register with our website via the “Facebook Connect” feature, enabling you to register with our website using your Facebook account data without entering the required data manually on our webpage.
When using a social media feature, if you have chosen to include it in your social media account, we may access information such as your name, profile picture, gender, birthday, email address, town or district and any other information you have chosen to make available. Subject to your privacy settings, we access information that you provide to a social media provider regarding your respective locations (“Location Data”) to provide you with relevant content. We do not store or use any data related to the friends you are connected with on a social media site.
We may also access information from social media providers about your use of an App that we run on their website. Therefore, we encourage you to review the privacy policy of any social media provider you use.

Call Monitoring and Recording:

Calls to and from our customer service teams may be recorded or monitored for quality control purposes, analytics, to protect us in the event of a legal dispute and for staff training. Call recordings will be maintained consistent with this Privacy Policy. Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

Other Online Communications:

Any interactions you have with us or Owners through our Online Services, such as chat, may be recorded and monitored for training and quality control purposes, to protect us in the event of a legal dispute and for staff training. This information will be processed and maintained consistent with this Privacy Policy.
When you choose to communicate with an Owner via our Online Services, your name and other information you supply will be visible to the relevant Owner so that they can reply to you. Such communications are subject to the Guest Terms and Conditions posted on our site.

Guest and Owner Reviews

We may collect reviews written by Guests on a property they have stayed in (“Guest Review”) and/or written by Owners on a Guest’s stay (“Owner Reviews”). Guest Reviews are displayed on our Site, while Owner Reviews will only be disclosed to Owners who receive an inquiry or booking request from that Guest. Owner Reviews enable an Owner to know more about the Guest who has contacted them and therefore increase trust in our platform. Owners must comply with the Owner Terms and Conditions and applicable law and this includes not using any information about a Guest to discriminate against such Guest.
We are not responsible for the Owner deducing your identity from the content of your review and contacting you directly.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we and our vendors use, why, and how you can control Cookies, please see our Cookie Policy. We may combine the information you give us with information related to your transactions and information we receive about you from third parties who carry out services on our behalf. The information received via Cookies and similar technologies may allow us to cross track devices and users' clickstream data associated with the Cookies.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.

Who do we share your personal information with?

We may disclose your personal information to the following categories of recipients:

Third party services providers who provide data processing services to us (for example, to support the delivery of; provide functionality on; or help to enhance the security of our Online Services), or who otherwise process personal information for purposes such as credit card processing, business analytics, customer service, marketing, distribution of surveys or sweepstakes programs, to facilitate the delivery of online advertising tailored to your interests and fraud prevention. Where third-party service providers have access to data they will only collect information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
Business partners with whom we may jointly offer products or services, or whose products or services may be offered on our Online Services. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasions share information about you, including your personal information, with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
If you were referred to our Online Services via a hyperlink from an external site of one of our partners, we will share your personal information, browsing activity on our Online Services, and purchase information with the referring partner.
Travel suppliers such as hotel, car rental, insurance, Owners, and, where available, activity providers, rail and cruise lines, who fulfil your travel reservations. All services provided by a such third-party travel supplier are described as such. These suppliers are not controlled by OVO Network and personal information disclosed to them is subject to the applicable supplier's privacy policy and security practices. Please note that these travel suppliers or Owners also may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or respond to a communication you submit in accordance with their own independent Privacy Policy as applicable.
Your online profile may be viewable by other users, including Owners, of our Online Services. For Owners, property listings may display statistics of usage, such as information related to the responsiveness of owners.
Social media providers when you access certain social media features through our Online Services, you will share information with the social media provider (such as Facebook). The information you share will be governed by the social media's privacy policy (including any data we may access via the social media provider). Social media providers should inform you about how you can modify your privacy settings on their site.
If you connect your OVO Network account to a social media provider, such as through “Facebook Connect,” we may make available on that social media provider's platform the information related to your use of our Services, such as any rewards and loyalty program we may introduce or the reviews you post on our Online Services. Such information may also be published on that social media provider’s websites or services. Information made available on the social media provider's platform will be attributed to the social media provider account to which your OVO Network account is connected.
You may choose to disable automatic publishing by the social media provider of such information by editing your privacy settings for that social media provider. We will not provide any other social media provider with access to your OVO Network account number or information. If you connect your OVO Network account to a social media provider, we may also share your user name and your profile picture from that social media provider to other OVO Network members. You may choose to disable such sharing of information by editing your privacy settings on that social media provider’s site.
Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. This includes applicable tax authorities or other authorities allowed to collect taxes, where necessary to pay taxes from or on behalf of Guests or Owners to tax authorities in accordance with the Online Services Terms and Conditions and to comply with any valid request;
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company or this website, our customers, or others; and in connection with our Terms and Conditions and other agreements;
In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Policy; or
Any other person with your consent to the disclosure. We are not able to list every specific recipient in this Privacy Policy due to the volume of recipients and frequency of changes to this information. The categories of recipients are explained in more detail in the sub paragraphs of this section above, for example, travel suppliers such as Owners, hotels, car rental companies and activity providers, who enable us to fulfil your booking. If you have any questions about third-party data sharing, please contact us at the information provided at the bottom of this Privacy Policy.
On occasion, we share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our website receives or the most popular properties and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope will be of interest to our users.

How do we use your information?

Our legal basis for processing personal information (EEA visitors only)

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it.

We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we will have a legal obligation to collect personal information from you such as where it is necessary to use your transaction history to complete our financial and tax obligations under the law.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you, for security verification purposes when you contact us and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

How do we determine what our Legitimate Business Interests are?

We carry out an assessment to ensure that:

(i) Our interest in the use of your data is legitimate (i.e., we have a clear business need); and

(ii) The business need, on balance, does not override your privacy rights.

When determining this, we assess the potential impact a specific use of the data may have on you as a customer and weigh this against our own business needs to ensure that we get the balance right. We also apply a series of security measures to minimise any potential risks.

By way of example in practice we would consider that the collection of our customers’ marketing preferences in the course of a booking is a legitimate business interest to have as an online ecommerce company. We believe that this does not unduly impact your privacy rights as you may, most definitely, want to hear about our products and services going forward. However, to protect your privacy rights we ensure that you can opt out of these communications at any time, in your account, in the email itself or through customer services.

In accordance with the legal grounds above, we use the information we collect to:

fulfil the transactions that you make, such as for Guests: booking a property or hotel, or for Owners: to list a property;
provide you with travel confirmations and important travel updates for your upcoming trip (via email or SMS);
verify your identity for fraud prevention purposes;
manage your account, including processing payments;
communicate with you in general, particularly if there is a change to your booking;
provide customer services related to your booking or to respond to any inquiry you make;
facilitate communication between you and Owner;
measure interest in and improve our products, services, and website functionality;
notify you about special offers, coupons, sweepstakes and travel-related products and services that may be of interest to you. You may receive these by email, post or via advertisements on third-party sites, including through social media;
otherwise customize your experience with this website or App;
reward you as part of any reward and recognition program you choose to join (whether this is our program or that of a third party);
obtain information from you, including through feedback you give or surveys you complete;
carry out statistical analysis about the use of our website and Apps and the services we offer to improve each aspect of what we do;
protect our rights as a company including our intellectual property for example;
resolve disputes, collect fees, or troubleshoot problems;
prevent potentially prohibited or illegal activities;
enforce our Terms and Conditions; and
as otherwise described to you at the point of collection.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us by sending an email to privacy@ovonetwork.com

How do we protect your personal information?

We want you to feel confident about using our Online Services to make travel arrangements, and we are committed to protecting the information we collect. While no Online Services can guarantee absolute security, we have implemented appropriate technical and organisational measures to protect the personal information that we collect and process about you. For example, we use encryption when transmitting your sensitive personal information between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your information. In addition, only authorised employees are permitted to access personal information, and they may only do so for permitted business functions.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident and outside of the EEA. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice when transferred outside of the EEA.

We ensure that any of our third-party service providers to whom a data transfer is made has appropriate safeguards in place to protection your personal information. The adequacy mechanism may be i, adequate country status, i.e., based in a country that the European Commission has deemed "adequate" since its data protection standards are similar to the European Union; ii, Standard Contractual Clauses; or iii, EU-US and Swiss-US Privacy Shield.

Data Retention

We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise the data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We will anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis over longer periods.

Your information rights

You can deactivate your account at any time by sending an email to privacy@ovonetwork.com. After you deactivate an account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time. If you wish to delete your data, please contact us by sending an email to privacy@ovonetwork.com

Your data protection rights [EEA residents]

If you are a resident of the European Economic Area, you have the following data protection rights:

If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by sending an email to privacy@ovonetwork.com
If you request access to your personal data we will confirm whether we hold your information and provide you with a copy, explaining how we process it and why, how long we store it for and your rights associated with it.
If you request deletion of your personal information, we will erase it. Please do note that we will need to retain any information that we require to fulfil our legal obligations or to establish, exercise or defend a legal claim.
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by sending an email to privacy@ovonetwork.com
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here).

The easiest way to submit your request to us is by sending an email to privacy@ovonetwork.com

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Changes to This Notice and How to Contact Us

Updates to this Privacy Policy

Changes to this Privacy Policy will be made when required in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

If you have any questions about changes to this Privacy Policy, please contact us by sending an email to privacy@ovonetwork.com