Privacy Policy of Homads, Inc.

Last Updated: May 8, 2020

Table of Contents

Introduction
Information We Collect
Why We Collect Your Data
How We Use Information We Collect
Sharing & Disclosures
Your Rights
California & Vermont Residents
California Privacy Rights
Users Outside of the United States
Changes to This Privacy Policy
Safeguarding and Securing the Data
Contact Us

1. Introduction

This privacy policy (“policy”) will help you understand how Homads (“us”, “we”, “our”) uses and protects the data you provide to us when you visit and use Homads.com (“website”, “service”).

If you choose to use our Service, then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect are used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

We reserve the right to change this policy at any given time, of which you will be promptly updated. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page.

1.1 Definitions

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Terms of Service (“Terms”), unless otherwise defined in this Privacy Policy.

2. Information We Collect

2.1 Information You Give to Us

2.1.1 Information that is necessary for the use of the Homads Platform.

We ask for and collect the following personal information about you when you use the Homads 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.

Account Information. When you sign up for an Homads 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 Homads Platform (such as booking or creating a Listing), 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 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. To use certain features of the Homads Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
Communications with Homads and other Members. When you communicate with Homads or use the Homads Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

2.1.2 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 Homads Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

Additional Profile Information. You may choose to provide additional information as part of your Homads profile (such as gender, preferred language(s), city, and a personal description). 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, update or add information to your Homads Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of the Homads Platform.

2.1.3 Information that is necessary for the use of the Payment Services.

Homads needs to collect the following information 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 or credit card information) in order to process payments and comply with applicable law.
Identity Verification and Other Information. If you are a Homeowner, Homads 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.

2.1.4 Information We Automatically Collect from Your Use of the Homads Platform and Payment Services.

When you use the Homads Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Homads Platform and Payment Services.

Geo-location Information. When you use certain features of the Homads Platform, 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. Homads may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Usage Information. We collect information about your interactions with the Homads Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Homads Platform.
Log Data and Device Information. We automatically collect log data and device information when you access and use the Homads Platform, even if you have not created an Homads Account or logged in. That information includes, among other things: details about how you’ve used the Homads Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Homads Platform.
Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Homads Platform or engage others to track your behavior on our behalf.
Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting opt-out@homads.com with a description of your request and validation information. Users can access a mechanism for exercising such choice by going to http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. For more information on our use of these technologies, see our Cookie Policy.
Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Homads Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
Payment Transaction Information. Homads Payments collects information related to your payment transactions through the Homads Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and to allow the provision of the Payment Services.

2.1.5 Information We Collect from Third Parties.

Homads may collect information, including personal information, that others provide about you when they use the Homads Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Homads Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Third Party Services. If you link, connect, or login to your Homads Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Background Information. For Members in the United States, to the extent permitted by applicable laws, Homads may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, Homads 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.
Referrals. If you are invited to Homads, the person who invited you may submit personal information about you such as your email address or other contact information.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, 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. We may receive information about you and your activities on and off the Homads Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2.2 Children’s Data.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

3. Why We Collect Your Data

We are collecting your data for several reasons:

To better understand your needs.
To improve our services and products.
To send you promotional emails containing the information we think you will find interesting.
To contact you to fill out surveys and participate in other types of market research.
To customize our website according to your online behavior and personal preferences.

4. How We Use Information We Collect

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Homads Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Homads Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

4.1 Provide, Improve, and Develop the Homads Platform.

We may use the personal information to provide, improve, and develop the Homads Platform such as to:

enable you to access and use the Homads Platform,
enable you to communicate with other Members,
operate, protect, improve, and optimize the Homads 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 Homads Platform and experience, and personalize and customize your experience (such as making Listing suggestions, ranking search results), and facilitate claims with our Homeowner Guarantee, Homeowner Protection Insurance, Experience Protection Insurance or other similar host protection programs, we conduct profiling based on your interactions with the Homads Platform, your search and booking history, your profile information and preferences, and other content you submit to the Homads Platform, and

We process this personal information for these purposes given our legitimate interest in improving the Homads Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

4.2 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,
enforce our Terms of Service and other policies, and
in connection with the activities above, we may conduct profiling based on your interactions with the Homads Platform, your profile information and other content you submit to the Homads Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Homads Platform if such processes detect activity that we think poses a safety or other risk to the Homads 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 Homads Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

4.3 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 Homads 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 Homads or its third party partners,
conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Homads 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 Homads 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 Homads Account, and
invite you to events and relevant opportunities (for example, when you share your Homeowner 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.

4.4 How Homads uses the Personal Information Collected for Payment Services.

We may use the personal information as a part of Payment services such as to:

Enable you to access and use the Payment Services.
Detect and prevent fraud, abuse, security incidents, and other harmful activity.
Conduct security investigations and risk assessments.
Conduct checks against databases and other information sources.
Comply with legal obligations (such as anti-money laundering regulations).
Enforce the Payment Terms and other payment policies.
With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

Homads processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

4.5 SMS Terms for U.S.

For text messaging in the United States, by requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, or otherwise consenting to receive one or more text messages (“Opting In”) or using a Homads arrangement in which Homads sends (or indicates that it may send, or receives a request that it send) one or more text messages (“Text Message Service”), you accept these SMS Terms for U.S. (“SMS Terms”), consent to the handling of your personal information as described in the Homads Privacy Policy, and agree to resolve disputes with Homads as described in our Terms of Service. Message and data rates may apply.

Homads will use reasonable commercial efforts to deliver the automated marketing text messages to the number you provide through compatible wireless carriers. Carriers and Homads are not liable for delayed or undelivered messages. The short code we use for some Text Message Services may not be supported on all U.S. carriers.

Opting In

By Opting In to a Text Message Service:

You expressly authorize Homads to use autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In (i.e., the number listed on the Opt-In form or instructions, or, if none, the number from which you send the Opt-In, or, if none, the number on file for your account). You also authorize Homads to include marketing content in any such messages. You do not have to Opt In or agree to Opt In as a condition of purchase.
You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, request a free paper or email copy of the Opt-In, or to update our records with your contact information, please contact us via the methods described in the Contact Us section. To view and retain an electronic copy of these SMS Terms or the rest of your Opt-In, you will need (i) a device (such as a computer or cell phone) with internet access, and (ii) either a printer or storage space on such device. If you withdraw your consent, certain features of our service may not be available to you. To update information on how we would contact you electronically, visit your Notification settings in your account settings.
You confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorized to Opt In.
You consent to the use of an electronic record to document your Opt-In. To withdraw that consent, update our records with your contact information, please visit your Homads account Notifications settings or contact customer support.
These SMS Terms still will apply if you withdraw the consent mentioned above or opt out of the Text Message Service.

After Opting In, in addition to the main messages the service offers, you may receive one or more welcome messages or administrative messages, such as (in some cases) a request to confirm your Opt-In.

About the Text Message Services and Opting Out

Message and data rates may apply. Unless otherwise noted, Text Message Services send multiple, recurring messages. Homads may terminate any Text Message Service or your participation in it at any time with or without notice, including, for example, before you have received any or all messages that you otherwise would have received, but these SMS Terms still will apply. Text STOP to any promotional message to Opt Out or if applicable update your “Notification” settings on your Homads account.

For additional help, contact customer service.

4.6 Your Choices

You have choices on the promotional messages that you choose to receive.

You can limit the information you provide to Homads. Participation in promotions and marketing programs is voluntary.
You can limit the communications that Homads 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 Homads 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 Homads Account by visiting the Notifications section of your Homads 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.

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 Homads Account or when you participate in promotional activities conducted by Homads 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 Homads 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 Homads. 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 Homads to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@homads.com.

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 Homeowner (and Co-Homeowner, 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 Homeowner (or Co-Homeowner, if applicable) have a confirmed booking, certain information is shared with the Renter to coordinate the booking, such as your profile, full name, phone number, and Accommodation or Experience address.

We don’t share your billing and payout information with other Members.

5.3 Profiles, Listings, and other Public Information.

The Homads 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’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 Homeowners 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 Homads 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 Homads Platform, that content is publicly visible.

Based on our legitimate interest to promote the Homads Platform we may display parts of the Homads Platform (e.g., your Listing page) on sites operated by Homads’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 Homads 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 Homeowners.

Homeowners may need to use third party services available through the Homads Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services or lock providers. Homeowners may use features on the Homads 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. Homeowners 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.

Homads 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 a valid legal request or to respond to claims asserted against Homads, (iii) to respond to a valid legal request 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 (See more information on Homads’s Law Enforcement Guidelines here), (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 Homads, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Homeowner 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 Homads 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 Homads’s property, its Members and the Homads Platform. In instances where we comply with legal requests without notice for these reasons, we may 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 Service Providers.

Homads uses a variety of third-party service providers to help us provide services related to the Homads Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”).

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Homads Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions .

Homads and the Homads Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

5.7 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.

5.8 Third Party Partners & Integrations

The Homads Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Homads doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Homads, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

Parts of the Homads Platform may use third party services such as Google Maps/Earth services, including the Google Maps API(s), and WePay and Chargebee for Homads Payments. Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy, WePay Privacy Policy, Chargebee Privacy Policy.

5.9 Links to Other Websites

Our website contains links that lead to other websites. If you click on these links Homads is not held responsible for your data and privacy protection. Visiting those websites is not governed by this privacy policy agreement. Make sure to read the privacy policy documentation of the website you go to from our website.

6. Your Rights

Consistent with applicable law, you may exercise any of the rights described in this section before Homads Data Controller and Payments Data Controller. See here for information on data subject rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Account settings. If you have chosen to connect your Homads 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.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Homads Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain 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).

6.4 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. In certain jurisdictions, you can request to have all your personal information deleted entirely." 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 an Homads Account for fraud or safety reasons, we may retain certain information from that Homads Account to prevent that Member from opening a new Homads Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Homads may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Homads Platform, even after your Homads Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the Homads Platform 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.

If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to Homads 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 (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 “Rectification of Inaccurate or Incomplete Information” and pending the verification whether the legitimate grounds of Homads override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Homads 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 Homads and/or Homads Payments 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 Homads to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@homads.com.

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section below or with a supervisory authority.

7. California & Vermont Residents

Homads Payments will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

8. California Privacy Rights

California law permits Members who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section for where to send such requests. Homads do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. See here for information on data subject rights requests and how to submit a request. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government government issued identification, and the authorized agent’s valid government issued identification.

We do not sell personal information to third parties. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

9. Users Outside of the United States

If you are a non-U.S. user of the Services outside of the US, by using the Services and/or providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your information, you consent to such transfer.

10. Changes to This Privacy Policy

Homads reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Homads Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Homads Platform will be subject to the revised Privacy Policy.

11. Safeguarding and Securing the Data

Homads is committed to securing your data and keeping it confidential. 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 Homads Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Homads Account, please contact us following the instructions in the Contact Us section below.

12. Contact Us

If you have any questions or complaints about this Privacy Policy or Homads’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at: vi@homads.com.