Last Updated: June 6, 2023

This Privacy Policy describes how eSimply Travel, RBO Kaubandus OÜ and its affiliates (“we,” “us,” or “Company”), process personal information in relation to your use of the Company Platform. Depending on where you live and what you are doing on the Company Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information describing how we process personal information for those regions and services.

1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).

2. PERSONAL INFORMATION WE COLLECT

2.1 Information Needed to Use the Company Platform.

We collect personal information about you when you use the Company Platform. Without it, we may not be able to provide all services requested. This information includes:

• Contact, Account, and Profile Information. Such as your first name, last name, phone number, postal address, email address, and date of birth.
• Payment Information. ​​Payment information relating to you, such as your payment card information to complete a booking.

2.2 Information You Choose to Give Us.

You can choose to provide us with additional personal information. This information may include:

• Information About Others. Such as a payment instrument belonging to another person or information about a co-traveller. By providing us with personal information about others, you certify that you have permission to provide that information to Company for the purposes described in this Privacy Policy and you have shared the Company Privacy Policy with them.
• Other Information. Such as when you fill in a form, add information to your order, respond to surveys, post to community forums, participate in promotions, communicate with Company Support and other Members, import or manually enter address book contacts, provide your address and/or geolocation, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the Company Platform and Our Payment Services.

When you use the Company Platform and Payment Services, we automatically collect personal and other information. This information may include:

• Geolocation Information. Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, additional services you have added, and other actions on the Company Platform.
• Log Data and Device Information. Such as details about how you’ve used the Company Platform, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the pages you’ve viewed or engaged with before or after using the Company Platform. We may collect this information even if you haven’t created a Company account or logged in.
• Cookies and Similar Technologies.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.

3. HOW WE USE INFORMATION WE COLLECT

We use personal information as outlined in this Privacy Policy.

3.1 Provide, Improve, and Develop the Company Platform. We may process this information to:

• enable you to access the Company Platform and make and receive payments,
• process your request,
• perform analytics, debug, and conduct research,
• provide customer service training,
• send you messages, updates, security alerts,
• personalize and customize your experience based on your interactions with the Company Platform, your search and booking history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products and accommodation services.

If you provide us with your contacts’ information, such as your friends or co-travellers, we may process this information to: (i) facilitate your referral invitations, (ii) share your trip details and facilitate trip planning, (iii) detect and prevent fraud, and (iv) facilitate your requests or for any other purpose you authorize.

3.2 Create and Maintain a Trusted and Safer Environment. We may process this information to:

• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activities,
• study and combat discrimination consistent with our Non-discrimination Policy,
• conduct fraud prevention, security investigations, and risk assessments,
• verify or authenticate information provided by you,
• comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees, and members of the public,
• resolve disputes with our Members, including sharing information with your co-Host(s) or additional Guests about disputes related to your role as a co-Host(s) or additional Guests,
• enforce our agreements with third parties,
• determine eligibility for certain types of bookings, such as Instant Book,
• comply with law, respond to legal requests, prevent harm, and protect our rights,
• enforce our Terms and other policies (e.g., Non-discrimination Policy), and
• assess or evaluate your interactions with the Company Platform and information obtained from third parties. In limited cases, automated processes, which analyze your data and activities on the Company platform as well as information in relation to activities on and off the Company platform that can be associated with you, could restrict or suspend your access to the Company Platform if such processes detect activity that may pose a safety or other risk to Company, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section below. You can find out more about how our system determines whether certain reservations may carry a higher risk for incidents here.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may process this information to:

• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you,
• invite you to events and relevant opportunities, and
• send, with your consent, promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

3.4 Analyzing and Sharing Your Communications.

We may review, scan, or analyze your communications on the Company Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites, and subject to applicable law, we scan and analyze all images uploaded by users to the Company platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities (such as evidence of child exploitation) for the purpose of identifying and reporting content violations to appropriate authorities. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

3.5 Provide Payment Services. Personal information is used to enable, or authorize third parties to use, Payment Services, such as to:

• detect and prevent money laundering, fraud, abuse, and security incidents, as well as conduct risk assessments,
• comply with legal and compliance obligations (such as anti-money laundering regulations and sanctions enforcement),
• enforce the Payment Terms and other payment policies, and
• provide and improve Payment Services.

4. SHARING & DISCLOSURE

4.1 Sharing With Your Consent or at Your Direction.

Where permissible under applicable law, we may use certain information about you, such as your email address, that we share with social media platforms after de-identifying it to generate leads, drive traffic to Company, or otherwise promote our products and services.

4.4 Seller Service Providers.

Sellers may use third-party services to help manage or deliver their services. Seller may use features on the Company Platform to share information about the Traveller (like check-in and check-out information, Traveler name, and Traveler phone number) with such third-party service providers.

4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against Company, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability (more information on Company Law Enforcement Guidelines here), (iv) enforce and administer our agreements with Members, including our Terms, Additional Legal Terms, and Policies, or (v) protect the rights, property or personal safety of Company, its employees, its Members, or members of the public.

4.6 Service Providers.

We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) perform product development, maintenance, and debugging, (v) allow the provision of the Company Services through third-party platforms and software tools (e.g., through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) offer additional services you select, (viii) process, handle, or assess insurance claims or similar claims, or (ix) review, scan, and analyze communications on the Company Platform for certain purposes (such as evidence of child exploitation). See the Analyzing and Sharing Your Communications section for additional information. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks. Other Members can use services other than Company to process your data. These can include email or reservation management software. Such services are outside of Company control and will be subject to applicable laws around the world with varying levels of data protection.

5. OTHER IMPORTANT INFORMATION

5.1 Third-Party Partners & Integrations.

Parts of Company may link to third-party services. Company does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them. Your use of these services is subject to the privacy policies of those providers, including Google Maps/Earth Additional Terms of Use, Google Privacy Policy.

6. YOUR RIGHTS

6.1 Managing Your Information.

You can access and update some of your personal information by contacting our Customer Support. You are responsible for providing your personal information correctly.

6.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

7. SECURITY

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorized access, loss, destruction, or alteration.

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you must stop using Company services. If you continue using our services before the date the revised Privacy Policy becomes effective, your continued access to or use of the Company Platform will be subject to the revised Privacy Policy.