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WATTTON : For a list of Privacy Policies by jurisdiction

For a list of Privacy Policies by jurisdiction

□ Last Updated: July 21, 2022

 

WATTTON exists to help build connections between people and make the world more open and inclusive. In short—to build a world where anyone can belong anywhere. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protecting your human right to privacy.

 

This Privacy Policy describes how WATTTON, Inc. and its affiliates (“we,” “us,” or “WATTTON”), process personal information in relation to your use of the WATTTON Platform. Depending on where you live and what you are doing on the WATTTON 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.

 

IMPORTANT SUPPLEMENTAL INFORMATION

 

Outside of the United States. If you reside outside of the United States, such as in the European Economic Area (“EEA”) visit our “Outside of the United States” page to learn about (i) the controller(s) of your personal information, (ii) legal bases, including legitimate interests, for collecting and processing your personal information, (iii) safeguards relied upon for transferring personal information outside the EEA, (iv) your rights, and (v) contact details of the controller(s) and Data Protection Officer.

 

 

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 WATTTON Platform.

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

 

Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.

 

2.2 Information you choose to give us.

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

Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.

Information About Others. Such as a payment instrument belonging to another person or information about a co-traveler. By providing us with personal information about others, you certify that you have permission to provide that information to WATTTON for the purposes described in this Privacy Policy, have shared the WATTTON Privacy Policy with them, and they have read and understood that it applies to them.

Address Book Contact Information. Address book contacts you import or enter manually.

Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, 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 WATTTON Platform and our Payment Services.

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

Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the WATTTON Platform.

Log Data and Device Information. Such as details about how you’ve used the WATTTON 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 WATTTON Platform. We may collect this information even if you haven’t created an WATTTON account or logged in.

Cookies and Similar Technologies as described in our Cookie Policy.

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.

 

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

Third-Party Services. If you link, connect, or login to the WATTTON Platform with a third party service (e.g. Google, Facebook, WeChat), you direct the service to send us information such as your registration, friends list, and profile information as 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, we may obtain, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, we 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.

Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.

Referrals. If you are invited to the WATTTON Platform, the person who invited you can 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 references, 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 or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the WATTTON Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to, health information related to contagious diseases.

 

 

3. HOW WE USE INFORMATION WE COLLECT

 

If you reside outside of the United States, click here to learn about our legal bases for collection and processing personal information. We use personal information as outlined in this Privacy Policy.

 

3.1 Provide, Improve, and Develop the WATTTON Platform. Such as to:

enable you to access the WATTTON Platform and make and receive payments,

enable you to communicate with other Members,

process your request,

perform analytics, debug and conduct research,

provide customer service, training,

send you messages, updates, security alerts, and account notifications,

personalize and customize your experience based on your interactions with the WATTTON Platform, your search, your profile information and preferences, and other content you submit, and

enable your use of our enterprise products.

 

 

3.2 Provide, Personalize, Measure, and Improve our Advertising and Marketing. For example 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,

administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by WATTTON or its third-party partners,

analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and

invite you to events and relevant opportunities.

 

3.3 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,

conduct security investigations and risk assessments,

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, and,

provide and improve Payment Services.

 

 

4. SHARING & DISCLOSURE

If you reside outside of the United States, learn about safeguards we rely on for transferring personal information to recipients outside of the EEA here.

 

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your WATTTON account or participating in promotional activities by WATTTON partners or third parties.

 

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

 

4.2 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

Your public profile page, which includes your profile photo, first name (or initials where applicable), description, and city.

Reviews, ratings, and other public feedback.

Content in a community or discussion forum, blog, or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps.

 

Information you share publicly on the WATTTON Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

 

4.3 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, or authorized third parties, 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 WATTTON, (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 WATTTON’s 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 WATTTON, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.

 

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 or harm to WATTTON, our Members, or expose WATTTON to a claim of obstruction of justice.

 

 

4.4 Business Transfers.

 

If WATTTON undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

 

 

4.5 Corporate Affiliates.

 

To support us in providing, integrating, promoting and improving the WATTTON Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control. Some examples are:

 

Sharing with WATTTON, Inc. Even if your country of residence is not the United States, your information will be shared with WATTTON, Inc. which provides the technical infrastructure for the WATTTON Platform.

Sharing with WATTTON Payments. In order to facilitate payments on or through the WATTTON Platform, certain information as described in the “Outside of the United States” section, will be shared with the relevant WATTTON Payments entity.

Sharing with WATTTON Ireland. Even if your country of residence is outside EEA (e.g. United States, Japan, China) your information may be shared with WATTTON Ireland which provides customer support and other business operation services to other WATTTON entities and may be disclosed in line with section 4.5 above.

Sharing with WATTTON GSL. Even if your country of residence is not Japan, your information may be shared with WATTTON GSL which provides customer support and other business operation services to other WATTTON entities.

Sharing with WATTTON China. Even if your country of residence is not China, information you provided will be shared with WATTTON China in the following circumstances:

Public data. Information you share publicly on the WATTTON Platform.

 

 

5. OTHER IMPORTANT INFORMATION

 

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the WATTTON Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, 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. 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.

 

5.2 Linking Third-Party Accounts.

You can link your WATTTON account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

some of the information provided to us from linking accounts may be published on your public profile,

your activities on the WATTTON Platform may be displayed to your Friends on the WATTTON Platform and/or that third-party service,

a link to your public profile on that third-party service may be included in your WATTTON public profile,

other WATTTON users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,

other WATTTON users may be able to see any schools, hometowns, or other groups you have in common with them as listed on your linked social networking service,

information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention and risk assessment purposes, and

publication and display of information that you provide to the WATTTON Platform through this linkage is subject to your settings and authorizations on the WATTTON Platform and the third-party service.

 

5.3 Third-Party Partners & Integrations.

Parts of WATTTON may link to third-party services, not owned or controlled by WATTTON, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information), and Citi Privacy Policy. WATTTON does not own or control these third parties and when you interact with them you are providing your information to them.

 

 

6. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. See here for information on data subject rights requests and how to submit a request. We may ask you to verify your identity and request before taking further action on your request.

 

 

6.1 Managing Your Information.

 

You can access and update some of your personal information through your Account settings. If you connected your WATTTON Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

 

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).

 

6.3 Data Erasure.

 

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

 

We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an WATTTON Account for fraud or safety reasons, we may retain information from that WATTTON Account to prevent that Member from opening a new WATTTON Account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, WATTTON and WATTTON Payments may keep information for tax, legal reporting, and auditing obligations.

Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on WATTTON, even after your WATTTON Account is canceled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.

Because we take measures to protect data 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.

 

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 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 can 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 WATTTON Platform will be subject to the revised Privacy Policy.

 

9. CONTACT INFORMATION AND RESPONSIBLE WATTTON ENTITIES

For questions or complaints about this Privacy Policy or WATTTON’s handling of personal information (i) If you reside in the United States contact WATTTON Corp., Legal Privacy, 5900 Balcones Drive, Suite 100, Austin, Texas, United States; (ii) for payments related matter please use the contact information provided in the Payments Terms of Service page, and (iii) if you reside outside the United States, please use the contact information for your controller provided in the Outside of the United States page.

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