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This Privacy Policy explains how we collect, use, process, and disclose your information across the HR Platform.  The Haute Retreats platform refers to websites, our mobile, tablet and other smart applications, and all associated HR services.

When this policy mentions “HR,” “we,” “us,” or “our,” it refers to the Haute Retreats company that is responsible for your information under this Privacy Policy.

In this policy, we use a few terms which are defined as follows: A “User” is anyone who has registered an Haute Retreats account, including Suppliers and Guests. A “Supplier” is someone who offers services (“Supplier Services”) via published listings on the HR Platform (“Listings”). A “Guest” is someone who books, or seeks to book, Supplier Services. “Accommodation” means a vacation or other property. “Payment Services” means any payment processing services provided through or in connection with a User’s use of the HR Platform.

1. Information We Collect

There are three general categories of information that we collect.

1.1. Information You Give Us.

We collect information you share with us when you use the HR Platform in order to ensure the adequate performance of contracts between you and HR, or between you and a Supplier. The provision of this information is necessary to use the HR Platform and, without it, we will not be able to provide you with services that you request.

  1. Account Information. When you sign up for an HR account or submit a request for Accommodation booking information, we require certain information such as your name and email address.
  2. Profile Information. To use certain features within the HR Platform, we may need to ask you to complete a profile, which may include your address and phone number.
  3. Other Authentication-Related Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identification that you provide or other authentication information.
  4. Payment Information. When you use the Payment Services (such as when booking Accommodation or a travel-related experience through us or establishing a Supplier relationship via us), we require certain financial information (like your bank account or credit card information) to process payments and comply with applicable law. If you are a Supplier, we may require additional information such as your ID or tax ID (where permitted by applicable law), and other proof of identification or verification in order to verify your identity, provide the Payment Services to you, and comply with applicable law. If you are a Guest, we may retain your financial information to assist you with booking travel-related experiences with third parties.
  5. Communications with HR. When you communicate with HR, we collect information about your communication and any information you choose to provide.
  6. Other Information. You may otherwise choose to provide us information (such as your itinerary, food allergies, emergency contact information, travel preferences, and information about other guests accompanying you on your stay) when you fill in a form, speak to, or otherwise communicate to us.

1.2. Information We Automatically Collect from Your Use of the HR Platform.

When you use the HR Platform, we collect information about the services you use and how you use them, even if you don’t sign up for an HR account. We process this information for the activities and legal bases described in Section 2 below.

  1. Usage Information. We collect information about your interactions with the HR Platform, such as the pages or other content you view, your searches for villas, bookings you have made, the experiences and activities you book with others through us, and other actions on the HR Platform.
  2. Log Data. We automatically collect log information when you use the HR Platform, when you create an HR account or logged in. We don’t require you to create an account if you will send a request.
  3. Transaction Information. We collect information related to your transactions on the HR Platform or transactions made through the HR Platform, including the date and time, amounts charged, and other related transaction details.
  4. Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. You may disable the usage of cookies through your browser settings or accept the cookie policy.

1.3. Information We Collect from Third Parties.

We may collect information that others provide you when they use the HR Platform, or obtain information from other sources and combine that with information we collect through the HR Platform. HR does not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to HR should be directed to such third parties.

  1. Third Party Services. If you link, connect, or login to your HR account with a third-party service (e.g., Facebook, Twitter, Google), we may collect information from the third party service, such as your registration and profile information. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  2. Background Information. For certain Members in the United States, to the extent permitted by applicable laws, HR 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, HR may obtain the local version of background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports. We will only collect this information where required by applicable laws or where necessary to ensure the adequate performance of our services for you.

2. How We Use The Information We Collect

We use, store, and process information about you to provide, understand, improve, and develop the HR Platform, and to create and maintain a trusted and safer environment.

2.1. Provide, Improve, and Develop the HR Platform.

  1. Enable you to access and use the HR Platform.
  2. Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
  3. Enable you to communicate with other Users and Owners.
  4. Operate, provide, improve and optimize the HR Platform and experience, such as by performing analytics and conducting research.
  5. Personalize or otherwise customize your experience by, among other things making Accommodation suggestions, ranking search results or showing ads based on your search or booking history, and any preferences you provide to us, or that are signified by your search and booking history.
  6. Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
  7. Provide customer service.
  8. Send you service or support messages, such as updates, security alerts, and account notifications.
  9. If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) for fraud detection and prevention, and (iii) for any other purpose you authorize at the time of collection.

We process this information given our legitimate interest in improving the HR Platform and our users’ experience with it, and to ensure the adequate performance of our contract with you.

2.2. Create and Maintain a Trusted and Safer Environment.

  1. Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
  2. Conduct investigations and risk assessments.
  3. Verify or authenticate information or identification provided by you (such as to verify your Accommodation address or compare your identification photo to another photo you provide).
  4. Conduct checks against databases and other information sources.
  5. Comply with our legal obligations.

We process this information given our legitimate interest in protecting the HR Platform, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.

2.3. Provide, Personalize, Measure, and Improve our Advertising and Marketing.

  1. Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about HR).
  2. Personalize, measure, and improve advertising.
  3. Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by HR or its third party business partners.
  4. Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our services, 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.

We process this information given our legitimate interest in protecting the HR Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3. Sharing & Disclosure

3.1. Sharing between Suppliers and Guests.

  1. When you as a Guest submit a booking request, certain information about you may be shared with the Supplier to coordinate the booking, such as your name, contact details, and arrival date.
  2. When you as a Supplier have a confirmed booking, certain of information about you may be shared with the Guest to coordinate the booking, such as your full name, phone number, and Accommodation address.

Sharing this information is necessary to provide Guests with our services, and we don’t share your billing and payout information with other Members.

3.2. Reviews, Listings, and other Public Information.

The HR Platform publishes information that is visible to the general public. For example:

  1. Public Listing pages are publicly visible and include information such as the Accommodation’s approximate or exact location, Listing description, calendar availability, and any additional information the Supplier chooses to share.
  2. After completing a booking, Guests may write reviews which may appear publicly on Listing pages (and other pages on which we may market Accommodations) under their first name, last initial, and general location.
  3. If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the HR Platform, that content is publicly visible

The information you share publicly on the HR Platform may be indexed through third party search engines. 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.

3.3. Service Providers.

We use a variety of third-party service providers to help us provide services related to the HR Platform and ensure we can adequately provide you with our services. For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually obligated to use it consistent with this policy.

3.4. Corporate Affiliates.

To help us provide the HR Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Additionally, we share your information with our affiliates to support, integrate, promote, and improve the HR Platform and our affiliates’ services. Our brand includes Fenice Hospitality and Sabrina Luxury Collection.

4. Your Choices

4.1 Data Retention & Account Cancellation.

We retain your information for as long as is needed to provide the HR Platform to you, or for as long as your account is active. If you no longer want us to use your information to provide the HR Platform to you, you may cancel your account or request us to erase your personal information. To cancel your HR account, contact us. If you cancel your account or request erasure of your personal information, note that:

  1. The information you have shared with others (such as Listing reviews) may continue to be publicly visible on the HR Platform in association with your first name, even after your HR account is cancelled.
  2. Some copies of your information (e.g. log records) may remain in our database but are disassociated from personal identifiers.
  3. Because we maintain the HR Platform to protect from accidental or malicious loss and destruction, residual copies of your information may not be removed from our backup systems for a limited period of time.
  4. HR may retain certain information to the extent necessary to comply with its legal obligations.
  5. HR may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if HR removes a user account for fraud or user safety reasons, HR may retain certain information from that account to prevent that user from opening a new HR account in the future.

5. 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.