This Privacy Policy explains how Progressive Business, s.r.o. (“ZeroCommHomes,” “we,” or “us”) processes personal data related to your use of the ZeroCommHomes Platform. Depending on your interactions with the ZeroCommHomes Platform, the supplementary privacy pages listed below may be applicable to you. Please refer to the information detailing our personal data processing procedures.
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1. PERSONAL INFORMATION COLLECTION
1.1 Information Required for ZeroCommHomes Platform Use
We gather personal information about you when you utilize the ZeroCommHomes service. This information is essential for us to deliver all requested services. It includes:
1.1.1 Contact, Account, and Profile Information. This may encompass your first and last name, phone number, postal address, email address, and profile photo, depending on the features you use.
1.1.2 Payment Information. This may consist of payment account or bank account details.
1.2 Information Provided by You
You can opt to offer us additional personal information, including:
1.2.1 Information About Others. This could include the payment instrument or contact information of another individual or details about a co-traveler. By providing us with personal information about others, you confirm that you have the appropriate consent to provide that information to ZeroCommHomes for the outlined purposes, and you have shared the ZeroCommHomes Privacy Policy with them.
1.2.3 Other Information. This might involve filling in a form, adding information to your account, responding to surveys, participating in promotions, communicating with ZeroCommHomes Support and other Members, importing or manually entering address book contacts, providing your address and/or geolocation, or sharing your experience with us.
1.3 Information Automatically Collected while Using ZeroCommHomes Platform and Paid Services
Whenever you engage with ZeroCommHomes and Paid Services, certain information is collected automatically. This may include:
1.3.1 Geolocation Information. For instance, precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information shared with us, based on your device settings. This information may also be collected when you are not using the app, if enabled through your settings or device permissions.
1.3.2 Usage Information. Such as searches for Listings, applications you have made, additional services you have added, access dates and times, the pages you have viewed or engaged with before or after using ZeroCommHomes, and other actions on ZeroCommHomes, including the pages or content you view and links you click to third-party applications. This information may be collected even if you haven’t created a ZeroCommHomes account or logged in.
1.3.3 Device Information. This could cover IP address, hardware and software information, device details, device event information, unique identifiers, crash data, and read receipts. This information may be collected even if you haven’t created a ZeroCommHomes account or logged in.
1.3.4 Cookies and Similar Technologies.
1.3.5 Payment Transaction Information. This may involve details of the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address, and other pertinent transaction details.
1.4 Information Obtained from Third Parties
We may gather personal information from other sources, such as:
1.4.1 Third-Party Applications. If you choose to link, connect, or log in to ZeroCommHomes using a third-party service, such as Google, Facebook, you authorize the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
1.4.2 Complainants. In case a property owner, its manager, or any third party registers a complaint about you, we may receive information related to the specific complaint to understand and, if applicable, address the complaint.
1.4.3 Financial Institutions. If you opt to pay using funds from your bank account, we may receive specific information from your financial institution, such as bank account details.
1.4.4 Other Sources. Subject to applicable law, we may receive additional information about you, such as references, demographic data, and information to help detect fraud and safety issues, from (i) third-party service providers, other third parties, and/or partners, or (ii) Members and any other individuals, entities, and authorities, and combine it with information we have about you. For instance, we may obtain background check results or fraud warnings from identity verification service providers to aid in our efforts related to fraud prevention, security investigation, and risk assessment. We may also receive information about you and your activities on and off the ZeroCommHomes Platform from users of ZeroCommHomes, members of the public, or governmental, public, or tax authorities, or about your experiences and interactions from our partners.
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2. HOW WE UTILIZE THE INFORMATION WE GATHER. We utilize personal information in accordance with this Privacy Policy.
2.1 Provision, Enhancement, and Advancement of ZeroCommHomes. We may utilize this information to:
• enable your access to ZeroCommHomes and facilitate payments,
• enable communication with others,
• process your requests,
• conduct analytics, debugging, and research,
• enhance and develop our products and services,
• provide customer service training,
• send you messages, updates, security alerts, and account notifications,
• process, manage, or assess insurance claims or similar claims,
• determine your country of residence based on automated review of your account information and interactions with the ZeroCommHomes Platform,
• personalize and customize your experience based on your interactions with ZeroCommHomes, search activity, profile information and preferences, and other submitted content, and
• facilitate your use of our products and accommodation services.
2.2 Safeguarding ZeroCommHomes and the Community. We may utilize this information to:
• study and combat discrimination,
• detect, prevent, assess, and address fraud and security risks,
• verify or authenticate information provided by you, including identity information, as described in Information Needed to Use ZeroCommHomes,
• fulfill our legal obligations,
• resolve disputes with our Members,
• enforce our agreements with third parties,
• comply with the law, respond to legal requests, prevent any harm, and protect our rights (see Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights),
• enforce our Terms and other policies,
• assess or evaluate your interactions with ZeroCommHomes and information obtained from third parties.
In certain instances, automated processes, which analyze your account and activities on ZeroCommHomes as well as information related to activities on and off ZeroCommHomes that can be linked to you, could restrict or suspend your access to ZeroCommHomes if such processes detect activity that may pose a safety or other risk to ZeroCommHomes, our community, or third parties. If you wish to contest decisions based on automated processes, please contact us via the Contact Information section.
2.3 Deliver, Personalize, Assess, and Elevate our Advertising and Marketing. We may utilize this information to:
• send you promotional and marketing messages, and other information,
• display, personalize, assess, and elevate our advertising on advertising platforms,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by ZeroCommHomes or its third-party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we believe might be of interest to you, and
• invite you to events and relevant opportunities.
2.4 Analyze and Share Your Communications. We may review, scan, or analyze your communications on ZeroCommHomes for the 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, 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 ZeroCommHomes 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.
2.5 Provision of Payment Services. Personal information is utilized to enable, or authorize third parties to use, Payment Services, such as to:
• identify and prevent money laundering, fraud, abuse, and security incidents, and conduct risk assessments,
• adhere to legal and compliance obligations, such as anti-money laundering regulations and sanctions enforcement,
• enforce other payment policies, and
• provide and enhance Payment Services.
3. Sharing and Disclosure
3.1 Sharing With Your Consent or at Your Direction
When you provide consent or direct us to share your information, we will share your information based on the terms of consent or choice provided. For example, this may occur when you authorize a third-party application or website to access your ZeroCommHomes account.
3.2 Who We Share With
We may share your information with the following:
3.2.1 Building Management
We may share personal information with the owner(s) of an Accommodation, a homeowners’ association, and/or their agent, such as a building operator or property management company (“Building Management”), including booking information and information related to compliance with applicable laws.
3.3 Why We May Share Your Information
We may share your information for the following reasons:
3.3.1 Build Your Paid Profile
We may make certain information visible to others, such as:
– Your profile and account information and information derived from them
3.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights
3.3.2(i) Disclosure
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 ZeroCommHomes, (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.
3.3.2(i)(b) To Tax Authorities
Where legally required or permissible according to applicable law, we may disclose information to relevant tax authorities or other governmental agencies, depending on where you are based, for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations.
4. Third-Party Partners and Integrations
4.1 Linking Third-Party Services
Users have the option to connect their ZeroCommHomes account with certain third-party services, such as social networks. By linking these accounts, users acknowledge that:
– Information provided to ZeroCommHomes from linking accounts may be displayed on their public profile.
– Information obtained from linked accounts may be stored, processed, and transmitted for purposes such as fraud prevention, security investigations, and risk assessment.
– ZeroCommHomes may share reservation information with third-party and reward programs.
– The publication and display of information provided to ZeroCommHomes through this linkage are governed by the users’ settings and authorizations on ZeroCommHomes and the third-party service.
4.2 Third-Party Service Terms
Certain areas of ZeroCommHomes may direct users to third-party services. It should be noted that ZeroCommHomes does not have ownership or control over these third-party entities. When users engage with these third parties and opt to use their services, they are directly providing their information to these external parties. Consequently, users are subject to the privacy policies of these service providers.
5. YOUR RIGHTS. You have the right to exercise any of the rights described in this section in accordance with applicable law.
5.1 Managing Your Information. You have the ability to access and update certain personal information through your Account settings. It is your responsibility to ensure that your personal information is kept up to date.
5.2 Access and Portability. In certain jurisdictions, you may be entitled to request copies of your personal information or information about how we handle your personal information, request copies of personal information 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.
5.3 Erasure. In some jurisdictions, you may request the deletion of your personal information. However, it’s important to note that if you request the deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:
5.3.1 Legitimate Business Interests. We may retain your personal information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a ZeroCommHomes Account for fraud or safety reasons, we may retain information from that ZeroCommHomes Account to prevent that Member from opening a new ZeroCommHomes Account in the future.
5.3.2 Legal, Tax, Reporting, and Auditing Obligations. We may retain and use your personal information to the extent necessary to comply with our legal, tax, reporting, and auditing obligations.
5.3.3 Shared Information. Information you have shared with others, such as Reviews and forum postings, may continue to be publicly visible on ZeroCommHomes, even after your ZeroCommHomes Account is canceled.
5.3.4 Residual Copies. Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may remain in our backup systems for a limited period.may not be removed from our backup systems for a limited period of time.
6. Security: While it is not possible for any organization to guarantee perfect security, we continuously implement and update administrative, technical, and physical security measures to safeguard your information against unauthorized access, loss, destruction, or alteration.
7. Changes to this Privacy Policy: We retain the right to modify this Privacy Policy at any time in accordance with applicable law. Should we do so, we will publish the revised Privacy Policy and update the “Last Updated” date at the top. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the ZeroCommHomes Platform will be subject to the revised Privacy Policy.
8. Contact Information and Responsible ZeroCommHomes Entities: For questions or complaints about this Privacy Policy or ZeroCommHomes’s handling of personal information:
(i) If you reside in the United States contact Progressive Business, s.r.o., Kaprova 42/14, 110 00 Prague 1, Czech Republic or by emailing us at info@zerocommhomes.com.
9. Definitions: Undefined terms in this Privacy Policy have the same definition as in our Terms of Use (“Terms”).
Last Updated: July 1, 2024