We collect and process your personal information in order to provide you an optimal experience possible when you interact with us. The following chart describes the type of information we collect, the source of that information, our purposes for using the information, and the third parties with whom we may share the information.
If you choose to connect or login to your Xenia account with a third party (e.g. Facebook, Apple, Google), the third party service may share information with us such as your registration data, profile information, or friends list in order to make it easy for you to create and maintain an account with us. The information sent may vary by service and is controlled by the service and authorized by you depending on your privacy settings with the third party. In addition to the above, there may be some circumstances where we may need to collect additional information. For example, if an individual requires medical or emergency assistance, we may collect and share information about individuals in order to assist with the situation. If you enter into a contest, sweepstakes, or other promotion, we may collect personal information from you in order to administer the event. In doing so, we may disclose your information to our co-sponsors, service providers, and other third parties in accordance with the event’s purpose and as described in the official rules or terms.
III. Our Operational and Commercial Purposes
As part of Service offerings we undertake a multitude of operations which require the processing of personal information. For example, our business purposes include: (1) accepting, coordinating, managing, and processing Listings and Bookings; (2) facilitating purchase transactions for goods and services; (3) providing top-level customer support, accommodations, and personalized services and amenities; (4) engaging in quality control in order to improve our offerings to you; (5) facilitating communications between parties; (6) engage in content based or interest-based advertising, (7) ensuring the safety and security of our users, our staff, and all other persons visiting our platform or the properties listed on it; (8) prevent, detect, and investigate fraud, cyber incidents, or other illegal activity; (9) communicating with you and others in relation to your use of our services, including providing legal updates; (10) administering our record-keeping for legal, tax, and operational purposes; (11) exploring new and unique ways to provide products and services; and (12) doing our best to fulfill your requests. Our commercial purposes are to advance our commercial interests, including for advertising and marketing.
IV. Disclosures of Your Personal Information
In order to provide you our service and to fulfill our business and commercial purposes, we may disclose your personal information.
Publicly Posted Information. Some user information is posted publicly on the platform and is visible by others. This may include profile information, information related to a Space or Listing, and other information that a user submits to be posted. Precise location information is not publicly posted.
Sharing Between Users. Our Services are designed to connect users and to facilitate interaction between them. We also will disclose your personal information to any agents or third parties to whom you authorize us to disclose it, including the operators, managers, agents, or other parties associated with an Event or when you agree to a Booking. This sharing is necessary to ensure the performance of the contract between you and Xenia, and/or you and a third party.
Disclosures to Our Service Providers: We may disclose your information to our trusted third party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, dispute resolution providers, advertising providers, governmental entities, social networks, and other users. When appropriate or required by applicable law, we will put in place appropriate contracts containing standard data protection clauses to protect that information and the rights of individuals.
Other Disclosures. In addition to the foregoing, we may disclose personal information in the following circumstances: (1) In order to comply with an applicable federal, state, or local law; (2) In order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) To cooperate with law enforcement agencies concerning conduct or activity that web reasonably and in good faith believes may violate federal, state, or local law; (4) To exercise and defend legal or payment related claims; (5) When such disclosure is pursuant necessary to protect the rights and freedoms of other individuals; (6) As part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of Xenia, Inc., and (7) In any other manner permitted by law, including engaging in protected speech.
Third Party Links: Links to web sites that are not operated by or for us (“Third Party Sites”) are provided solely as a convenience to you. If you use these links, you will leave our website. This Privacy Notice does not apply to Third Party Sites. We have not reviewed the Third Party Sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.
We are committed to protecting the security of any personal information you provide. For these reasons, all financial information you provide, such as credit card data, will generally be transferred over a Secured Socket Layer (SSL) connection (provided that it is supported or enabled on your browser). In spite of these protections, any information submitted over the Internet could be intercepted or otherwise corrupted during transmission, and we cannot guarantee the complete security of any data submitted over the Internet. Sensitive personal information is stored on servers or locations protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. The servers are under our control at all times but may be hosted, managed or otherwise maintained by third party service providers with whom we contract. These third party service providers have no right to use or access this data other than in performing their services for us. You may access and change certain information that you submitted during registration (if you have registered at the Site) at any time by providing your username and password. Please keep your password in a safe place and do not provide this information to anyone. We strongly encourage you to check the accuracy of your data regularly as we will use your e-mail, phone number, and home address to communicate with you regarding products or services that you have requested. We will not be liable for any problems or difficulties that arise as a result of your failure to keep your information up to date.
VI. International Data Transfers
For users located outside the jurisdiction of the United States, Xenia, Inc. is located in the United States. Information we collect from you will be processed in the United States and potentially in other jurisdictions, and by using our Services (including our website) you acknowledge and consent to the processing of your data in the United States and elsewhere. While we do not target individuals in the EU or other jurisdictions outside of the United States, we are aware that individuals from outside the US may interact with us and inquire about the adequacy of our data protection. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 41 of the GDPR. We collect and transfer to the U.S. personal data only with your consent (as provided herein); to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.
VII. Your Marketing and Ad Choices
Adjust Your Browser Setting to Block Third Party Cookies You can also use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.
Set Do Not Track Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser’s do-not-track request. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
VIII. Children’s Privacy
We are committed to complying with the Children's Online Privacy Protection Act (COPPA). Our website and services are not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly destroy such information. Parents are encouraged to supervise their children's online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association's home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.
IX. Agreement and Changes
XI. Contact Information
If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us by e-mail at info@getXenia.com. Please note, we do not accept consumer rights requests via email.
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain additional privacy rights related to the personal information we collect about you. Generally, the CCPA provides you with rights to know about the personal information we collect about you and rights to have personal information we collected from you deleted in certain circumstances. Please see below to learn more about your rights under the CCPA and to learn more about our practices. Not all of your personal information is subject to the CCPA. The CCPA does not apply to personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRA). Your personal information may be subject to these other privacy laws and your personal information that we maintain may be exempt from the CCPA.
What Is Personal Information?
The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Personal information does not include publicly available information or consumer information that is de-identified or aggregate consumer information.
What Personal Information Do We Collect About You?
Personal Identifiers: This includes first and last name, previous name, address, telephone number, unique personal identifier, and signature;
Device and Online Identifiers and Related Information: This includes online identifiers, Internet Protocol (IP) address, email address, account user name, mobile/ wireless number, social media profile, unique device identifier and serial number, and other device information;
Demographic Information: This includes date of birth and household income data; Financial Information: This includes transaction information, financial account information used to validate your identity, account information about externally linked accounts, account login credentials, and other financial information;
Government Identifiers: This includes social security number, national identification number, other government-issued identification number, driver’s or operator’s license number, passport number, and copies of government IDs;
Protected Classification Characteristics: This includes age, national origin, citizenship, nationality, marital status, sex, and veteran or military status; please note that we do not collect information regarding gender identity, gender expression, or sexual orientation unless you provide it to us in connection with our products or services;
Purchase History: This includes customer transaction history or tendencies;
Internet, Application, and Network Activity: This includes text messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits and cookies or other similar technologies);
Location Data: We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your wi-fi connection;
Sensory Data: This includes audio data, such as a recording of your voice when you call us;
Professional or Employment-Related Information: This includes occupation, title, employer, and employment history; and
Inferences About You: This includes a profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes and creditworthiness profile.
How Do We Use Your Personal Information?
What Is The Source Of The Personal Information We Collect About You?
Who Do We Share Your Personal Information With?
We share personal information with other users, third party vendors or service providers you engage with on our site, and our trusted third party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, dispute resolution providers, advertising providers, governmental entities, social networks, and other users.
Do We Sell Personal Information?
Rights to Know About My Personal Information?
You have the right to know certain information about our collection, use, and disclosure of your personal information for the 12 months preceding the date of your request. You also have the right to request that we provide you with specific pieces of your personal information. These rights are subject to certain exceptions.
Upon receipt of your request, and after we verify your identity, we may provide you with information about the following:
The categories of personal information we collected about you.
The categories of sources of the personal information we collected about you.
Our business or commercial purpose for collecting the personal information.
The categories of personal information we disclosed about you to a service provider.
The specific pieces of personal information we collected about you (data portability).
If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that is not in conflict with applicable laws or exempt under the CCPA.
Rights to Have my Personal Information Deleted?
You have the right to request that we delete personal information we have collected from you, subject to certain exceptions and exemptions. Absent an exception or exemption, upon receipt of your request, and after we verify your identity, we will delete and will request that our service providers delete your personal information.
How Do I Exercise My CCPA Rights?
How Do I Exercise My CCPA Rights? If you are a California resident and would like to submit a CCPA request, you may email us at email@example.com
Only you, or a person you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That individual must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.
How Will You Verify My Identity If I Make a CCPA Request?
In order to verify your identity, we will obtain certain information from you and use it to verify your identity using reasonable methods. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identity verification service. We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.
We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.
You are not required to have an account with us to make a verifiable request.
CCPA Non-Discrimination Rights?
We will not discriminate against you for exercising any of your CCPA rights, which means we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
If you have any questions or concerns about this CA Policy, please contact us a firstname.lastname@example.org