In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered an MoV account, including Customers and Suppliers. A “Customer” is someone who books, or seeks to book Accommodation or Supplier Services. A “Supplier” is someone who offers services (“Supplier Services”) via published listings on the MoV Platform (“Listings”). “Accommodation” means a villa, chalet, apartment, hotel, resort or other form of rental property. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the MoV 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 MoV Platform in order to ensure the adequate performance of contracts between you and MoV, or between you and a Supplier. The provision of this information is necessary to use the MoV Platform and, without it, we will not be able to provide you with services that you request.
i) Account Information: when you sign up for an MoV account or submit a request for Accommodation information, we require certain information such as your name and email address.
ii) Profile Information: to use certain features within the MoV Platform, we may need to ask you to complete a profile, which may include your address and phone number.
iii) 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 (like a photo of your government-issued ID) or other authentication information.
iv) 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 Customer, we may retain your financial information to assist you with booking travel-related experiences with third parties. 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.
v) Communications with MoV: when you communicate with MoV, we collect information about your communication and any information you choose to provide.
vi) 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 with an MoV representative, conduct a search, update or add information to your MoV account, respond to surveys, participate in promotions, or use other features of the MoV Platform.
1.2. Information We Automatically Collect from Your Use of the MoV Platform
When you use the MoV Platform, we collect information about the services you use and how you use them, even if you don’t sign up for an MoV account. We process this information for the activities and legal bases described in Section 2 below.
i) Usage Information: we collect information about your interactions with the MoV 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 MoV Platform.
ii) Location Information: when you use certain features of the MoV Platform, we may collect different types of information about your general location (e.g. city, country).
iii) Log Data: we automatically collect log information when you use the MoV Platform, even if you have not created an MoV account or logged in. That information includes, among other things: details about how you’ve used the MoV Platform (including if you clicked on links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g. browser type, crashes), unique identifiers, and the page you’ve viewed or engaged with before or after using the MoV Platform.
iv) Transaction Information: we collect information related to your transactions on the MoV Platform or transactions made through the MoV Platform, including the date and time, amounts charged, and other related transaction details.
1.3. Information We Collect from Third Parties
We may collect information that others provide about you when they use the MoV Platform, or obtain information from other sources and combine that with information we collect through the MoV Platform. MoV 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 MoV should be directed to such third parties.
i) Third Party Services: if you link, connect, or login to your MoV 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 authorised by you via your privacy settings at that service.
ii) Background Information: for certain Members in the United States, to the extent permitted by applicable laws, MoV 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, MoV 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.
iii) Other Sources: to the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners (such as SafelyStay) and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the MoV Platform, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through MoV, the restaurant may send information to us that you submitted to them, like your dining preferences or dining activity. We may receive information about you and your activities on and off the MoV Platform through partnerships, or about your experiences and interactions from our partner ad networks.
2. How We Use The Information We Collect
We use, store, and process information about you to provide, understand, improve, and develop the MoV Platform, and to create and maintain a trusted and safer environment.
2.1. Provide, Improve, and Develop the MoV Platform
i) Enable you to access and use the MoV Platform.
ii) Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
iii) Enable you to communicate with other Members.
iv) Operate, provide, improve and optimise the MoV Platform and experience, such as by performing analytics and conducting research.
v) Personalise or otherwise customise 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.
vi) Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
vii) Provide customer service.
viii) Send you service or support messages, such as updates, security alerts, and account notifications.
ix) If you provide us with your contacts’ information, we may use and store this information: a) to facilitate your referral invitations, b) for fraud detection and prevention, and c) for any other purpose you authorise at the time of collection.
We process this information given our legitimate interest in improving the MoV 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
i) Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
ii) Conduct investigations and risk assessments.
iii) Verify or authenticate information or identification provided by you (such as to verify your address or compare your identification photo to another photo you provide).
iv) Conduct checks against databases and other information sources.
v) Comply with our legal obligations.
vi) Resolve any disputes with any of our users and enforce our agreements with third parties.
vii) Enforce our Terms of Service, Member agreements, and policies.
We process this information given our legitimate interest in protecting the MoV Platform, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalise, Measure, and Improve our Advertising and Marketing
i) Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about MoV or partner campaigns and services).
ii) Personalise, measure, and improve advertising.
iii) Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by MoV or its third party business partners.
iv) 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 MoV Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3. Sharing & Disclosure
3.1. With Your Consent or Where Authorised by Law
i) We may share your information at your direction or as described by us to you at the time of sharing, such as if you, as a Customer, have requested us to connect you with a third party vendor or to purchase services from a third party vendor on your behalf, in connection with your booking (e.g. an insurance provider or activities provider), or if you, as a Supplier, have agreed to let us market your Accommodation through, or refer you to, a third party’s platform. In these situations, you are authorising MoV to disclose to these third party vendors information required to book them and to receive the relevant services from them. This could include special preferences or requests, and any additional guest information. These third party vendors are not controlled by MoV and personal information shared with them is subject to their privacy policies and practices.
ii) We may also share certain contact details about you, such as your name, email and past reservations in MoV, to other companies and business partners of MoV, who may then send you marketing communications about products or services that may interest you.
3.2. Sharing between Customers and Suppliers
i) When you as a Customer 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.
ii) When you as a Supplier have a confirmed booking, certain of information about you may be shared with the Customer to coordinate the booking, such as your full name, phone number, and Accommodation address.
Sharing this information is necessary to provide Customers with our services, and we don’t share your billing and payout information with other Members.
3.3. Reviews, Listings, and other Public Information
The MoV Platform publishes information that is visible to the general public. For example:
i) 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.
ii) After completing a booking, Customers may write reviews which may appear publicly on Listing pages (and other pages on which we may market Properties) under their first name, last initial, and general location.
iii) If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the MoV Platform, that content is publicly visible.
Information you share publicly on the MoV 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.
3.4. Service Providers
We use a variety of third party service providers to help us provide services related to the MoV Platform and ensure we can adequately provide you with our services. For example, service providers may help us: a) verify or authenticate your identification, b) check information against public databases, c) assist us with background checks, fraud prevention, and risk assessment, or d) 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.
3.5. Additional Services by Suppliers
Suppliers may use third party services available through the MoV Platform to assist with managing their Accommodation or providing additional services, such as cleaning services, insurance or activities providers. Suppliers may use features on the MoV Platform to share information about the Customer (like the Customer’s check-in and check-out dates, name, phone number, and email address) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services.
3.6. Safety and Compliance with Law
MoV may disclose your information to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary:
i) to comply with legal process and to respond to claims asserted against MoV,
ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability,
iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of MoV, its employees, its Members, or members of the public.
We will attempt to notify Members about these 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 MoV’s property, its Members and the MoV Platform (collectively, “Risk Scenarios”).
In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
3.7. Corporate Affiliates
To help us provide the MoV 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 MoV Platform and our affiliates’ services. Our affiliates include other Ministry of Villas companies.
We may display parts of the MoV Platform on sites operated by MoV’s business partners, using technologies such as widgets or APIs.
3.9. Tax Authorities
In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Customers and Suppliers expressly grant us permission, without further notice, to disclose Customers’ and Suppliers’ data and other information relating to them or to their transactions, bookings, Properties and occupancy taxes to the relevant tax authority, including, but not limited to, the Customer’s or Supplier’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Customers, and contact information.
3.10. Business Transfers
3.11. Aggregated Data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified information for industry and market analysis, regulatory compliance, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1. Analysing your Communications
We may review, scan, or analyse your communications on the MoV Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some 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 analyse your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications. These activities are carried out based on MoV’s legitimate interest in ensuring compliance with applicable laws, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2 Linking Third Party Accounts
You may link your MoV account with your account at a third party social networking service. When you create this link:
i) the 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
ii) the publication and display of information that you provide to MoV through this linkage is subject to any of your settings and authorisations on the MoV Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
4.3 Google Maps/Earth
5. Third Party Partners & Integration
The MoV Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). MoV doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Choices
6.1. Managing Your Information
You may access, update, and correct most of your basic personal information by logging into your MoV account and reviewing your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by us. In some cases and where permitted by law, we may charge a fee which will be disclosed to you before we comply with your request. You are responsible for keeping your personal information up-to-date.
6.2 Data Retention & Account Cancellation
We generally retain your information for as long as is needed to provide the MoV 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 MoV Platform to you, you may cancel your account or request us to erase your personal information. To cancel your MoV account, contact us. If you cancel your account or request erasure of your personal information, note that:
i) Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the MoV Platform in association with your first name, even after your MoV account is cancelled.
ii) Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
iii) Because we maintain the MoV 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.
iv) MoV may retain certain information to the extent necessary to comply with its legal obligations.
v) MoV 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 MoV removes a user account for fraud or user safety reasons, MoV may retain certain information from that account to prevent that user from opening a new MoV account in the future.
6.3 Withdrawing Consent
6.4 Data Portability
In some jurisdictions, applicable law may entitle you to request a copy of your personal information that you have provided to us and/or to request us to move such personal information to another service provider. In such cases, and in line with our legal obligations, we will provide you or the service provider with information in a structured and commonly used format.
6.5 Restricting Processing
In certain extraordinary circumstances (e.g. where you think that MoV is not holding accurate data about you) and in line with applicable law, you may request MoV to temporarily restrict our use of your personal information for a limited period of time until the extraordinary circumstance that justified the restriction ends.
6.6 Objecting to Processing (including Automated Decision-Making)
In some jurisdictions, applicable law may entitle you to require MoV not to process your personal information for certain specific purposes, such as profiling or marketing purposes.
6.7 Exercising Rights and Lodging Complaints
If you would like to learn more about, or exercise any of, the rights described in this Section 6, contact us at [email protected]. We may ask you to verify your identity before taking further action on your request. You have the right to lodge complaints about the data processing activities carried out by MoV before competent data protection authorities.
7. Operating Globally
7.1 European Economic Area
7.2 California Residents
This section applies solely to visitors, users, and others who are residents of the State of California, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section is effective as of January 1, 2020, to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this section.
We set out below the CCPA categories of personal information we have collected from consumers within the last twelve (12) months in respect of our Services. Please note that personal information in certain categories may overlap with other categories.
A. Identifiers: yes – device IP address, email address, cookie string data, pseudonymous data (e.g. hashed emails), operating system, and (in the case of mobile devices) your device type, and mobile device’s identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to any device by third parties and cross-referenced to recognise a device.
B. Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): yes – name, address, telephone number, and email address.
C. Protected classification characteristics under California or federal law: no.
D. Commercial information: records of services purchased, considered, or other purchasing or consuming histories on the MoV Platform.
E. Biometric information: no.
F. Internet or other similar network activity: yes – browsing history, search history, information on a consumer’s interaction with MoV’s websites, applications, or advertisements.
G. Geolocation data: yes – non-precise geolocation derived from IP address.
H. Sensory data: no.
I. Professional or employment-related information: no.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R Part 99)): no.
K. Inferences drawn from other personal information: no.
For clarity, under CCPA personal information does not include:
Publicly available information from government records; de-identified or aggregated consumer information; and information excluded from the CCPA’s scope such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Data Portability and Right to Deletion), we will delete (and direct our services providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relations with you or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities; exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); comply with a legal obligation; and make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please send your request to [email protected].
Only you, or a person registered with the California Secretary of State that you authorise 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.
You may only make a verifiable request for access of data portability twice within a 12-month period. The verifiable consumer request must: provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration.
Last Updated: 20th May 2019