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We’re updating our Privacy Policy on 10th January 2020. You can review the new policy below.

Privacy Policy updated and effective from 10 January 2020.

Luxury Retreats Privacy Policy

This Privacy Policy explains how we collect, use, process, and disclose your information across the LR Platform. The “LR Platform” refers to Luxury Retreats’ ( “LR” ) websites, our mobile, tablet and other smart applications, and all associated LR services.

When this policy mentions “LR,” “we,” “us,” or “our,” it refers to the Luxury Retreats company that is responsible for your information under this Privacy Policy (the “Data Controller” ). The Data Controller is the Luxury Retreats entity that you are contracting with which, if you are booking or supplying Accommodation through the LR Platform, will be one of the following:

If you are booking or supplying Accommodation located in Canada or Barbados, the Data Controller is Luxury Retreats International ULC ( “LRI” ).
If you are booking or supplying Accommodation located in the Collectivity of Saint Martin, the Data Controller is SVV SXM ( “Carimo” ).
If you are booking or supplying Accommodation located outside of Canada, Barbados, and Saint Martin, the Data Controller is Luxury Retreats Management Inc. ( “LRM” ).

Please see Section 10 for contact details of the companies listed above.

In this policy, we use a few terms which are defined as follows: A “Supplier” is someone who offers services ( “Supplier Services” ) via published listings on the LR Platform ( “Listings” ). A “Guest” is someone who books, or seeks to book, Supplier Services (“Suppliers and Guests are Collectively “Members” ). “Accommodation” means a vacation or other property. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the LR 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 LR Platform in order to ensure the adequate performance of contracts between you and LR, or between you and a Supplier. The provision of this information is necessary to use the LR Platform and, without it, we will not be able to provide you with services that you request.
Member Information. When you submit a request for Accommodation booking information, we require certain information such as your first name, last name, email address and phone number. To use certain features within the LR Platform, we may need to ask you for additional information which may include your address and date of birth.
Identity Verification Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identity verification information (such as images of your government-issued ID, passport, national ID card, or driving license) or other authentication information.
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 identity verification information (such as images of your government issued ID, passport, national ID card, or driver’s license) or other authentication information, your date of birth, your address, email address, phone number and other information 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.
Communications with LR. When you communicate with LR, we collect information about your communication and any information you choose to provide.

You may choose to provide us with additional personal information in order to obtain a better user experience when using the LR Platform. For example, you may 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 LR representative, conduct a search, respond to surveys, participate in promotions, share your experience with us, or use other features of the LR Platform.This additional information will be processed based on our legitimate interest or when applicable, your consent.

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

When you use the LR Platform, we collect information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the LR Platform.
Usage Information. We collect information about your interactions with the LR 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 LR Platform.
Geo-Location Information. When you use certain features of the LR Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. LR may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Log Data. We automatically collect log data and device information when you access and use the LR Platform, even if you have not created an LR account or logged in. That information includes, among other things: details about how you’ve used the LR 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 (e.g., crashes, browser type), unique identifiers, cookie data and the pages you’ve viewed or engaged with before or after using the LR Platform.
Payment Transaction Information. We collect information related to your payment transactions on the LR Platform or transactions made through the LR Platform, including the payment instrument used, the date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the LR Platform or engage others to track your behavior on our behalf.
Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting us (see Section 10 below) with a description of your request and validation information. Users can access a mechanism for exercising such choice by going to http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. For more information on our use of these technologies, see our
California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the LR Platform for third party purposes, which is why we provide in our Cookie Policy the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

1.3. Information We Collect from Third Parties.

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

Background Information. For certain Members in the United States, to the extent permitted by applicable laws, LR 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 and with your consent where required, LR 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 (such as programs with property managers and owners) may submit personal information to facilitate account management and invitations to use enterprise products.
Referrals. If you are invited to LR, the person who invited you may 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 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 (with your consent where required) 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 LR Platform through partnerships, i or about your experiences and interactions from our partner ad networks. For example, if you book a restaurant reservation through LR, the restaurant may send information to us that you submitted to them, like your dining preferences or dining activity.

1.4. Children’s Data

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us (see Section 10 below).

2. How We Use The Information We Collect

We use, store, and process information about you to (1) provide, understand, improve, and develop the LR Platform, (2) create and maintain a trusted and safer environment, and (3) provide, personalize, measure, and improve our advertising and marketing.

2.1. Provide, Improve, and Develop the LR Platform. We may use the personal information to provide, improve, and develop the LR Platform such as to:

Enable you to access and use the LR Platform;
Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings;
Enable you to communicate with other Members;
Operate, provide, improve and optimize the LR Platform and experience, such as by performing analytics and conducting research;
Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier;
Provide customer service;
Send you service or support messages, such as updates, security alerts, and account notifications;
If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any other purpose you authorize at the time of collection;
To operate, protect, improve, and optimize the LR Platform and experience, and personalize and customize your experience (such as making Accommodation suggestions and ranking search results) and facilitate claims with our Host Guarantee, Host Protection Insurance or other similar Supplier protection programs, we conduct profiling based on your interactions with the LR Platform, your search and booking history, any saved account preferences and other content you submit to the LR Platform; and
Enable your use of our enterprise products.
We process this information given our legitimate interest in improving the LR 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. We may use the personal information to create and maintain a trusted and safer environment such as to:

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity; Conduct security investigations and risk assessments;
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);
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required;
Comply with our legal obligations (such as anti-money laundering regulations);
Resolve any disputes with any of our users and enforce our agreements with third parties.
Enforce our Terms of Use, Member agreements, and policies; and
In connection with the activities above, we may conduct profiling based on your interactions with the LR Platform, your member information and other content you submit to the LR Platform, and other information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the LR Platform if such processes detect activity that we think poses a safety or other risk to the LR Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us (see Section 10 below).

We process this information given our legitimate interest in protecting the LR 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. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about LR or partner campaigns and services, such as services offered by LR’s affiliate, Airbnb) and social media advertising through social media platforms such as Facebook or Google;
Personalize, measure, and improve advertising;
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LR or its third party business partners;
Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the LR Platform, information obtained from third parties, 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; and Invite you to events and relevant opportunities.
Enrolling in an email subscription will not affect the frequency of administrative emails
that we may send in connection with your use of the Services. No fee is charged for sending promotional emails to you, but third-party data rates may apply.

We process this information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.

2.4 SMS Terms

If you would like to receive text message communications from LR, such as booking assistance, customer support or notifications about the Services you can provide your prior express opt in consent in written form. In doing so you expressly authorize LR to use an autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In. By opting in you confirm that you are the subscriber to the relevant phone number or that you are otherwise authorized to opt in. Opt in is not a condition of purchase. Message and data rates may apply. You can opt out at any time by texting or replying STOP or by contacting us (see Section 10 below).

2.5 Your Choices

You have choices on the promotional messages that you choose to receive. You can limit the information you provide to LR. Participation in promotions and marketing programs is voluntary. You can limit the communications that LR sends to you.To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of marketing emails, we may still send you booking information or fraud alerts. To update your notifications settings on Airbnb go to your Airbnb account settings.

Sharing & Disclosure

3.1. Advertising and Social Media: Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in promotional activities conducted by LR partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the LR Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest.

The social media platforms with which we may share your personal information are not controlled or supervised by LR. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask LR to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).

3.2. Sharing between Suppliers and Guests.

To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

When you as a Guest submit a booking request, certain information about you may be shared with the Supplier (and Co-Supplier, if applicable) including your full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
When you as a Supplier (or Co-Supplier, if applicable) have a confirmed booking, certain information about you is shared with the Guest (and the additional Guests they may invite, if applicable) to coordinate the booking, such as your full name, phone number, and Accommodation address.

We don’t share your billing and payout information with other Members.

3.3. Listings and other Public Information.

The LR Platform publishes information, including personal information that is visible to the general public. For example, Public Listing pages are publicly visible and include information such as the Accommodation’s approximate location (neighbourhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, aggregated demand information (like page views over a period of time), and any additional information the Supplier chooses to share.

Based on our legitimate interest to promote the LR Platform, we may display parts of the LR Platform (e.g. your Listing page) on sites operated by LR’s business partners, using technologies such as widgets or APIs.

Information shared publicly on the LR Platform may be indexed through third party search engines. We do not control the practices of third party search engines.

3.4. Service Providers.

We use a variety of third party service providers to help us provide services related to the LR Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the LR services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims (such as claims under the LR Supplier Guarantee). These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

3.5. Additional Services by Suppliers.

Suppliers may use third party services available through the LR Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services, insurance or activities providers. Suppliers may share information about the Guest (like the Guest’s check-in and check-out dates, Guest name, Guest phone number with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services. Suppliers are responsible for third party service providers they use and ensuring those service providers process Guest information securely and in compliance with applicable law including data privacy and data protection laws.

3.6. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

LR may disclose your information to courts, law enforcement or governmental authorities, tax authorities or authorized 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 our legal obligations, (ii) to comply with legal process and to respond to claims asserted against LR, (iii) to respond to valid 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) to enforce and administer our Terms of Use or other agreements with Members, or (v) to protect the rights, property or personal safety of LR, its employees, its Members, or members of the public. For example, Supplier tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the LR Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

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 LR’s property, its Members and the LR Platform. 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.

3.7. Corporate Affiliates.

To help us provide the LR 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 LR Platform and our affiliates’ services. Our affiliates include other Luxury Retreats companies and Airbnb companies.

3.8. Tax Authorities.

In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers and Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.

3.9. Government Registration.

In jurisdictions where LR facilitates or requires a registration, notification, permit, or license application of a Supplier with a local governmental authority through the LR Platform in accordance with local law, we may share information of participating Suppliers with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Supplier’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.

3.10. Programs with Managers and Owners.

We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, Guest booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a Supplier lives and/or the Listing is to facilitate hosting services, security, billing, and other services that may be provided. 3.11. Business Transfers.

If LR 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 personal 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.

3.12. 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 anonymized information for industry and market analysis, regulatory compliance, research, demographic profiling, marketing and advertising, and other business purposes.

3.13. Airbnb Member Account and Payment Services

Please note in order to list or book Accommodation on the LR Platform, Members must create an Airbnb account and use the Airbnb Payment Services. Account creation and use of the Airbnb account and Payment Services is subject to the applicable (as amended from time to time).

4. Other Important Information

4.1. Analyzing your Communications.

We may review, scan, or analyze your communications on the LR 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 analyze messages to mask contact information and references to other websites. 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. 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 analyze 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 LR’s legitimate interest in ensuring compliance with applicable laws, our Terms of Use, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2. Third Party Partners & Integrations

The LR 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” ). LR 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, LR, or both. 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.

4.3 Google Maps/Earth.

Parts of the LR Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Your Rights

You may exercise any of the rights described in this section before your applicable LR Data Controller by contacting us (see Section 10 below). Please note that we may ask you to verify your identity and request before taking further action on your request.

5.1. Managing Your Information.

You may access and update some of your Airbnb information through your Airbnb account. You are responsible for keeping your personal information up-to-date.

5.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you and which you cannot update yourself.

5.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.4 Data Retention and Erasure.

We generally retain your information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the LR Platform to you, you can request that we erase your personal information by contacting us (see Section 10 below). Please note that if you request the erasure of your personal information:

Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the LR Platform to protect 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.
LR may retain certain information to the extent necessary to comply with its legal obligations. For example, LR may keep some of your information for tax, legal, reporting and auditing obligations.
LR 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 LR suspends a user for fraud or user safety reasons, LR may retain certain information from that account to prevent that user from using the Services in the future.

5.5 Withdrawing Consent.

If we are processing your personal information based on your consent you may withdraw your consent at any time by contacting us (see Section 10 below) specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

5.6 Restricting Processing.

In some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.7 and pending the verification whether the legitimate grounds of LR override your own.

5.7 Objecting to Processing.

In some jurisdictions, applicable law may entitle you to require LR not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, LR will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask LR to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).

5.8 Lodging Complaints.

You have the right to lodge complaints about the data processing activities carried out by LR before competent data protection authorities.

6. Operating Globally and International Transfers

To facilitate our global operations LR may transfer, store, and process your information within our family of companies, partners, and service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. The transfer of information is necessary to provide our services as set out in the Terms of Use. In certain cases LR may rely on Standard Contractual Clauses approved by the European Commission and European Commission's adequacy decisions about certain countries, as applicable, to receive data transferred from the EEA to other countries outside of where you live. You may request a copy of the Standard Contractual Clauses by contacting us (see Section 10 below).

7. California Residents.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year. LR does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. If you do opt-in to receiving marketing and other communications from a third party, please be advised that the information you elect to share with that third party will be governed by the third party’s privacy policy and terms of service, and we encourage you to review those policies before providing consent for LR to share your information.

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Contact us (see Section 10 below) for information on data subject rights requests and how to submit a request.

We do not sell personal information to third parties. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

8. 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.

9. Changes to this Privacy Policy

LR reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy that materially disadvantage our existing users we will provide you with reasonable advance notice of the modifications in accordance with applicable law. If you disagree with the modified Privacy Policy you may cease using the Services. Your continued access to or use of the Services after the effective date of any such modifications will constitute acceptance of the modifications. We will also post the revised Privacy Policy on the LR Platform and update the “Last Updated” date at the top of this Privacy Policy. For modifications that we need to make to meet security, safety, legal or regulatory requirements, we may not be able to notify you in advance but we will let you know as soon as practicable.

10. Contact

If you need to contact us or have any questions or complaints about this Privacy Policy or LR’s information handling practices (including how our service providers process your personal information), you may contact LR at: Data Protection Officer, 5530 St. Patrick, Suite 2210, Montreal, Quebec, Canada H4E 1A8. You may also email us at privacy@luxuryretreats.com.

Privacy Policy effective until 10 January 2020.

Luxury Retreats Privacy Policy
This Privacy Policy explains how we collect, use, process, and disclose your information across the LR Platform. The “LR Platform” refers to Luxury Retreats’ ( “LR” ) websites, our mobile, tablet and other smart applications, and all associated LR services.

When this policy mentions “LR,” “we,” “us,” or “our,” it refers to the Luxury Retreats company that is responsible for your information under this Privacy Policy (the “Data Controller” ). The Data Controller is the Luxury Retreats entity that you are contracting with which, if you are booking or supplying Accommodation through the LR Platform, will be one of the following:

If you are booking or supplying Accommodation located in Canada or Barbados, the Data Controller is Luxury Retreats International ULC ( “LRI” ).
If you are booking or supplying Accommodation located in the Collectivity of Saint Martin, the Data Controller is SVV SXM ( “Carimo” ).
If you are booking or supplying Accommodation located outside of Canada, Barbados, and Saint Martin, the Data Controller is Luxury Retreats Management Inc. ( “LRM” ).
Please see Section 10 for contact details of the companies listed above.

In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered an LR account, including Suppliers and Guests. A “Supplier” is someone who offers services ( “Supplier Services” ) via published listings on the LR 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 Member’s use of the LR 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 LR Platform in order to ensure the adequate performance of contracts between you and LR, or between you and a Supplier. The provision of this information is necessary to use the LR Platform and, without it, we will not be able to provide you with services that you request.

Account Information. When you sign up for an LR account or submit a request for Accommodation booking information, we require certain information such as your name and email address.
Profile Information. To use certain features within the LR Platform, we may need to ask you to complete a profile, which may include your address and phone number.
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.
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.
Communications with LR. When you communicate with LR, we collect information about your communication and any information you choose to provide.
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 LR representative, conduct a search, update or add information to your LR account, respond to surveys, participate in promotions, or use other features of the LR Platform.

1.2. Information We Automatically Collect from Your Use of the LR Platform.
When you use the LR Platform, we collect information about the services you use and how you use them, even if you don’t sign up for an LR account. We process this information for the activities and legal bases described in Section 2 below.

Usage Information. We collect information about your interactions with the LR 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 LR Platform.
Location Information. When you use certain features of the LR Platform, we may collect different types of information about your general location (e.g. IP address, zip code).
Log Data. We automatically collect log information when you use the LR Platform, even if you have not created an LR account or logged in. That information includes, among other things: details about how you’ve used the LR 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., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the LR Platform.
Transaction Information. We collect information related to your transactions on the LR Platform or transactions made through the LR Platform, including the date and time, amounts charged, and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the LR Platform, or engage others to track your behavior on our behalf. You may disable the usage of cookies through your browser settings. For more information on our use of these technologies, see our Cookie Policy.
California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the LR Platform for third party purposes, which is why we provide in our Cookie Policy the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

1.3. Information We Collect from Third Parties.
We may collect information that others provide about you when they use the LR Platform, or obtain information from other sources and combine that with information we collect through the LR Platform. LR 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 LR should be directed to such third parties.

Third Party Services. If you link, connect, or login to your LR 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.
Background Information. For certain Members in the United States, to the extent permitted by applicable laws, LR 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, LR 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.
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 LR Platform, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through LR, 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 LR 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 LR Platform, and to create and maintain a trusted and safer environment.

2.1. Provide, Improve, and Develop the LR Platform.
Enable you to access and use the LR Platform.
Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
Enable you to communicate with other Members.
Operate, provide, improve and optimize the LR Platform and experience, such as by performing analytics and conducting research.
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.
Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
Provide customer service.
Send you service or support messages, such as updates, security alerts, and account notifications.
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 LR 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.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct investigations and risk assessments.
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).
Conduct checks against databases and other information sources. Comply with our legal obligations.
Resolve any disputes with any of our users and enforce our agreements with third parties.
Enforce our Terms of Service, Member agreements, and policies.

We process this information given our legitimate interest in protecting the LR 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.

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about LR or partner campaigns and services, such as services offered by LR’s affiliate, Airbnb).
Personalize, measure, and improve advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LR or its third party business partners.
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 LR 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 Authorized by Law.
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 Guest, 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 authorizing LR 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 LR and personal information shared with them is subject to their privacy policies and practices.
We may also share certain contact details about you, such as your name, email and past reservations in LR, to other companies and business partners of LR, including our affiliate, Airbnb, who may then send you marketing communications about products or services that may interest you.

3.2. Sharing between Suppliers and Guests.
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.
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.

3.3. Reviews, Listings, and other Public Information.
The LR Platform publishes information that is visible to the general public. For example:
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.
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.
If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the LR Platform, that content is publicly visible.

Information you share publicly on the LR 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 LR 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.

3.5. Additional Services by Suppliers.
Suppliers may use third party services available through the LR 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 LR Platform to share information about the Guest (like the Guest’s check-in and check-out dates, name, phone number, and anonymized 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.
LR may disclose your information to courts, law enforcement or governmental authorities, or authorized 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 LR, (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, (iii) to enforce and administer our Terms of Use or other agreements with Members, (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 LR, 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 LR’s property, its Members and the LR 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 LR 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 LR Platform and our affiliates’ services. Our affiliates include other Luxury Retreats companies and Airbnb companies.

3.8. Widgets.
We may display parts of the LR Platform (e.g., your Listing page) on sites operated by LR’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, Suppliers and Guests expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.

3.10. Business Transfers.
If LR 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 personal 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.

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. Analyzing your Communications.
We may review, scan, or analyze your communications on the LR 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 analyze messages to mask contact information and references to other websites. 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. 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 analyze 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 LR’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 LR account with your account at a third party social networking service. When you create this link:

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
the publication and display of information that you provide to LR through this linkage is subject to any of your settings and authorizations on the LR 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.
Parts of the LR Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Third Party Partners & Integrations
The LR 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”). LR 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, Airbnb, or both. 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 LR 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 LR 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 LR Platform to you, you may cancel your account or request us to erase your personal information. To cancel your LR account, contact us. If you cancel your account or request erasure of your personal information, note that:

Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the LR Platform in association with your first name, even after your LR account is cancelled.
Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the LR 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.
LR may retain certain information to the extent necessary to comply with its legal obligations.
LR 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 LR removes a user account for fraud or user safety reasons, LR may retain certain information from that account to prevent that user from opening a new LR account in the future.

6.3 Withdrawing Consent.
In some jurisdictions, applicable law may entitle you to withdraw consent you previously gave to LR to process your information and to end your use of the LR Platform by cancelling your account as described in this section. Additionally, you may have the right to limit the ways in which we use your personal information.

For information about, and to opt-out of, online behavioral advertising, please see our Cookie Policy.

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 LR is not holding accurate data about you) and in line with applicable law, you may request LR 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 LR 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 privacy@luxuryretreats.com. 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 LR before competent data protection authorities.

7. Operating Globally
As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties.

7.1 Service Providers. Where we engage third party service providers to help us provide services related to the LR Platform, we may need to transfer them your personal information for the purposes described in this Privacy Policy. These services providers may be located inside or outside of the European Economic Area (“EEA”), including in countries that are considered to provide a level of data protection equivalent to that provided in the EEA (like Canada) and other countries that do not, including the United States and Barbados. When transferring your personal information to service providers in these countries, we will ensure that such information is processed there in a manner consistent with this Privacy Policy.

When you use the LR Platform, you authorize us to transfer, store, and process your information in such countries. Laws in these countries may differ from the laws applicable to the place where you live. By using the LR Platform, you consent to transferring your data to these countries.

7.2 California Residents.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year. LR does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. If you do opt-in to receiving marketing and other communications from a third party, please be advised that the information you elect to share with that third party will be governed by the third party’s privacy policy and terms of service, and we encourage you to review those policies before providing consent for LR to share your information.

8. 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.

9. Changes to this Privacy Policy
LR reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the LR Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your LR account before the date the revised Privacy Policy becomes effective, your continued access or use of the LR Platform will constitute acceptance of the revised Privacy Policy.

10. Contact
If you have any questions or complaints about this Privacy Policy or LR’s information handling practices (including how our service providers process your personal information), you may contact LR at: Data Protection Officer, 5530 St. Patrick, Suite 2210, Montreal, Quebec, Canada H4E 1A8. You may also email us at privacy@luxuryretreats.com.
We’re updating our Privacy Policy on 10th January 2020. You can review the new policy below.

Privacy Policy updated and effective from 10 January 2020.

Luxury Retreats Privacy Policy

This Privacy Policy explains how we collect, use, process, and disclose your information across the LR Platform. The “LR Platform” refers to Luxury Retreats’ ( “LR” ) websites, our mobile, tablet and other smart applications, and all associated LR services.

When this policy mentions “LR,” “we,” “us,” or “our,” it refers to the Luxury Retreats company that is responsible for your information under this Privacy Policy (the “Data Controller” ). The Data Controller is the Luxury Retreats entity that you are contracting with which, if you are booking or supplying Accommodation through the LR Platform, will be one of the following:

If you are booking or supplying Accommodation located in Canada or Barbados, the Data Controller is Luxury Retreats International ULC ( “LRI” ).
If you are booking or supplying Accommodation located in the Collectivity of Saint Martin, the Data Controller is SVV SXM ( “Carimo” ).
If you are booking or supplying Accommodation located outside of Canada, Barbados, and Saint Martin, the Data Controller is Luxury Retreats Management Inc. ( “LRM” ).

Please see Section 10 for contact details of the companies listed above.

In this policy, we use a few terms which are defined as follows: A “Supplier” is someone who offers services ( “Supplier Services” ) via published listings on the LR Platform ( “Listings” ). A “Guest” is someone who books, or seeks to book, Supplier Services (“Suppliers and Guests are Collectively “Members” ). “Accommodation” means a vacation or other property. “Payment Services” means any payment processing services provided through or in connection with a Member’s use of the LR 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 LR Platform in order to ensure the adequate performance of contracts between you and LR, or between you and a Supplier. The provision of this information is necessary to use the LR Platform and, without it, we will not be able to provide you with services that you request.
Member Information. When you submit a request for Accommodation booking information, we require certain information such as your first name, last name, email address and phone number. To use certain features within the LR Platform, we may need to ask you for additional information which may include your address and date of birth.
Identity Verification Information. To help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identity verification information (such as images of your government-issued ID, passport, national ID card, or driving license) or other authentication information.
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 identity verification information (such as images of your government issued ID, passport, national ID card, or driver’s license) or other authentication information, your date of birth, your address, email address, phone number and other information 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.
Communications with LR. When you communicate with LR, we collect information about your communication and any information you choose to provide.

You may choose to provide us with additional personal information in order to obtain a better user experience when using the LR Platform. For example, you may 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 LR representative, conduct a search, respond to surveys, participate in promotions, share your experience with us, or use other features of the LR Platform.This additional information will be processed based on our legitimate interest or when applicable, your consent.

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

When you use the LR Platform, we collect information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the LR Platform.
Usage Information. We collect information about your interactions with the LR 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 LR Platform.
Geo-Location Information. When you use certain features of the LR Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. LR may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
Log Data. We automatically collect log data and device information when you access and use the LR Platform, even if you have not created an LR account or logged in. That information includes, among other things: details about how you’ve used the LR 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 (e.g., crashes, browser type), unique identifiers, cookie data and the pages you’ve viewed or engaged with before or after using the LR Platform.
Payment Transaction Information. We collect information related to your payment transactions on the LR Platform or transactions made through the LR Platform, including the payment instrument used, the date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the LR Platform or engage others to track your behavior on our behalf.
Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting us (see Section 10 below) with a description of your request and validation information. Users can access a mechanism for exercising such choice by going to http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. For more information on our use of these technologies, see our
California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the LR Platform for third party purposes, which is why we provide in our Cookie Policy the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

1.3. Information We Collect from Third Parties.

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

Background Information. For certain Members in the United States, to the extent permitted by applicable laws, LR 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 and with your consent where required, LR 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 (such as programs with property managers and owners) may submit personal information to facilitate account management and invitations to use enterprise products.
Referrals. If you are invited to LR, the person who invited you may 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 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 (with your consent where required) 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 LR Platform through partnerships, i or about your experiences and interactions from our partner ad networks. For example, if you book a restaurant reservation through LR, the restaurant may send information to us that you submitted to them, like your dining preferences or dining activity.

1.4. Children’s Data

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us (see Section 10 below).

2. How We Use The Information We Collect

We use, store, and process information about you to (1) provide, understand, improve, and develop the LR Platform, (2) create and maintain a trusted and safer environment, and (3) provide, personalize, measure, and improve our advertising and marketing.

2.1. Provide, Improve, and Develop the LR Platform. We may use the personal information to provide, improve, and develop the LR Platform such as to:

Enable you to access and use the LR Platform;
Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings;
Enable you to communicate with other Members;
Operate, provide, improve and optimize the LR Platform and experience, such as by performing analytics and conducting research;
Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier;
Provide customer service;
Send you service or support messages, such as updates, security alerts, and account notifications;
If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any other purpose you authorize at the time of collection;
To operate, protect, improve, and optimize the LR Platform and experience, and personalize and customize your experience (such as making Accommodation suggestions and ranking search results) and facilitate claims with our Host Guarantee, Host Protection Insurance or other similar Supplier protection programs, we conduct profiling based on your interactions with the LR Platform, your search and booking history, any saved account preferences and other content you submit to the LR Platform; and
Enable your use of our enterprise products.
We process this information given our legitimate interest in improving the LR 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. We may use the personal information to create and maintain a trusted and safer environment such as to:

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity; Conduct security investigations and risk assessments;
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);
Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required;
Comply with our legal obligations (such as anti-money laundering regulations);
Resolve any disputes with any of our users and enforce our agreements with third parties.
Enforce our Terms of Use, Member agreements, and policies; and
In connection with the activities above, we may conduct profiling based on your interactions with the LR Platform, your member information and other content you submit to the LR Platform, and other information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the LR Platform if such processes detect activity that we think poses a safety or other risk to the LR Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us (see Section 10 below).

We process this information given our legitimate interest in protecting the LR 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. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about LR or partner campaigns and services, such as services offered by LR’s affiliate, Airbnb) and social media advertising through social media platforms such as Facebook or Google;
Personalize, measure, and improve advertising;
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LR or its third party business partners;
Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the LR Platform, information obtained from third parties, 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; and Invite you to events and relevant opportunities.
Enrolling in an email subscription will not affect the frequency of administrative emails
that we may send in connection with your use of the Services. No fee is charged for sending promotional emails to you, but third-party data rates may apply.

We process this information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.

2.4 SMS Terms

If you would like to receive text message communications from LR, such as booking assistance, customer support or notifications about the Services you can provide your prior express opt in consent in written form. In doing so you expressly authorize LR to use an autodialer or non-autodialer technology to send text messages to the cell phone number associated with your Opt-In. By opting in you confirm that you are the subscriber to the relevant phone number or that you are otherwise authorized to opt in. Opt in is not a condition of purchase. Message and data rates may apply. You can opt out at any time by texting or replying STOP or by contacting us (see Section 10 below).

2.5 Your Choices

You have choices on the promotional messages that you choose to receive. You can limit the information you provide to LR. Participation in promotions and marketing programs is voluntary. You can limit the communications that LR sends to you.To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you. Please note that even if you opt-out of marketing communications, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of marketing emails, we may still send you booking information or fraud alerts. To update your notifications settings on Airbnb go to your Airbnb account settings.

Sharing & Disclosure

3.1. Advertising and Social Media: Sharing With Your Consent.
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in promotional activities conducted by LR partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the LR Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest.

The social media platforms with which we may share your personal information are not controlled or supervised by LR. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

Please note that you may, at any time ask LR to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).

3.2. Sharing between Suppliers and Guests.

To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

When you as a Guest submit a booking request, certain information about you may be shared with the Supplier (and Co-Supplier, if applicable) including your full name, the full name of any additional Guests, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
When you as a Supplier (or Co-Supplier, if applicable) have a confirmed booking, certain information about you is shared with the Guest (and the additional Guests they may invite, if applicable) to coordinate the booking, such as your full name, phone number, and Accommodation address.

We don’t share your billing and payout information with other Members.

3.3. Listings and other Public Information.

The LR Platform publishes information, including personal information that is visible to the general public. For example, Public Listing pages are publicly visible and include information such as the Accommodation’s approximate location (neighbourhood and city) or precise location (where you have provided your consent), Listing description, calendar availability, aggregated demand information (like page views over a period of time), and any additional information the Supplier chooses to share.

Based on our legitimate interest to promote the LR Platform, we may display parts of the LR Platform (e.g. your Listing page) on sites operated by LR’s business partners, using technologies such as widgets or APIs.

Information shared publicly on the LR Platform may be indexed through third party search engines. We do not control the practices of third party search engines.

3.4. Service Providers.

We use a variety of third party service providers to help us provide services related to the LR Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in Europe, India, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the LR services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess insurance claims or other similar claims (such as claims under the LR Supplier Guarantee). These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions.

3.5. Additional Services by Suppliers.

Suppliers may use third party services available through the LR Platform to assist with managing their Accommodation or providing additional services requested by you, such as cleaning services, insurance or activities providers. Suppliers may share information about the Guest (like the Guest’s check-in and check-out dates, Guest name, Guest phone number with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services. Suppliers are responsible for third party service providers they use and ensuring those service providers process Guest information securely and in compliance with applicable law including data privacy and data protection laws.

3.6. Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

LR may disclose your information to courts, law enforcement or governmental authorities, tax authorities or authorized 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 our legal obligations, (ii) to comply with legal process and to respond to claims asserted against LR, (iii) to respond to valid 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) to enforce and administer our Terms of Use or other agreements with Members, or (v) to protect the rights, property or personal safety of LR, its employees, its Members, or members of the public. For example, Supplier tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the LR Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

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 LR’s property, its Members and the LR Platform. 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.

3.7. Corporate Affiliates.

To help us provide the LR 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 LR Platform and our affiliates’ services. Our affiliates include other Luxury Retreats companies and Airbnb companies.

3.8. Tax Authorities.

In jurisdictions where we facilitate the collection and remittance of occupancy taxes, Suppliers and Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.

3.9. Government Registration.

In jurisdictions where LR facilitates or requires a registration, notification, permit, or license application of a Supplier with a local governmental authority through the LR Platform in accordance with local law, we may share information of participating Suppliers with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Supplier’s full name and contact details, Accommodation address, tax identification number, Listing details, and number of nights booked.

3.10. Programs with Managers and Owners.

We may share personal information and booking information with landlords, management companies, and/or property owners in order to facilitate programs with these partners. For example, Guest booking and personal information may be shared with owners and property managers of the building, complex, or planned community where a Supplier lives and/or the Listing is to facilitate hosting services, security, billing, and other services that may be provided. 3.11. Business Transfers.

If LR 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 personal 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.

3.12. 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 anonymized information for industry and market analysis, regulatory compliance, research, demographic profiling, marketing and advertising, and other business purposes.

3.13. Airbnb Member Account and Payment Services

Please note in order to list or book Accommodation on the LR Platform, Members must create an Airbnb account and use the Airbnb Payment Services. Account creation and use of the Airbnb account and Payment Services is subject to the applicable (as amended from time to time).

4. Other Important Information

4.1. Analyzing your Communications.

We may review, scan, or analyze your communications on the LR 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 analyze messages to mask contact information and references to other websites. 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. 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 analyze 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 LR’s legitimate interest in ensuring compliance with applicable laws, our Terms of Use, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2. Third Party Partners & Integrations

The LR 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” ). LR 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, LR, or both. 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.

4.3 Google Maps/Earth.

Parts of the LR Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Your Rights

You may exercise any of the rights described in this section before your applicable LR Data Controller by contacting us (see Section 10 below). Please note that we may ask you to verify your identity and request before taking further action on your request.

5.1. Managing Your Information.

You may access and update some of your Airbnb information through your Airbnb account. You are responsible for keeping your personal information up-to-date.

5.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you and which you cannot update yourself.

5.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.4 Data Retention and Erasure.

We generally retain your information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the LR Platform to you, you can request that we erase your personal information by contacting us (see Section 10 below). Please note that if you request the erasure of your personal information:

Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the LR Platform to protect 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.
LR may retain certain information to the extent necessary to comply with its legal obligations. For example, LR may keep some of your information for tax, legal, reporting and auditing obligations.
LR 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 LR suspends a user for fraud or user safety reasons, LR may retain certain information from that account to prevent that user from using the Services in the future.

5.5 Withdrawing Consent.

If we are processing your personal information based on your consent you may withdraw your consent at any time by contacting us (see Section 10 below) specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

5.6 Restricting Processing.

In some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.7 and pending the verification whether the legitimate grounds of LR override your own.

5.7 Objecting to Processing.

In some jurisdictions, applicable law may entitle you to require LR not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, LR will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask LR to cease processing your data for these direct marketing purposes by contacting us (see Section 10 below).

5.8 Lodging Complaints.

You have the right to lodge complaints about the data processing activities carried out by LR before competent data protection authorities.

6. Operating Globally and International Transfers

To facilitate our global operations LR may transfer, store, and process your information within our family of companies, partners, and service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. The transfer of information is necessary to provide our services as set out in the Terms of Use. In certain cases LR may rely on Standard Contractual Clauses approved by the European Commission and European Commission's adequacy decisions about certain countries, as applicable, to receive data transferred from the EEA to other countries outside of where you live. You may request a copy of the Standard Contractual Clauses by contacting us (see Section 10 below).

7. California Residents.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year. LR does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. If you do opt-in to receiving marketing and other communications from a third party, please be advised that the information you elect to share with that third party will be governed by the third party’s privacy policy and terms of service, and we encourage you to review those policies before providing consent for LR to share your information.

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Contact us (see Section 10 below) for information on data subject rights requests and how to submit a request.

We do not sell personal information to third parties. We do allow third parties to collect personal information through our Service and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

8. 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.

9. Changes to this Privacy Policy

LR reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy that materially disadvantage our existing users we will provide you with reasonable advance notice of the modifications in accordance with applicable law. If you disagree with the modified Privacy Policy you may cease using the Services. Your continued access to or use of the Services after the effective date of any such modifications will constitute acceptance of the modifications. We will also post the revised Privacy Policy on the LR Platform and update the “Last Updated” date at the top of this Privacy Policy. For modifications that we need to make to meet security, safety, legal or regulatory requirements, we may not be able to notify you in advance but we will let you know as soon as practicable.

10. Contact

If you need to contact us or have any questions or complaints about this Privacy Policy or LR’s information handling practices (including how our service providers process your personal information), you may contact LR at: Data Protection Officer, 5530 St. Patrick, Suite 2210, Montreal, Quebec, Canada H4E 1A8. You may also email us at privacy@luxuryretreats.com.

Privacy Policy effective until 10 January 2020.

Luxury Retreats Privacy Policy
This Privacy Policy explains how we collect, use, process, and disclose your information across the LR Platform. The “LR Platform” refers to Luxury Retreats’ ( “LR” ) websites, our mobile, tablet and other smart applications, and all associated LR services.

When this policy mentions “LR,” “we,” “us,” or “our,” it refers to the Luxury Retreats company that is responsible for your information under this Privacy Policy (the “Data Controller” ). The Data Controller is the Luxury Retreats entity that you are contracting with which, if you are booking or supplying Accommodation through the LR Platform, will be one of the following:

If you are booking or supplying Accommodation located in Canada or Barbados, the Data Controller is Luxury Retreats International ULC ( “LRI” ).
If you are booking or supplying Accommodation located in the Collectivity of Saint Martin, the Data Controller is SVV SXM ( “Carimo” ).
If you are booking or supplying Accommodation located outside of Canada, Barbados, and Saint Martin, the Data Controller is Luxury Retreats Management Inc. ( “LRM” ).
Please see Section 10 for contact details of the companies listed above.

In this policy, we use a few terms which are defined as follows: A “Member” is anyone who has registered an LR account, including Suppliers and Guests. A “Supplier” is someone who offers services ( “Supplier Services” ) via published listings on the LR 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 Member’s use of the LR 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 LR Platform in order to ensure the adequate performance of contracts between you and LR, or between you and a Supplier. The provision of this information is necessary to use the LR Platform and, without it, we will not be able to provide you with services that you request.

Account Information. When you sign up for an LR account or submit a request for Accommodation booking information, we require certain information such as your name and email address.
Profile Information. To use certain features within the LR Platform, we may need to ask you to complete a profile, which may include your address and phone number.
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.
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.
Communications with LR. When you communicate with LR, we collect information about your communication and any information you choose to provide.
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 LR representative, conduct a search, update or add information to your LR account, respond to surveys, participate in promotions, or use other features of the LR Platform.

1.2. Information We Automatically Collect from Your Use of the LR Platform.
When you use the LR Platform, we collect information about the services you use and how you use them, even if you don’t sign up for an LR account. We process this information for the activities and legal bases described in Section 2 below.

Usage Information. We collect information about your interactions with the LR 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 LR Platform.
Location Information. When you use certain features of the LR Platform, we may collect different types of information about your general location (e.g. IP address, zip code).
Log Data. We automatically collect log information when you use the LR Platform, even if you have not created an LR account or logged in. That information includes, among other things: details about how you’ve used the LR 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., crashes, browser type), unique identifiers, and the page you’ve viewed or engaged with before or after using the LR Platform.
Transaction Information. We collect information related to your transactions on the LR Platform or transactions made through the LR Platform, including the date and time, amounts charged, and other related transaction details.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the LR Platform, or engage others to track your behavior on our behalf. You may disable the usage of cookies through your browser settings. For more information on our use of these technologies, see our Cookie Policy.
California Do Not Track Disclosure. We are committed to providing you with meaningful choices about the information collected on the LR Platform for third party purposes, which is why we provide in our Cookie Policy the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, and Google Analytics opt out link. However, we do not recognize or respond to browser-initiated Do Not Track signals.

1.3. Information We Collect from Third Parties.
We may collect information that others provide about you when they use the LR Platform, or obtain information from other sources and combine that with information we collect through the LR Platform. LR 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 LR should be directed to such third parties.

Third Party Services. If you link, connect, or login to your LR 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.
Background Information. For certain Members in the United States, to the extent permitted by applicable laws, LR 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, LR 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.
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 LR Platform, including about your interactions from our partner ad networks. For example, if you book a restaurant reservation through LR, 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 LR 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 LR Platform, and to create and maintain a trusted and safer environment.

2.1. Provide, Improve, and Develop the LR Platform.
Enable you to access and use the LR Platform.
Contact you about your booking requests, plan your stay at one of our villas, and make and manage your bookings.
Enable you to communicate with other Members.
Operate, provide, improve and optimize the LR Platform and experience, such as by performing analytics and conducting research.
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.
Enable you to access and use the Payment Services, including collecting payment on behalf of a Supplier.
Provide customer service.
Send you service or support messages, such as updates, security alerts, and account notifications.
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 LR 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.

Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
Conduct investigations and risk assessments.
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).
Conduct checks against databases and other information sources. Comply with our legal obligations.
Resolve any disputes with any of our users and enforce our agreements with third parties.
Enforce our Terms of Service, Member agreements, and policies.

We process this information given our legitimate interest in protecting the LR 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.

Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about LR or partner campaigns and services, such as services offered by LR’s affiliate, Airbnb).
Personalize, measure, and improve advertising.
Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LR or its third party business partners.
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 LR 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 Authorized by Law.
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 Guest, 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 authorizing LR 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 LR and personal information shared with them is subject to their privacy policies and practices.
We may also share certain contact details about you, such as your name, email and past reservations in LR, to other companies and business partners of LR, including our affiliate, Airbnb, who may then send you marketing communications about products or services that may interest you.

3.2. Sharing between Suppliers and Guests.
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.
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.

3.3. Reviews, Listings, and other Public Information.
The LR Platform publishes information that is visible to the general public. For example:
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.
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.
If you submit content on our blog, in a public forum, or in a social media post, or use a similar feature on the LR Platform, that content is publicly visible.

Information you share publicly on the LR 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 LR 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.

3.5. Additional Services by Suppliers.
Suppliers may use third party services available through the LR 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 LR Platform to share information about the Guest (like the Guest’s check-in and check-out dates, name, phone number, and anonymized 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.
LR may disclose your information to courts, law enforcement or governmental authorities, or authorized 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 LR, (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, (iii) to enforce and administer our Terms of Use or other agreements with Members, (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 LR, 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 LR’s property, its Members and the LR 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 LR 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 LR Platform and our affiliates’ services. Our affiliates include other Luxury Retreats companies and Airbnb companies.

3.8. Widgets.
We may display parts of the LR Platform (e.g., your Listing page) on sites operated by LR’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, Suppliers and Guests expressly grant us permission, without further notice, to disclose Suppliers’ and Guests’ data and other information relating to them or to their transactions, bookings, Accommodations and occupancy taxes to the relevant tax authority, including, but not limited to, the Supplier’s or Guest’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Suppliers from Guests, and contact information.

3.10. Business Transfers.
If LR 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 personal 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.

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. Analyzing your Communications.
We may review, scan, or analyze your communications on the LR 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 analyze messages to mask contact information and references to other websites. 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. 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 analyze 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 LR’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 LR account with your account at a third party social networking service. When you create this link:

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
the publication and display of information that you provide to LR through this linkage is subject to any of your settings and authorizations on the LR 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.
Parts of the LR Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.

5. Third Party Partners & Integrations
The LR 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”). LR 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, Airbnb, or both. 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 LR 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 LR 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 LR Platform to you, you may cancel your account or request us to erase your personal information. To cancel your LR account, contact us. If you cancel your account or request erasure of your personal information, note that:

Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the LR Platform in association with your first name, even after your LR account is cancelled.
Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain the LR 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.
LR may retain certain information to the extent necessary to comply with its legal obligations.
LR 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 LR removes a user account for fraud or user safety reasons, LR may retain certain information from that account to prevent that user from opening a new LR account in the future.

6.3 Withdrawing Consent.
In some jurisdictions, applicable law may entitle you to withdraw consent you previously gave to LR to process your information and to end your use of the LR Platform by cancelling your account as described in this section. Additionally, you may have the right to limit the ways in which we use your personal information.

For information about, and to opt-out of, online behavioral advertising, please see our Cookie Policy.

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 LR is not holding accurate data about you) and in line with applicable law, you may request LR 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 LR 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 privacy@luxuryretreats.com. 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 LR before competent data protection authorities.

7. Operating Globally
As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties.

7.1 Service Providers. Where we engage third party service providers to help us provide services related to the LR Platform, we may need to transfer them your personal information for the purposes described in this Privacy Policy. These services providers may be located inside or outside of the European Economic Area (“EEA”), including in countries that are considered to provide a level of data protection equivalent to that provided in the EEA (like Canada) and other countries that do not, including the United States and Barbados. When transferring your personal information to service providers in these countries, we will ensure that such information is processed there in a manner consistent with this Privacy Policy.

When you use the LR Platform, you authorize us to transfer, store, and process your information in such countries. Laws in these countries may differ from the laws applicable to the place where you live. By using the LR Platform, you consent to transferring your data to these countries.

7.2 California Residents.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year. LR does not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent. If you do opt-in to receiving marketing and other communications from a third party, please be advised that the information you elect to share with that third party will be governed by the third party’s privacy policy and terms of service, and we encourage you to review those policies before providing consent for LR to share your information.

8. 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.

9. Changes to this Privacy Policy
LR reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the LR Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your LR account before the date the revised Privacy Policy becomes effective, your continued access or use of the LR Platform will constitute acceptance of the revised Privacy Policy.

10. Contact
If you have any questions or complaints about this Privacy Policy or LR’s information handling practices (including how our service providers process your personal information), you may contact LR at: Data Protection Officer, 5530 St. Patrick, Suite 2210, Montreal, Quebec, Canada H4E 1A8. You may also email us at privacy@luxuryretreats.com.