Privacy Policy

Last Updated: 27 May, 2022

HopLocal (a part of GetMe Technologies OÜ) exists to help build connections between people and make the world more open and inclusive. In short—to build a world where anyone can belong anywhere. We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy.

This Privacy Policy describes how HopLocal and its affiliates (“we,” “us,” or “HopLocal”), process personal information that we collect through the HopLocal Platform. Depending on where you live and what you are doing on the HopLocal Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information provided there with information about how we process personal information for those regions and services.

We store user’s important information required by the General Data Protection Regulation (“GDPR”) to disclose, including (i) the controller(s) of your personal information; (ii) legal bases, (iii) your legal rights, (iv) safeguards we rely on for transferring your personal information outside the EEA; and (v) the contact details of the controller and Data Protection Officer. This page also contains important information about the Payments Controller (defined below) and the information processed in connection with the Payments Services. Please read this page carefully. If you have any questions, you can contact us at the details below.

1.1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service & Conditions (“Terms”).

1.2. PERSONAL INFORMATION WE COLLECT

1.2.1 Information needed to use the HopLocal Platform.

We collect personal information about you when you use the HopLocal Platform. Without it, we may not be able to provide you with all services requested. This information includes:

• Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

1.2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.

1.2.3 Information Automatically Collected by Using the HopLocal Platform and our Payment Services.

When you use the HopLocal Platform and Payment Services, we automatically collect personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the HopLocal Platform.
• Log Data and Device Information. Such as details about how you’ve used the HopLocal 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, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the HopLocal Platform. We may collect this information even if you haven’t created an HopLocal account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

1.2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:.

• Third-Party Services. If you link, connect, or login to the HopLocal Platform with a third party service (e.g. Google, Facebook, WooCommerce, Stripe, etc.), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Background Information. For Members in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. To the extent permitted by applicable laws and with your consent where required, we 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 may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals and co-travelers. If you are invited to the HopLocal Platform such as a co-traveler on a trip, the person who invited you can 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 references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the HopLocal Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

1.2.5 Sharing and disclosure

Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your HopLocal account or participating in promotional activities by HopLocal partners or third parties.

Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to HopLocal or otherwise promote our products and services.

Sharing Between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information such as:

• When a booking request is made or dispute is submitted, certain information may be shared between Guest(s) and Host(s), including profile, name, names of any additional Guests, cancellation history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a booking is confirmed, additional information is shared to assist with coordinating the trip, like profile photo and phone number. When you as a Host have a confirmed booking, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Listing address.
• When you as a Host invite another Member to host with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation address, calendar, Listing information, Listing photos, and email address.
• When you as a Guest invite additional Guests to a booking, your full name, travel dates, Host name, Listing details, the Accommodation address, and other related information will be shared with each additional Guest.

Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

• Your public profile page, which includes your profile photo, first name/display name, description, and city.
• Listing pages includes information such as approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings and other public feedback.
• Content in a community or discussion forum, blog or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms and apps.

Information you share publicly on the HopLocal Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

2. WHO CONTROLS MY PERSONAL INFORMATION

2.1 Controller

Where this Subpage mentions “HopLocal,” “we,” “us,” or “our,” it refers to the HopLocal company that is responsible for your information under this Privacy Policy (the “Controller”). 

2.2 Payments Controller

The Privacy Policy also applies to the Payment Services provided to you by HopLocal in association with  Stripe – payment gateway.

When using the Payment Services, you will also be providing your personal information, to HopLocal and Stripe, which will be responsible for your information related to the Payment Services, generally depending on your country of residence.

The Payments Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

2.3 Changing Your Country of Residence

If you change your country of residence, the Controller and/or Payments Controller will be determined by your new country of residence as specified above, from the date on which your country of residence changes. To this end the Controller and/or Payments Controller that originally collected your personal information will need to transfer such personal information to the new applicable Controller and/or Payments Controller. The new Controller and/or Payment Controller will continue to process your personal information as described in the Privacy Policy and Subpage (when applicable).

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:.

• Third-Party Services. If you link, connect, or login to the HopLocal Platform with a third party service (e.g. Google, Facebook and their subsidiaries), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Complying with Law. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against HopLocal, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability. (iv) to enforce and administer our terms and conditions with Members, or (v) to protect the rights, property or personal safety of HopLocal, its employees, its Members, or members of the public. For example, if permitted due to the foregoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies. 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 or harm to HopLocal, our Members, or expose HopLocal to a claim of obstruction of justice.
• Background Information. To the extent permitted by applicable laws and with your consent where required, we 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 may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals and co-travelers. If you are invited to the HopLocal Platform such as a co-traveler on a trip, the person who invited you can 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 information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the HopLocal Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

3. PROCESSING OF PAYMENTS INFORMATION

3.1 Information Necessary For Use of Payment Services

The Payments Controller needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

• Payment Information. When you use the Payment Services, the Payments Controller requires certain financial information (such as your bank account or credit card information.) in order to process payments and comply with applicable law.
• Identity Verification and Other Information. The Payments Controller may require identity verification information (such as images of your government issued ID document(s), passport, national ID card, tax ID or driving license) or other authentication information (such as 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 to comply with applicable law.

3.2 How the Payments Controller Uses Personal Information Collected

We may use the personal information as a part of Payment Services to:

• Enable or authorise third parties to use the Payment Services
• Detect and prevent money laundering, fraud, abuse, security incidents
• Conduct security investigations and risk assessments
• Comply with legal obligations (such as anti-money laundering regulations)
• Enforce the Payment Terms and other payment policies
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences
• Provide and improve the Payment Services

4. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

We process personal information for the purposes described in this privacy policy with the lawful bases set out below. For more information on the processing activities, please refer to the relevant section of the Privacy Policy.

4.1 How We Use Information We Collect 

SUB-SECTION	LEGAL BASES
Provide, improve, and develop HopLocal.	We process this personal information for these purposes given our legitimate interest in improving HopLocal and our users’ experience with it, and where it is necessary for the adequate performance of the contract with you.
Create and maintain a trusted and safer environment.	We process this personal information for these purposes given our legitimate interest in protecting HopLocal and our users, to measure the adequate performance of our contract with you, to comply with applicable laws, for the protection of your or another person’s vital interests, and for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health.
Provide, personalize, measure, and improve our advertising and marketing.	We will process this personal information with your consent or based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.
How the Payments Controller uses the personal information collected	The Payments Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

4.3 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights 

SUB-SECTION

LEGAL BASES

Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

These disclosures may be necessary to comply with our legal obligations, for the protection of a person’s vital interests, for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, for reasons of substantial public interest, or for the purposes of HopLocal’s or a third party’s legitimate interest in keeping HopLocal secure, preventing a breach of the law, harm or crime, enforcing or defending legal rights, claims, or obligations, facilitating the collection of taxes and prevention of tax fraud or preventing loss or damage.

4.4 Other important information 

SUB-SECTION	LEGAL BASES
Analyzing your communications.	These activities are carried out based on HopLocal’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
Linking third party accounts, Third Party Partners & Integrations	We process personal information from linked third party accounts, third party partners, and integrations 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.

5. YOUR RIGHTS

If HopLocal is the Payments Controller, or pursuant to applicable law, you benefit from a number of rights. While some of these rights apply generally, certain rights apply only in certain limited cases. Please note that we may ask you to verify your identity and request before taking further action on your request. 

5.1 Data Access and Portability

You have the right to request certain copies of your personal information held by us. In certain instances, you also have the right 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).

5.2 Rectification

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your HopLocal account).

5.3 Erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us, to comply with our legal obligations, and as permitted by applicable law.

You have the right to ask us to delete your personal information, subject to certain limitations and restrictions. Please note that if you request the erasure of your personal information:

• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention and enhancing safety. For example, if we suspend an HopLocal account for fraud or safety reasons, we may retain information from that HopLocal account to prevent that Member from opening a new HopLocal account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, HopLocal and HopLocal Payments may keep your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on HopLocal, even after your HopLocal account is cancelled. However, attribution of such information to you will be removed.
• Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we maintain HopLocal 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.

5.4 Withdrawing Consent

If we are processing your personal information based on your consent you can withdraw your consent at any time by changing your account settings or by sending a communication to HopLocal 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.

5.5 Restriction of Processing

You have 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 personal information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.6 (below) and pending the verification whether the legitimate grounds of HopLocal override your own.

5.6 Objection to Processing

You have the right to object to the processing of your personal information based on grounds specific to your situation if such processing is for direct marketing or is for a purpose based on a legitimate interest or public interest. If you object to processing based on legitimate or public interests we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or where the processing is otherwise 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 HopLocal to cease processing your data for these direct marketing purposes by sending an e-mail to hello@hoplocal.co.

5.7 Lodging Complaints

You have the right to lodge complaints about our data processing activities by filing a complaint with our Data Protection Officer who can be reached by the “Contact Us” section above or with a local supervisory authority.

6. RETENTION

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

• the length of time we have an ongoing relationship with you and provide HopLocal to you (for example, for as long as you have an account with us or keep using HopLocal);
• whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); and/or
• whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS

To facilitate our global operations HopLocal and HopLocal Payments may transfer, store, and process your information within our family of companies, partners, and service providers based in various countries. Laws in each country may differ from the laws applicable to your country of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in these other countries may be entitled to access your personal information.

Some of these countries are subject to a European Commission adequacy decision. For other countries, measures have been taken pursuant to applicable data protection law, such as standard contractual clauses within HopLocal or with the relevant third party to protect this personal data.

7.1 Other Means to Ensure an Adequate Level of Data Protection

If HopLocal is the Controller and your information is shared with corporate affiliates or third party service providers outside the EEA, we have (prior to sharing your information with such corporate affiliate or third party service provider) established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection, such as a copy of the EU Model Clauses, on request.

7. SECURITY

While no organization can guarantee perfect 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.

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least seven days (07) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the HopLocal Platform will be subject to the revised Privacy Policy.

9. CONTACT INFORMATION 

For questions or complaints about this Privacy Policy or HopLocal’s handling of personal information, please reach out to us at hello@hoplocal.co.