Nativ Proptech Inc., including its subsidiaries and affiliates (collectively, “Nativ“, “we” or “us“), is providing this Privacy Policy (this “Policy“) to inform you of our policies and procedures regarding the collection, use and disclosure of Personal Information we receive in relation to your use of http://www.staynativ.com (the “Site“), our mobile applications (the “Apps“) and other products and services, including the reservation and use of accommodation at a Nativ unit (an “Accommodation“) (collectively with the Site and the Apps, “Services“). This Policy also informs you of your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms of Service: https://www.staynativ.com/terms-of-service.

For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual.

1. What Personal Information Do We Collect About You?

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it to provide our Services. We may collect Personal Information about you directly from you and from third parties, as well as automatically through your use of our Services.

Information We Collect Directly from You.

Registration. When you create an account on our Site or Apps (a “Nativ Account“) or otherwise book an Accommodation with us, we may ask you for certain Personal Information including your name, phone number, email address, home postal address, password, date of birth, and/or booking information. We may also ask you to submit a completed travel document where required by local regulations.

ID Verification (“IDV”) and Check-in. We may require our guests to provide a government-issued ID to ensure their safety and prevent fraud. To help provide a seamless check-in experience, we may use a service provider such as Persona or Chekin (our “IDV Partners“) to capture a photo of your ID and compare it to a scan of your face to securely verify your identity. Nativ does not receive your face scan and our service providers delete the scan according to the periods described in Biometric Data Privacy Policy.

Third Party Services. We may make available to you at your election the services of third-party service providers, such as luggage storage, parking reservations, or activity concierge services. When you access these providers via the Services, you may be asked to provide certain Personal Information, such as your name, address, phone number, email address, credit card number or other payment information, drivers license number, and/or license plate number, which will be used by these service providers in the provision of their services. The treatment of the Personal Information you provide to any of these providers is governed by that provider’s own Privacy Policy and Nativ is not responsible for their handling of your information; you should review them prior to providing your Personal Information.

Payment Information. If you make a purchase through the Services, your payment information, such as credit card number or billing information, is collected by our third party payment processor on our behalf.

Administration and personalization of your Nativ Account profile. We may collect any Personal Information you provide to us as part of the administration and personalization of your Nativ Account profile (e.g., zip code, and individual preferences or demographic information). You may voluntarily provide us with information about yourself so that we can personalize your stays with us (e.g., whether or not you need a crib, etc.).

Communications. If you contact us directly (e.g., via email, SMS, phone call, in-App messaging), we will collect your name, contact details, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. You may choose to submit your email address and phone number on our Site or Apps to receive our updates. You may also provide us with your reviews of our Services or complete surveys regarding our Services.

Recruitment. If you apply for a job via the “Careers” page on the Site, we will collect your name, contact details, email, phone number and information in your resume or curriculum vitae. We may also ask you to provide a link to your publicly-available professionally-related social media accounts, such as LinkedIn, Twitter, GitHub or portfolio URLs or links to other websites, your current workplace, and any other information you want to share with us.

COVID-19. The wellbeing of our guests and team members is our top priority. During the ongoing COVID-19 pandemic, if you are a guest in one of our Accommodations, we may request certain Personal Information from you related to possible risk of COVID-19 exposure or infection. This information may include (but may not be limited to) whether you have been in recent contact with someone known to have or who is experiencing symptoms of COVID-19; whether you have recently traveled internationally; if you are currently quarantining due to a possible COVID-19 exposure and/or are awaiting a COVID-19 test result; and whether you are currently experiencing COVID-19 symptoms (consistent with Centers for Disease Control and Prevention (CDC) guidance).

Information We Collect from Your Interactions with Us.

Customer service. If you reach out to us with inquiries or requests, we will keep a record of how your inquiry or request was handled. If you contact us via phone, we may record your call for quality assurance, training, and compliance purposes.

Information We Collect Automatically.

Online usage data. We may automatically collect the following information about your use of our Services through cookies, web beacons, and similar technologies: your domain name; your browser type; operating system type, name, and version; page views; links you click; your IP address; location information; the length of time you visit or use our Services; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the Services and communications that we send you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information. Where required under applicable law, we will perform such data collection only with your consent.

Property usage data. We automatically collect your Nativ stay history (e.g., to identify you as a return guest). We may also automatically collect information regarding the use of an Accommodation (e.g., when a door was unlocked). We also deploy certain types of sensors in our Accommodations, such as noise detection systems (which register only decibel levels, not conversations) and smoking detection devices, to help us provide a great experience for all our guests and to enforce our House Rules. We may also use or have access to security cameras in certain common areas of buildings housing our Accommodations (e.g., in lobbies or monitoring public entrances). Where required under applicable law, we will collect property usage data only with your consent.

Wi-Fi usage data. Nativ manages the guest W-Fi network on some of its properties. If you connect to a Nativ-managed guest Wi-Fi network offered on our premises, we temporarily log certain information about your connection necessary to provide and secure our Wi-Fi network, such as the IP address and MAC address of the device used to connect to our network, as well as the IP address of the destination to which the device is connecting. We do not access the content of your electronic communications when using our guest Wi-Fi network.

Information We Collect from Third Parties.

Other Members. We may obtain Personal Information about you from another Nativ Account holder who adds you to their reservation. If you are not a Nativ Account holder you will be invited to create a Nativ Account. If you are already a Nativ Account holder and accept the invitation to be added to the reservation, that reservation will be linked to your Nativ Account.

Third party accounts. If you choose to log in to your Nativ Account using a third party log-in (such as “log in with Google”), we may obtain Personal Information about you from such third party’s authentication and social networking services (“SNS“) to link your Nativ Account with your third party account (“Third Party Account“) by us either: (i) receiving your Third Party Account login information through the Service; or (ii) being allowed access to your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. We may receive from such third parties the following types of Personal Information:

Apple: email, first name, last name.
Facebook: ID, cover photo, email, first name, last name, age range, link, gender, location, picture, timezone, date of last update, user verification.
Google: Google ID, name, profile URL, email address.
LinkedIn: basic profile, email address.

We may also receive any other information you authorize Nativ to access by authorizing the SNS to provide such information.

Third party partners and travel services. We may receive Personal Information when you book an Accommodation through indirect channels (e.g., online travel agencies such as Airbnb, Booking.com, and Expedia, corporate travel partners, or group sales accounts). The Personal Information we receive from these third party partners and travel services may include your name, email address, phone number, other information available in your user account with a third party travel service and your Nativ stay information (e.g., information on the Nativ unit you are staying in).

Background checks. If you book an Accommodation in the United States, we may engage with a vendor to conduct a background check for use in our trust and safety, fraud prevention and risk assessment efforts, and/or to comply with landlord requirements. We may receive your name, date of birth, address, and the results of the background check. Our vendor will use U.S. county, state, and federal criminal databases and reports from U.S. credit agencies to run the checks.

IDV Partners. We may also receive Personal Information from our IDV Partners regarding your identity for use in our trust and safety, fraud prevention and risk assessment efforts, including your photo and images of any government identification documents you provide to those IDV Partners; however, we never receive any biometric data from those IDV Partners. Please refer to the section labeled “Information we Receive from You – ID Verification and Check-in” above and our Biometric Data Privacy Notice for more information.

Vendor and partner relationships. We receive Personal Information of employees and other individuals who are contact persons at our partners and vendors, such as contact details and other information relevant to the particular business relationship.

2. How We Use Your Personal Information

We use your Personal Information for the following purposes:

To operate, provide, and maintain our Services, to communicate with you about our Services, to respond to your inquiries, to fulfill our contract with you, to complete your transactions, and for other customer service purposes.
We may run a criminal background check on behalf of landlords or property managers who require it for Accommodations in the United States, to the extent permitted under applicable law.
To link your Nativ Account with Third Party Accounts to add information from Third Party Accounts to your Nativ Account. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available, and store (if applicable and as permitted by the SNS and authorized by you) the information in your Third Party Accounts so that it is available on and through your Nativ Account on the Services.
To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Services, including personalizing your Nativ Account and identifying you as a return guest to provide products or services to you according to your preferences or restrictions. We may also tailor our Services and communications on the basis of your Site browsing history. Where required under applicable law, we will use your Personal Information for such purposes only with your consent.
To contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you relating to Nativ or its partners, via email, SMS, and phone calls. Where required under applicable law, we will send you marketing communications only with your consent. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
For quality assurance purposes.
To solicit a review or other feedback from you.
To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve the quality and value of our Services, provide you and others with a better experience, and develop new Services, and for other research and analytical purposes.
To find and prevent fraud and respond to trust and safety issues that may arise.
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
For other purposes for which we provide specific notice at the time the information is collected.
During the ongoing COVID-19 pandemic, we may use the Personal Information described in the section labeled “Information We Collect Directly from You – COVID-19″, above, to help maintain a safe environment for our guests, team members and partners who may be required to access our Accommodations to provide services. Personal Information you share with us related to COVID-19 may be used by us to determine whether to permit our team members or partners to service the Accommodation during your stay as a guest and will not be used or shared for any purposes unrelated to COVID-19.

3. When We Use Personal Information About You

If you are located in the European Economic Area (“EEA“), we process your Personal Information only based on a valid legal ground, including when:

Consent. You have consented to the use of your Personal Information, for example for marketing purposes or to track your online activities via cookies and similar technologies.
Contract. We need your Personal Information to provide you with our Services, for example for Nativ Account registration and management, to manage your booking or stay at an Accomodation, or to respond to your inquiries.
Legal obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations, or anti-terrorism laws.
Legitimate interest. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

4. How We Share Your Personal Information

We may employ third party companies and individuals to support our Services. We do not sell or otherwise disclose your Personal Information for purposes unrelated to our Services, unless otherwise described in this Policy or disclosed to you at the time your Personal Information is collected or shared. We may share your Personal Information under the following circumstances:

Affiliates. We may disclose the information we collect about you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Policy.
Service providers. We may disclose Personal Information we collect about you to third party vendors, service providers, contractors, or agents who perform functions on our behalf, including to facilitate our Services, to provide the Services on our behalf, to perform Site-related services (e.g., maintenance services, database management, web analytics, fraud detection services relating to the activity of Nativ Users (as defined below), and improvement of the Site’s or Apps’ features), to perform background checks, to send marketing communications, to manage job applications that we receive via the “Careers” page on our Site, to solicit and aggregate reviews, or to assist us in analyzing how our Site, Apps, and Services are used. We require these service providers to safeguard the privacy of Personal Information they process on our behalf.
Third party travel services, referral services, and brokers. When you book an Accommodation via indirect channels or we receive your Personal Information through a referral service or broker, we may share your Personal Information with such channel, service or broker in order to manage your booking or provide credit for referrals.
Landlords and property managers. We may share reports with landlords and property managers regarding the use of their properties, such as cleaning and occupancy reports. Additionally, we may share guest names, email addresses, dates of stay at their properties, and other necessary information for safety or security purposes (e.g., to keep out individuals who are not guests or respond to emergencies), or as necessary for legal compliance purposes or cooperation with law enforcement, as further detailed below. For extended stay reservations, we may share guest names, email addresses, phone numbers, IDs, dates of birth, and addresses with landlords. If permitted by applicable law, we may also share pass/fail results of background checks that we carry out on guests based in the United States.
Advertising and analytics partners. We may share Personal Information about you with third party advertising partners to serve advertisements regarding goods and services that may be of interest to you. We may also share information about the use of our Services with third parties for analytics and optimization purposes. Some of our advertising partners are members of the Network Advertising Initiative (“NAI“) or the Digital Advertising Alliance (“DAA“). If you do not wish to receive personalized ads, please use the NAI’s Opt-Out Tool or the DAA’s Opt-Out Tool to opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
Business transfers. Nativ may sell, transfer, or otherwise share some or all of its assets, including your Personal Information, in connection with the consideration, negotiation, or completion of a merger, acquisition, reorganization, or sale of assets or in the event of bankruptcy.
Compliance with laws and law enforcement. Nativ cooperates with government and law enforcement officials (e.g., immigration offices, customs authorities, anti-terrorism authorities) and private parties to enforce and comply with the law. We will disclose your Personal Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Nativ or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable. We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or appropriate to protect the property and rights of Nativ or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable.
Consent. We may also disclose your Personal Information with your permission. For example, with your consent, we may post your testimonial on the Site along with your name. If you would like your testimonial removed, please contact us.

5. Cookies and Other Tracking Mechanisms

We use cookies, web beacons, and log files to collect information about your use of our Website and Apps, as described above.

Cookies. We use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s storage. We use cookies for two purposes. First, we use persistent cookies to save your login information for future logins to the Services. Second, we use session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by Nativ Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. We use the following cookies:
Google. We use Google Analytics cookies and Google Tag Manager to analyze our Services. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout. We also use Google cookies to serve ads based on a Nativ User’s prior visits to Nativ. You can learn more about these cookies here and disable these cookies via Google’s Ads Settings or Ad Settings for mobile apps.
Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
Segment.io cookies. We use Segment.io cookies to analyze our Services, support your use of the Services and track your activity on our Website and Apps. More on Segment.io can be found at https://segment.com/docs/legal/privacy/.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Service.

Web beacons. Our Site may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Log data. When you visit the Site, whether as a Nativ Account holder or a non-registered user just browsing (any of these, a “Nativ User“), our servers automatically record information that your browser sends whenever you visit a website (“Log Data“). This Log Data may include information such as your computer’s Internet Protocol (“IP“) address, browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site functionality and user-friendliness, and to better tailor our Site to our visitors’ needs.
Error reporting. We may use Bugsnag’s bug tracking JavaScript notifier or other technology to analyze the functioning of our Services. More on Bugsnag can be found at https://docs.bugsnag.com/legal/privacy-policy/.

6. Children’s Privacy

The Site is not directed to individuals under 16. We do not knowingly collect Personal Information from children under 16. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us via the information provided in the “How to Contact Us” section, below. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.

7. Links to Other Websites

Our Site contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. Some portions of the Nativ Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use, which incorporates Google’s Privacy Policy.

8. Data Security

Nativ is very concerned with safeguarding your Personal Information. When you enter particularly sensitive information (such as a credit card number) on our registration or reservation forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site and Services, you can contact us. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

9. Phishing

Identity theft and the practice currently known as “phishing” are of great concern to Nativ. Safeguarding Personal Information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your Nativ Account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.

10. Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

11. Your Rights and Choices

Marketing opt-out. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. Please note that even if you opt out of receiving promotional messages from us, you will continue to receive administrative or transactional messages from us.
Changing or deleting information. All Nativ Account holders may review, update, correct or delete the Personal Information in their Nativ Account by contacting us at hello@staynativ.com or editing the relevant part of their profile. If you would like us to cancel your Nativ Account, please contact us and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your Nativ Account. Please note that, if you cancel your Nativ Account, any reviews you have posted via the Site will remain publicly viewable via the Site.
Opt out from cookies. Most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our website may not work for you.
European privacy rights. If you are located in the EEA, the United Kingdom (“UK“) or Switzerland, you are entitled to reach out to us via the contact details in this Policy and ask us for an overview of your Personal Information or ask for a copy. In addition, you may request us to update and correct inaccuracies, delete your Personal Information, restrict processing of your Personal Information, or exercise your right to data portability and to easily transfer your Personal Information to another company. In some cases, you may object to the processing of your Personal Information and where we have asked you for your consent to process your Personal Information, you can withdraw it at any time. These rights may be limited in some circumstances by local law requirements. We always enjoy hearing from you and appreciate your business. Should you nonetheless have unresolved concerns, you have the right to lodge a complaint with the supervisory authority of your residence, place of work or where the incident took place. If you are located in the UK, you have the right to lodge a complaint with the UK Information Commissioner’s Office.
California privacy rights. If you are a California resident, please review for more information regarding your California privacy rights.

12. Cross-Border Data Transfers

We operate our Services in multiple countries. The Personal Information we collect is transferred to our affiliates, subsidiaries, service providers and agents, who may be located in the United States or in other jurisdictions worldwide. The United States and the other jurisdictions to which we transfer information may not have equivalent data protection laws as your home jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

If you are located in the EEA, UK or Switzerland, we comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA, UK or Switzerland. We may transfer your Personal Information to countries for which adequacy decisions have been issued (e.g., Canada), use contractual protections for the transfer of Personal Information, or rely on third parties’ Privacy Shield certifications, where applicable. You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA, UK or Switzerland.

13. Changes to this Policy

Because we’re always developing and improving standards of services we provide to you, this Policy may change over time. We will post the new Policy online and we will change the “Last Updated” date. We encourage you to periodically review this page for the latest information on our privacy practices. If any modifications materially change your rights, we will provide notice on the Site or we will notify you by email (sent to the email address specified in your Nativ Account).

14. How to Contact Us

For privacy queries, please contact us at hello@staynativ.com.

15. Steward of Your Personal Information

The Nativ entity responsible for your Personal Information under this Privacy Policy is defined as the “Steward.” The Steward of your Personal Information is based on the location of travel. Generally, if your stay is located in the United States or Mexico, the Steward of your Personal Information is Nativ Proptech, Inc. Note that we reserve the right to replace the Steward of your Personal Information at any time and without notice.