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Privacy Policy

Last updated on Feb 10, 2022

Popless 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 protecting your human right to privacy.

This Privacy Policy describes how Popless, Inc. and its affiliates (“we,” “us,” or “Popless”), process personal information in relation to your use of the Popless Platform. Depending on where you live and what you are doing on the Popless Platform, the supplemental privacy pages listed below may apply to you. Please follow the links and review the supplemental information describing how we process personal information for those regions and services.

Outside of the United States. If you reside outside of the United States, such as in the European Economic Area (“EEA”) visit our “Outside of the United States” page to learn about (i) the controller(s) of your personal information, (ii) legal bases, including legitimate interests, for collecting and processing your personal information, (iii) safeguards relied upon for transferring personal information outside the EEA, (iv) your rights, and (v) contact details of the controller(s) and Data Protection Officer.
California and Vermont. If you reside in California or Vermont, visit our “California and Vermont” page to learn about specific privacy information that applies to you.

We’ve provided short summaries in this Privacy Policy to help you understand what information we collect, how we use it, and what choices or rights you may have. While these summaries help explain some of the concepts in a simple and clear way, we encourage you to read the entire Privacy Policy to understand our data practices.

This Privacy Policy also describes the choices available to you for the use of, your access to, and how to update and correct your personal information. Please note that certain features or services referenced in this Privacy Policy may not be offered on the Popless Platform at all times. Please also review our Terms of Service, which governs your use of the Popless Platform.

1. Definitions

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

2. Personal information we collect

We collect personal information about you when you use the Popless Platform. Without it, we may not be able to provide all services requested. Such information may include your name and contact information, financial information to make or receive payment for services obtained through the Popless Platform, or information to help us fill out tax forms. When you use the Popless Platform, we may also collect information related to your use of the Popless Platform and aggregate this with information about other users. This helps us improve the Popless Platform for you. You may also provide us with information about your contacts or friends if, for example, you’d like to add those contacts to a massage room.

2.1 Information needed to use the Popless Platform

Information needed to use the Popless Platform you may provide include:

Personal 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.
Payment Information: If you use the Popless Platform to make or receive payments, we will also collect certain payment information, such as credit card, PayPal, or other financial account information, and billing address. If you are not a Popless user, we may receive payment information relating to you, such as when a Popless user provides your payment card to complete a booking. If a copy of your ID is provided to us, we may scan, use, and store information contained in your ID to verify your identity.
Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer-identification number, as may be required by law, such as to complete tax filings. We may request documents to verify this 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.

2.2 Information you choose to give us

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.
Information About Others. Such as a payment instrument belonging to another person. By providing us with personal information about others, you certify that you have permission to provide that information to Popless for the purposes described in this Privacy Policy, have shared the Popless Privacy Policy with them, and they have read and understood that it applies to them.
Address Book Contact Information. Address book contacts you import or enter manually.
Biometric Identifiers or Service Interaction Information: We may collect Personal Information to verify your identity and to detect fraud, identity theft, or other misuses of your account through facial recognition and other technologies. This might be a photograph of your face, a selfie, or data about your interactions with the Popless Platform. We may request documents to verify this information, such as a copy of your government-issued ID. From time to time, Popless may require you to take and submit another or updated image of your face for comparison to your government-issued ID. The biometric identifiers, or information collected, are used only to verify your identity and platform security and use integrity purposes.
Non-Identifying Information/Usernames: We also may collect other information, such as zip codes, demographic data, information regarding your use of the Service, and general project-related data (“Non-Identifying Information”). We may aggregate information collected from Popless registered and non-registered users (“Popless Users”). We consider usernames to be Non-Identifying Information. Usernames are made public through the Service and are viewable by other Popless Users. In some cases, we may render Personal Information (generally, email address) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.
Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but Popless will treat the combined information as Personal Information.
Collection of the Third Party Personal Information: We collect the following personal information from you about your contacts or friends: First name, last name, and email address when you provide it to us for the purpose of adding your contacts to a massage room.
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.

You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we may not be able to provide the Popless Platform to you. If you have any questions regarding whether the provision of information is mandatory and the consequences for withholding such information, please contact us at hello@popless.com.

2.3 Information Automatically Collected by Using the Popless Platform and our Payment Services.

When you use the Popless 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 Popless Platform.
Log Data and Device Information. Such as details about how you’ve used the Popless 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 Popless Platform. We may collect this information even if you haven’t created a Popless account or logged in.
Cookies: Popless uses cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, and gather demographic information about our user base as a whole. Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the Popless Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how Popless Users interact with the Service and to monitor aggregate usage by Popless Users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service. For further information on cookies and how they are used for the Service, please visit 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.
Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how Popless Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.
Device and IP Identifiers: The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifiers (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access the Service.

2.4 Information We Collect from Third Parties.

We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, and site functionality.

If we combine third-party information with information about you collected through the Service, we will still treat that combined information as set forth in this Privacy Policy. For example, we may supplement the information we collect with outside records or third parties may provide information in connection with a co-marketing agreement or at your request (such as if you choose to sign in with a third-party service). If we combine the information we receive from others with information we collect through the Service, we will treat the combined information as described in this Privacy Policy. Personal Information we collect from third parties may include:

Third-Party Services. If you link, connect, or login to the Popless Platform with a third party service (e.g. Google, Facebook, WeChat), 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, for example, reports of criminal records, sex offender registrations, and other information about you and/or your background. For Members outside of the United States, 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. If you are invited to the Popless Platform, 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 Popless 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.

2.5 User Profiles

You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, your experience, skills, tests taken, test scores, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your Profile may be visible to all Popless Users and the general public subject to the privacy choices you make within your Popless Profile. You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. Clients and Agencies of associated individual users or companies may also have the opportunity to create an organization Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at hello@popless.com.

2.6 Messaging

You may communicate with other people on the Popless Platform. For example, Guests and Hosts may wish to discuss Guest needs and the Host’s profile. If you communicate with a Host or Guest, that Host or Guest will also be a “data controller” with respect to such communications.

2.7 Community Forums

We may offer public forums or blogs. If you participate, your comments and questions will be publicly displayed. Popless may provide you the opportunity to participate and post content publicly in forums, on blogs, through interactive features Popless, and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, or other content (collectively, “User Forum Content”). Please note that certain information, such as your name and Profile may be publicly displayed on the Service along with your User Forum Content. Please note that your use of Community Forums is subject to the Popless Forum Rules and our Terms of Service. Note that anything you post to a Community Forum is public — others will have access to your User Forum Content and may use it or share it with third parties.

If you choose to voluntarily disclose Personal Information in your User Forum Content or use Community Forums to link to your Profile, that information will be considered public information and the protections of this Privacy Policy will not apply. To request removal of your personal information from our blog or community forum, contact us at hello@popless.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

2.8 Testimonials

We display personal testimonials of satisfied customers on the Popless Platform, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at hello@popless.com.

2.9 Work Listings Through the Service

If you choose to post a Request as a Guest, the contents of such listing will be viewable publicly, unless you designate the listing as only viewable through the Popless Platform or as private using the settings available on the applicable website. Requests may include information such as budget, location, history of request(s) by the Guest, the names of other Hosts engaging with the Guest, and Guest feedback and rating information.

2.10 Feedback

We collect feedback from Guests about their experience with Hosts. Please note that any feedback you provide on the Popless Platform or feedback provided about you is publicly viewable. On very rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Service.

2.11 Email to Friends and Referral Program

Popless lets you share Listings with friends via email. Popless also offers the ability to send friends emails about providing or purchasing Sessions on the Popless Platform. If you choose to use either feature, your friend’s email address will be used to send the requested posting and your email address will be used to copy you on the message to your friend or to send the message on your behalf. Popless stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us at hello@popless.com to request that we remove this information from our database.

2.12 Social Networking Services

You may register to join the Popless directly via the Service (e.g., using email) or by logging into your account with a third party social networking service (“SNS”) via the Popless Platform (e.g., Facebook, Github, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link your Popless account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS independent of our Service, and Popless is not responsible for it.

The Popless Service also may permit additional interactions between it and a third party website, service, or other content provider, such as enabling you to “like” or share content to a third party SNS. If you choose to “like” or share content, or to otherwise share information from or via our Service with a third-party site or service, that information may be publicly displayed, and the third party may have access to information about you and your use of our Service (and we may have access to information about you from that third party). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with third parties through an SNS or similar features are governed by the respective privacy policies of those third parties.

You can disable the link between your Popless account and your SNS account at any time though the “Settings” section of our Service. Please note that your relationship with any SNS is governed solely by your agreement(s) with such SNS. If your SNS account terminates, then functions enabled through the link between your Popless account and your SNS account will terminate as well.

2.13 How we Respond to Do Not Track Signals

Popless does not respond to Do-Not-Track signals. Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Popless does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

2.14 The General Data Protection Regulation: Data Processing Agreement

To streamline compliance with the General Data Protection Regulation (“GDPR”), Popless has posted a Data Processing Agreement (“DPA”) governing the relationship between the Customer (as defined in the DPA) acting as a data controller or processor, as applicable (and as defined in the DPA), of personal data under European Data Protection Legislation; and Popess (acting as a data processor or subprocessor, as applicable).

Unless otherwise agreed to in writing by you and Popless, to the extent Popless processes any EU personal data for you as a controller (as defined by the General Data Protection Regulation (EU) 2016/679) in your role as a Customer, the Data Processing Agreement applies.

3. How we use information we collect

3.1 Provide, Improve, and Develop the Popless Platform. Such as to:

enable you to access the Popless Platform and make and receive payments,
enable you to communicate with other Members,
process your request,
perform analytics, debug and conduct research,
provide customer service, training,
send you messages, updates, security alerts, and account notifications,
if you provide us with your contacts’ information, such as your friends, we may process this information: (i) to facilitate your referral invitations, (ii) to share Session details and facilitate Session planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
personalize and customize your experience based on your interactions with the Popless Platform, your search and booking history, your profile information and preferences, and other content you submit, and
enable your use of our enterprise products.

3.2 Create and Maintain a Trusted and Safer Environment.

Including to:

detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
study and combat discrimination consistent with our Nondiscrimination Policy,
conduct security investigations and risk assessments,
verify or authenticate information provided by you,
conduct checks against databases and other information sources, including background or police checks,
comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees, and members of the public,
resolve disputes with our Members, including sharing information with your co-Host or additional Guests about disputes related to your role as a co-Host or additional Guest,
enforce our agreements with third parties,
comply with the law, respond to legal requests, prevent harm, and protect our rights (see section 4.5),
enforce our Terms and other policies (e.g. Nondiscrimination Policy), and
in connection with the activities above, we may conduct profiling based on your interactions with the Popless Platform, your profile information and other content you submit to Popless, and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Popless Platform as well as information in relation to activities on and off the Popless Platform that can be associated with you, could restrict or suspend access to the Popless Platform if such processes detect activity that may pose a safety or other risk to Popless, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section below.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

For example to:

send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
personalize, measure, and improve our advertising,
administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Popless or its third-party partners,
analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
invite you to events and relevant opportunities.

3.4 Provide Payment services.

Personal information is used to enable, or authorize third parties to use, Payment Services such as to:

detect and prevent money laundering, fraud, abuse, and 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, and
provide and improve Payment Services.

3.5 Comply with the law

We use Information We Collect

To provide and improve the Service, complete your transactions, and address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.
To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.
To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of Popless 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, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Popless Users.
For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

3.6 For Our Legitimate Interests

In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

Providing our Site and Service.
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
Measuring interest and engagement in our Services.
Improving, upgrading, or enhancing our Services.
Developing new products and services.
Ensuring internal quality control and safety.
Authenticating and verifying individual identities.
Debugging to identify and repair errors with our Services.
Auditing relating to interactions, transactions, and other compliance activities.
Enforcing our agreements and policies.
Analyzing and improving our business.
Communications, including marketing and responding to your inquiries about our services.
Addressing information security needs and protecting our Users, Popless, and others.
Managing legal issues.

4. Sharing and disclosure

4.1 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 Popless account or participating in promotional activities by Popless partners or third parties.

Where permissible under 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 Popless, or otherwise promote our products and services.

4.2 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, when there is a co-host, or a 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 any additional Guests they invite, if applicable) to coordinate the booking, such as your profile, full name, phone number, and Conference details.
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, Conference details, calendar, Listing information, Listing photos, and email address.
When you as a Guest invite additional Guests to a booking, your name, Session dates, Host name, Listing details, Conference details, and other related information will be shared with each additional Guest.

4.3 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 (or initials where applicable), description, and city.
Listing pages that include information such as the Host 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 Popless Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

4.4 Host Service Providers.

Hosts may use third-party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Popless Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third-party service providers.

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

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 to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order) or to respond to claims asserted against Popless, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activty, 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) enforce and administer our agreements with Members, including our Terms, Additional Legal Terms, and Policies, or (v) protect the rights, property or personal safety of Popless, 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 Popless, our Members, or expose Popless to a claim of obstruction of justice.

Where legally required or permissible according to applicable law, we may disclose Hosts’ and/or Guests’ information to tax authorities for the purpose of the tax authorities’ determination of proper compliance with relevant tax obligations. Relevant tax obligations include Popless’s tax obligations on its service fees, its facilitation of taxes on withholding taxes, and Hosts’ individual tax obligations. Information that may be disclosed includes, but is not limited to, Host and Guest names, listing addresses, Host addresses, tax/business identification number(s), date of birth, and/or contact information, property parcel identification numbers, payout information, transaction dates and amounts, number of nights and Guests booked, gross and net booking value and payout amounts, taxes collected by Popless on behalf of Guests and Hosts, to the extent any of this information is known by Popless.

In jurisdictions where Popless facilitates or requires a registration, notification, permit, or license application or number of a Host with a governmental authority, we may share information of participating Hosts with the relevant authority, both during the application process, when the Listing is published, and periodically thereafter, such as the Host’s full name and contact details, Conference details, tax identification number, registration, permit, or license number, Listing details, reservation information, and number of Sessions booked subject to applicable laws.

4.6 Programs with Managers and Owners.

We may share personal information of Hosts and Guests with landlords, management companies, and/or property owners (“Building Management”), such as booking information and information related to compliance with applicable laws, in order to facilitate programs with Building Management. For example, guest booking and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located to facilitate hosting services, compliance with applicable laws, security, billing, and other services.

4.7 Host Information Provided to Popless for Work Customers.

If a booking is designated as being for a business or work purpose and (1) is made by a Guest affiliated with an Enterprise and (2) the Enterprise is enrolled in Popless for Work, we may disclose information related to the booking to the Enterprise (e.g., name of the Host, Conference details, booking dates, Listing details, etc.) to the extent necessary for the adequate performance of Popless’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.

4.8 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business and for their compliance purposes, including service providers that 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 Popless 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 similar claims. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.9 Business Transfers.

If Popless 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 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.

4.10 Internal and Business Transfers

Popless may share information, including Personal Information, with its parent company Pop Hosting Inc., and any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

4.11 Sweepstakes, Contests, and Promotions

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.

4.12 Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of Popless’ features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.

4.13 Receiving Information from Third Parties or Request We Share Your Information

You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third-party application, that we share information about you with a third party and we will typically do so under those circumstances.

5. Other important information

5.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Popless Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, 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 sites. 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. Occasionally we may need to manually review 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 messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

5.2 Linking Third-Party Accounts.

You can link your Popless account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

some of the information provided to us from linking accounts may be published on your public profile,
your activities on the Popless Platform may be displayed to your Friends on the Popless Platform and/or that third-party service,
a link to your public profile on that third-party service may be included in your Popless public profile,
other Popless users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
other Popless users may be able to see any schools, hometowns, or other groups you have in common with them as listed on your linked social networking service,
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
publication and display of information that you provide to the Popless Platform through this linkage is subject to your settings and authorizations on the Popless Platform and the third-party service.

5.3 Third-Party Partners & Integrations.

Parts of Popless may link to third-party services, not owned or controlled by Popless, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information), and Citi Privacy Policy. Popless does not own or control these third parties and when you interact with them you are providing your information to them.

6. Your rights

You can exercise any of the rights described in this section consistent with applicable law. See here for information on data subject rights requests and how to submit a request. We may ask you to verify your identity and request before taking further action on your request. Learn more about rights under GDPR here.

6.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Popless Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

6.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

6.3 Data Erasure.

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

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 a Popless Account for fraud or safety reasons, we may retain information from that Popless Account to prevent that Member from opening a new Popless Account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Popless may keep 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 Popless, even after your Popless Account is canceled. 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 take measures to protect data 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.

6.4 Data Subject Rights

All Users may request access to, or correction of, any Personal Information we have about them or to delete their account and/or request deletion of all Personal Information we have about them. In certain jurisdictions, Users may have certain rights with regard to their Personal Information. We will honor User requests to the extent we can reasonably do so and as required by law. Upon request, Popless will provide you with information about whether we hold any of your personal information.

You may access, correct, or request deletion Popless of your personal information by making updates to that information or by contacting Popless via hello@popless.com. If you request to access all personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by applicable law.

In accordance with applicable law, you may have the right to delete all personal information, which will then deactivate your account. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so by emailing hello@popless.com with a request to do so.

Depending on where you are located, you may have certain rights with regard to your Personal Information (including, in certain cases, under the Privacy Shield, described below). You may also request the restriction of, or object to our processing of, your personal information when processing is noncompliant, and withdraw your consent to our processing of your personal information. If you refrain from providing personal information, or withdraw your consent to processing, some features of our Service may not be available.

If you request to access the personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by applicable law. If you are located in the European Economic Area (“EEA”), in addition to the rights described above, you may contact us at the contact information provided below to (1) request a restriction on the processing of your Personal Information, (2) object to the processing of your Personal Information, or (3) exercise other rights with respect to your Personal Information.

6.5 Host Success Score

Popless uses automated means to calculate the Host Success Score. If you believe that our services have miscalculated your Host Success Score or you would like to exercise any other rights with regard to your Personal Information, please email us at hello@popless.com for assistance. We may be able to assist you by conducting a manual review of your Job Success Score, such as by assessing whether the information you’ve provided us is accurate. While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have a right to lodge a complaint with the relevant supervisory authority.

6.6 Persistent Information

We will use commercially reasonable efforts to honor your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including information in your Calendar and messages you posted to the Service. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Popless can delete all copies of information that has been previously shared with others on the Service.

7. Your choices and rights

According to applicable law, you may have certain choices and rights associated with your personal information and regarding how we may communicate with you.

7.1 Communication Preferences

Registered Popless Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications. You may opt-out of receiving text messages by replying “STOP” to any text message received. Registered Popless Users who access the Service by using a Popless mobile application may, with permission, receive push notifications. Similarly, registered Popless Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser.

8. Data retention

Popless retains account and purchases data as long as it is necessary to facilitate a User’s access and use of the Services. When an account is terminated, Personal Information collected will be deleted in accordance with the requirements of applicable law. Personal Information obtained from Site visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises its right to opt-out of requested communications or information-based services. Anonymized and Pseudo-anonymized data will be retained as long as Popless determines such data is commercially necessary for legitimate business interests. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.

9. Third-party analytics and ads

We may work with advertising agencies and vendors who use technology to help us understand how people use our Site. These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt-out of receiving interest-based advertising.

Popless works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons ), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us. If you wish to opt out of interest-based advertising, click here (or if located in the European Union, click here). If you choose to opt-out, please note you will continue to receive generic ads.

While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program.

Popless uses Google Analytics as a web analytics tool to track user behavior on the Site. Google Analytics collects anonymized information in accordance with their Privacy Policy. However, if you do not want Google Analytics to track your use, you may opt-out by installing Google Analytics Opt-out Browser Add-on.

10. 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.

We take a number of steps to protect your data, but no security is guaranteed.

Popless takes commercially reasonable steps to help protect and secure the information it collects and stores about Popless users. All access to the Popless Platform is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection for our Popless users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, Popless cannot ensure and does not warrant the security of any information you transmit to us.

11. International transfer of personal information

Because we are a U.S. company, we process and store your information in the United States and our service providers may process and store it elsewhere.

Popless is a U.S. company. If you are located outside the United States and choose to provide information to us, Popless transfers Personal Information to the United States for processing, and our service providers may process Personal Information in the United States and elsewhere. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the United States, we will protect it as described in this Privacy Policy.

When we transfer Personal Information from territories in the EEA or with similar laws to our affiliates or service providers in the United States and elsewhere outside the EEA, we rely on approved data transfer mechanisms, which may include standard contractual clauses approved by the European Commission and the Privacy Shield, as described below. You may request a copy of the standard contractual clauses relevant to your Personal Information, if any, using the contact information below.

12. Links to other sites

The Popless Platform 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. We encourage you to read the privacy policies or statements of the other websites you visit.

13. Phishing

Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Popless. For more information about phishing, visit the website of the Federal Trade Commission at http://www.consumer.ftc.gov/articles/0003-phishing. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Popless, please report it to hello@popless.com.

14. General Audience Service

Only persons age 18 or older are authorized to create an account. We do not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her child: 1) under the age of 16 in applicable EU Member Countries, or 2) under the age of 13 in the U.S. and applicable EU Member Countries, has provided us with Personal Data without their consent, he or she should contact hello@popless.com. We will delete such Personal Information from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s country of residence.

15. Notice for California residents

Popless does not share personal information with third parties for their own marketing purposes. Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. Alternatively, the law provides that a company may comply, as Popless does, by disclosing in its privacy policy that it provides consumers choice (opt-in or opt-out) regarding sharing Personal Information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Policy, Popless provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time Popless offers that choice, Popless does not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us using the contact information below. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your email address. We are not responsible for notices that are not labeled, sent properly, or do not have complete information.

You can find the Popless Privacy Policy supplement for residents of California and Vermont here.

16. Changes to this 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 thirty (30) 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 Popless Platform will be subject to the revised Privacy Policy. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information unless you consent to the new or revised policy. Express consent to the collection of information and use practices will be obtained when required by applicable law.

17. Contact

For questions or complaints about this Privacy Policy or Popless’s handling of personal information (i) If you reside in the United States contact Popless, Inc., Legal Privacy, 888 Brannan Street, San Francisco, CA 94103 USA; (ii) for payments related matter please use the contact information provided in the Payments Terms of Service page, and (iii) if you reside outside the United States, please use the contact information for your controller provided in the Outside of the United States page.