LivingLab Privacy Policy

Last Updated: November 6, 2017

Thank you for using LivingLab!

This Privacy Policy explains how we collect, use, process, and disclose your information across the LivingLab Platform.

If you see an undefined term in this Privacy Policy (such as “Listing” or “LivingLab Platform”), it has the same definition as outlined in our Terms of Service.

When this policy mentions “LivingLab,” “we,” “us,” or “our,” it refers to the LivingLab company that is responsible for your information under this Privacy Policy (the “Data Controller”).

  • If you reside in the United States, the Data Controller is LivingLab, Inc.

If you change your place of residence, the Data Controller will be determined by your new place of residence as specified above, from the date on which your place of residence changes.

This Privacy Policy also applies to the Payment Services provided to you by LivingLab Payments pursuant to the Payments Terms of Service(“Payments Terms”). One or more LivingLab Payments entities will be the Data Controller of your information related to the Payment Services depending on where your Payment Method or Payout Method is issued:

  • If issued in the United States, the Data Controller is LivingLab, Inc.

1. INFORMATION WE COLLECT

There are three general categories of information we collect.

1.1 Information You Give Us.

We collect information you share with us when you use the LivingLab Platform.

  • Account Information. When you sign up for a LivingLab Account, we require certain information such as your name, email address, and date of birth.

  • Profile Information. To use certain features within the LivingLab Platform, we may also ask you to complete a profile, which may include your address, phone number, and gender. Certain parts of your profile (like your profile picture, first name, and description) are a part of your public profile page, and will be publicly visible to others.

  • Other Authentication-Related Information. To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued ID) or other authentication information. In order to streamline your approval for a LivingLab Residence, we may also collect more private information associated with credit and background checks. To learn more, please contact us directly.

  • Payment Information. We collect your financial information (like your bank account or credit card information) when you use the Payment Services to process payments.

  • Communications with LivingLab and other Members. When you communicate with LivingLab or use the LivingLab Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

  • Address Book Contact Information. You may choose to import your address book contacts or enter your contacts’ information manually to access certain features of the LivingLab Platform, like inviting them to use LivingLab.

  • Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your LivingLab Account, respond to surveys, post to community forums, participate in promotions, or use other features of the LivingLab Platform.

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

When you use the LivingLab Platform, we collect information about the services you use and how you use them.

  • Usage Information. We collect information about your interactions with the LivingLab Platform, such as the pages or other content you view, your searches for Listings, bookings you have made, and other actions on the LivingLab Platform.

  • Location Information. When you use certain features of the LivingLab Platform, we may collect different types of information about your general location (e.g. IP address, zip code) or more specific location information (e.g. precise location from your mobile GPS). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.

  • Log Data. We automatically collect log information when you use the LivingLab Platform, even if you have not created a LivingLab Account or logged in. That information includes, among other things: details about how you’ve used the LivingLab Platform (including links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the LivingLab Platform.

  • Transaction Information. We collect information related to your transactions on the LivingLab Platform, including the date and time, amounts charged, and other related transaction details.

  • Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the LivingLab Platform, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. For more information please contact us directly.

1.3 Information We Collect from Third Parties.

We may collect information that others provide about you when they use the LivingLab Platform, or obtain information from other sources and combine that with information we collect through the LivingLab Platform.

  • Third Party Services. If you link, connect, or login to your LivingLab Account with a third party service (e.g., Facebook, WeChat), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

  • Your References. If someone has written a reference for you, it will be published on your LivingLab public profile page. We will offer this feature at a future date and notify Members of its implementation.

  • Background Information. For Members in the United States, to the extent permitted by applicable laws, LivingLab may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws, LivingLab may obtain the local version of background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

  • Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the LivingLab Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information about you to provide, understand, improve, and develop the LivingLab Platform, and to create and maintain a trusted and safer environment.

2.1 Provide, Improve, and Develop the LivingLab Platform.

  • Enable you to access and use the LivingLab Platform.

  • Enable you to communicate with other Members.

  • Operate, protect, improve and optimize the LivingLab Platform and experience, such as by performing analytics and conducting research.

  • Personalize or otherwise customize your experience by, among other things, ranking search results or showing ads based on your search, booking history, and preferences.

  • Enable you to access and use the Payment Services.

  • Provide customer service.

  • Send you service or support messages, such as updates, security alerts, and account notifications.

  • If you provide us with your contacts’ information, we may use and store this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.

2.2 Create and Maintain a Trusted and Safer Environment.

  • Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.

  • Conduct investigations and risk assessments.

  • Verify or authenticate information or identifications provided by you (such as to verify your Provided Residence address or compare your identification photo to another photo you provide).

  • Conduct checks against databases and other information sources.

  • Comply with our legal obligations.

  • Resolve any disputes with any of our users and enforce our agreements with third parties.

  • Enforce our Terms of Service, Payments Terms, and other policies.

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

  • Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about LivingLab or partner campaigns and services).

  • Personalize, measure, and improve advertising.

  • Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LivingLab or its third party business partners.

3. SHARING & DISCLOSURE

3.1 With Your Consent.

We may share your information at your direction or as described at the time of sharing, such as when you authorize a third party application or website to access your LivingLab Account.

3.2 Sharing between Residence Providers, Members and Co-Residence Providers.

To help facilitate bookings, we may share your information with other Members as follows:

  • When you as a Member submit a lease request, certain information about you is shared with the Residence Provider (and Co-Residence Provider, if applicable), including your full name, the full name of any additional Members, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with streamlining the application and move-in process, like your phone number.

  • When you as a Residence Provider (or Co-Residence Provider, if applicable) have a confirmed booking, certain information is shared with the Member to coordinate the booking, such as your full name, phone number, and Residence address.

  • When you as a Residence Provider invite another Member to become a Co-Residence Provider, you authorize the Co-Residence Provider to access your information and Member Content, including but not limited to certain information like your full name, phone number, Provided Residence address, and email address.

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

3.3 Profiles, Listings, and other Public Information.

The LivingLab Platform lets you publish information that is visible to the general public. For example:

  • Parts of your public profile page, such as your first name, your description, and city, are publicly visible to others.

  • Public Listing pages are publicly visible and include information such as the Provided Residence’s approximate location (neighborhood and city), Listing description, calendar availability, the Residence Provider public profile photo, aggregated demand information (like page views over a period of time), and any additional information the Residence Provider chooses to share.

  • After completing a booking, Members and Residence Providers may write reviews and rate each other. Reviews are a part of your public profile page.

  • If you submit content in a public forum or social media post, or use a similar feature on the LivingLab Platform, that content is publicly visible.

Information you share publicly on the LivingLab Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4 Service Providers.

We use a variety of third party service providers to help us provide services related to the LivingLab Platform. For example, service providers may help us: (i) verify or authenticate your identification, (ii) check information against public databases, (iii) assist us with background checks, fraud prevention, and risk assessment, or (iv) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this Privacy Policy.

3.5 Additional Services by Residence Providers.

Residence Providers may use third party services available through the LivingLab Platform to assist with managing their Provided Residence or providing additional services, such as cleaning services or lock providers. Residence Providers may use features on the LivingLab Platform to share information about the Member (like Lease dates, Member name, Member phone number, and Member anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Residence, or delivering other services.

3.6 LivingLab Payments.

LivingLab Payments may share your personal information to: (i) provide the Payment Services, (ii) facilitate your use of the LivingLab Platform, and (iii) jointly market products or services to you with other financial third parties with whom LivingLab Payments has a formal agreement. You can unsubscribe or opt-out from receiving such marketing communications in your Account settings.

3.7 Safety and Compliance with Law.

LivingLab may disclose your information to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required to do so by law or if such disclosure is reasonably necessary: (i) to comply with legal process and to respond to claims asserted against LivingLab, (ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iii) to enforce and administer our Terms of Service or other agreements with Members, (iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of LivingLab, its employees, its Members, or members of the public.

We will attempt to notify Members about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon LivingLab’s property, its Members and the Platform (collectively, “Risk Scenarios”). In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

3.8 Corporate Affiliates.

To help us provide the LivingLab Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. These related entities are covered under this Privacy Policy, and when services have additional terms specific to them, we tell you through the LivingLab Platform.

3.9 Widgets.

We may display parts of the LivingLab Platform (e.g., your Listing page) on sites operated by LivingLab’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

3.10 Tax Authorities.

In jurisdictions where we facilitate the Collection and Remittance of Occupancy Taxes as described in the “Taxes” section of the Terms of Service, Residence Providers and Members expressly grant us permission, without further notice, to disclose Residence Providers’ and Members’ data and other information relating to them or to their transactions, bookings, Provided Residences and Occupancy Taxes to the relevant tax authority, including, but not limited to, the Residence Provider or Member’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Residence Providers from Members, and contact information.

3.11 Residence Provider Information Provided to Business Program Customers.

If a booking is designated as being for business purposes and made by a Member affiliated with a company or other organization enrolled in our Business Program (either or both an “Enterprise”), we may disclose information related to the booking to the Enterprise, such as the name of the Residence Provider, the Provided Residence address, pricing, Listing details, and other related information. At the request of the Enterprise, we may also share this information with third parties engaged by it to provide travel management, financial reporting, personnel management, crisis management, or other services.

3.12 Member Information Provided to Business Program Customers.

If you have linked your LivingLab Account with an Enterprise, and you are included on a booking designated as being for business purposes, we may disclose information related to the booking to your Enterprise. Typically, this includes your name, dates of the booking, number of Members, pricing, Listing details, the Provided Residence address, and other related information. At the request of your Enterprise, we may also disclose this information to service providers engaged by it, such as companies that provide travel management, financial reporting, personnel management, crisis management, or other services. In the event of a dispute, emergency, or similar situation involving a booking identified as being for business purposes, LivingLab may also share relevant information it believes is necessary to safely and quickly address the situation.

3.13 Business Transfers.

If LivingLab 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 this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.14 Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION

4.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the LivingLab Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

4.2 Linking Third Party Accounts.

You may link your LivingLab Account with your account at a third party social networking service. Your contacts on these third party services are referred to as “Friends.” When you create this link:

  • some of the information you provide to us from the linking of your accounts may be published on your LivingLab Account profile;

  • your activities on the LivingLab Platform may be displayed to your Friends on the LivingLab Platform and/or that third party site;

  • a link to your public profile on that third party social networking service may be included in your LivingLab public profile;

  • other LivingLab users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

  • other LivingLab 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;

  • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

  • the publication and display of information that you provide to LivingLab through this linkage is subject to your settings and authorizations on the LivingLab Platform and the third party site.

4.3 Google Maps/Earth.

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

5. THIRD PARTY PARTNERS & INTEGRATIONS

The LivingLab Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). LivingLab doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, LivingLab, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. YOUR CHOICES

6.1 Access and Update.

You may review, update, or delete the information in your LivingLab Account by logging into your LivingLab Account and reviewing your Account settings and profile.

6.2 Account Cancellation.

For information on how to cancel your LivingLab Account, visit www.LivingLab.com/help. Note that information that you have shared with others (like Reviews or forum postings) may continue to be publicly visible on the LivingLab Platform in association with your first name, even after your LivingLab Account is cancelled.

7. OPERATING GLOBALLY

As described in this Privacy Policy, we may sometimes share your information within our family of companies or with third parties. When you use the LivingLab Platform, you authorize us to transfer, store, and process your information in the United States and possibly other countries. Laws in these countries may differ from the laws applicable to the place where you live. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. By using the LivingLab Platform, you consent to transferring your data to these countries.

7.2 California & Vermont Residents.

LivingLab Payments will not share information it collects about you with their affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. However, the Internet is not a 100% secure environment so we can’t guarantee the security of the transmission or storage of your information.

9. CHANGES TO THIS PRIVACY POLICY

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

10. CONTACT

If you have any questions or complaints about this Privacy Policy or LivingLab’s information handling practices, you may contact us at:

  • For residents of the United States: LivingLab, Inc., 1919 Meeting St., Durham, NC 27705.

You may also email us.

 

 

Privacy Policy

Last Updated: November 5, 2017

  1. LivingLab PRIVACY POLICY

  2. LivingLab (hereinafter referred to as “LivingLab”, “we”, “us” or “our”) operates a platform and community marketplace that helps people form offline experiences and relationships directly with one another, where they can create, list, discover and book unique Provided Residences around the world, whether through our website or our mobile applications (“Platform”).

  3. LivingLab refers to (i) LivingLab, Inc. At a later date, LivingLab, Inc. reserves the right to create an entity known as LivingLab Payments, Inc., a subsidiary of LivingLab, Inc. that processes payments for Members and Residence Providers that use a Payment Method or Payout Method issued in the USA. This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your LivingLab Account. You can find out more about how to deactivate your LivingLab Account by contacting us.

  4. DEFINITIONS

  5. Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Provided Residence”, “Content,” “Services” etc.), it shall be given its definition as outlined in our our Terms of Service.

  6. “Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies.

  7. “Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

  8. “Data Controller” means LivingLab, the company responsible for the use and processing of Personal Information.

  9. “Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and LivingLab.

  10. “Personal Information” means information (which may include sensitive information) relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

  11. WHAT TYPES OF INFORMATION DOES LivingLab GATHER ABOUT ITS USERS?

    1. Information that you give us

    2. We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:

      • fill in any form on the Platform, such as when you register or update the details of your user account, or when you supply ID and other verification information;

      • access or use the Platform, such as to search for or post Provided Residences, make or accept bookings, pay for Provided Residences, book or pay for any associated services that may be available (such as but not limited to cleaning), post comments or reviews, or communicate with other users;

      • link your account on a Third-Party site (e.g. Facebook) to your LivingLab Account, in which case we will obtain the Personal Information that you have provided to the Third-Party site, to the extent allowed by your settings with the Third-Party site and authorized by you;

      • communicate with LivingLab; and

      • share information with another Member.

    3. Information we get from your use of our Platform

    4. We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:

      • Mobile Data

      • When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, zip code) and more specific information (e.g. GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

      • Contact Information

      • You may use your contact information, such as your email address, phone number or WeChat account ID to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address, phone number or WeChat account ID, you agree to receive emails to that email address, text messages to that phone number or messages to that WeChat account, as the case may be. We may use your contact information to send you information about our Platform and Services, to market to you, and to help prevent spam, fraud, or abuse.

      • Log Data

      • We may also receive, store and process Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with LivingLab or logged in to your LivingLab Account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.

      • Cookies and other Tracking Technologies

      • LivingLab uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners.

      • While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for LivingLab services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

      • We may, either directly or through Third Parties we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through Third-Parties we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and Third-Party websites. Third Parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access.

      • Third Parties may not collect information about users’ online activities on the Platform except as described in this policy.

      • Third-Party social plugins

      • Our Platform may use social plugins which are provided and operated by Third-Parties, such as Facebook’s Like Button.

      • As a result of this, you may send to the Third-Party the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the Third-Party, then the Third Party may not know your identity. If you are logged into your account with the Third Party, then the Third Party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the Third Party.

      • Please refer to the Third Party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the Third Party uses such data.

  12. HOW LivingLab USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

    1. We use, store and process information about you for the following general purposes:

      • to enable you to access and use the Platform;

      • to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the Booking process;

      • to operate, protect, improve and optimize the Platform, LivingLab’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;

      • to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the address of your listings, verifying any identifications provided by you (including by comparing the photo on that identification to another photo you provide to us), and conducting checks against databases and information sources (such as but not limited to public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;

      • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

      • to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about LivingLab, our services, or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications in your settings (in the “Account” section) when you login to your LivingLab Account;

      • if a Member has an employment or consulting relationship with a company or other organization that participates in the LivingLab Business Program, and that Member has linked their LivingLab Account to that organization, to administer the LivingLab Business Program;

      • to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by LivingLab or our Third Party business partners; and

      • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with Third Parties.

    2. How LivingLab Uses and Processes User Communications

    3. We may, either directly or through Third-Parties we engage to provide services to us, review, scan, or analyze your communications with other users exchanged via the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, as part of our fraud prevention efforts, the Platform may scan and analyze messages and attachments to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Members to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand product offerings. We will not review, scan, or analyze your communications for sending Third-Party marketing messages to you. We will also not sell these reviews or analyses of communications to Third Parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that LivingLab, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.

  13. WHEN LivingLab DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM

  14. IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries in accordance with this Privacy Policy.

  15. We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area (“EEA”) including the United States and possibly other countries. By using the Platform, you consent to transferring your data to these countries. Please note that laws vary from jurisdiction to jurisdiction, and so laws and regulations relating to privacy and data disclosure, applicable to the places where your information is transferred to or stored, used or processed in, may be different from the laws and regulations applicable to the place where you are resident.

  16. Your Personal Information may be transferred, stored, used, processed and disclosed as follows:

    1. Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes or if you post content in a community forum or other features on the Platform that are visible to the general public.

    2. Your public Listing page will always include some minimum information such as the city and neighborhood where the Provided Residence is located, your listing description, your calendar availability, your public profile photo, your responsiveness in replying to Members’ queries, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes. The Platform may also display the Provided Residence’s approximate geographic location on a map, such that a user can see the general area of the Provided Residence.

    3. The Platform allows your public profile and public Listing pages to be included in search engines, in which case your public profile and public Listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public Listing pages, Third-Party search engines may not update their databases quickly or at all. We do not control the practices of Third-Party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public Listing pages.

    4. When you submit a request to book an Provided Residence, your full name, and the full name of any confirmed Members staying with you, and other Personal Information you agree to pass through to the Residence Provider(s) will become visible to the Residence Provider(s) of any Listing you Book or request to Book. We may also disclose parts of your public profile; your public Wish List; other Member reviews of you; and any additional information you share with other Members. We will not share your phone number unless there is a confirmed booking; if there is a confirmed booking, your phone number will become visible to the Residence Provider(s)/Member, who may call you directly.

    5. When your request to book an Provided Residence is accepted by the Residence Provider(s) or when a Member books your Provided Residence, we will disclose some of your Personal Information to the Residence Provider(s) and any confirmed Member(s). However, your billing and payout information will never be shared with another user.

    6. If a Member books a Provided Residence for a business trip, and the Member is engaged or employed by a company or other organization (either or both a “Member Affiliated Organization”) that is enrolled in our Business Program, we may disclose the name of the Residence Provider and the address and other Provided Residence information to the Member Affiliated Organization. If the Member or the Member Affiliated Organization uses any Third Party for travel management, financial reporting and/or travel related crisis management services (collectively, “Business Services”), we may also share Residence Provider and Provided Residence information with those Third Parties and any service providers of those Third Parties who participate in providing such Business Services.

    7. When a Residence Provider accepts your request to book an Provided Residence, the Residence Provider may elect to use Third-Party services available through the LivingLab platform to assist with managing the Provided Residence, such as cleaning services and lock providers. The Residence Provider may use features on the LivingLab platform to share information about the Member with that Third-Party service provider for the purposes of coordinating the stay or managing the Provided Residence, including check-in and check-out dates, Member name, Member’s phone number, and the Member’s anonymized email address.

    8. If you as a Member are associated with a Member Affiliated Organization, we may share with it information related to your bookings through the Business Program. Further, if you have linked your LivingLab Account to a Member Affiliated Organization and indicate that a booking is for business purposes, we may disclose your booking information (which may include your Personal Information) to such organization. Typically this information will include your name, dates of the booking, number of Members, cost of the booking, and the address of the booking. In addition, if your Member Affiliated Organization has requested that we provide it with information in the event of a dispute, emergency or similar situation involving your bookings through the Business Program, we may notify such organization of the situation and disclose to it any information, including your Personal Information, that we believe in good faith is necessary to safely and quickly resolve or address the situation. If you or your Member Affiliated Organization uses a Third Party for travel management, financial reporting, and/or travel related crisis management services, we may also disclose your booking information, or information related to a dispute, emergency or similar situation involving you, to those Third Parties and any service providers of those Third Parties who participate in providing such services.

    9. When a Member stays at your Provided Residence or when you stay at a Residence Provider’s Provided Residence, we may ask you to review the Member, Residence Provider, or the Provided Residence. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Member or Residence Provider may be public on the Platform.

    10. You may link your account on a Third-Party social networking site to your LivingLab Account. We refer to a person’s contacts on these Third-Party sites as “Friends”. When you create this linkage:

      • some of the information you provide to us from the linking of your accounts may be published on your LivingLab Account profile;

      • your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;

      • a link to your public profile on that Third-Party social networking site may be included in your LivingLab public profile;

      • other LivingLab users may be able to see any common Friends that you may have with them, or that you are a Friend of their Friend if applicable;

      • other LivingLab 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 site(s);

      • the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and

      • the publication and display of information that you provide to LivingLab through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.

    11. We may distribute parts of the Platform (including your Listing) for display on sites operated by LivingLab’s business partners and affiliates, using technologies such as HTML widgets. If and when your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

    12. LivingLab may provide your Personal Information to its Affiliates, including LivingLab Payments, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy. LivingLab Payments may share your Personal Information for (i) their everyday business purposes; (ii) to jointly market products or services to you with other financial Third Parties with whom LivingLab Payments has a formal agreement; and (iii) with respect to information about your transactions and experiences only, for their Affiliates’ everyday purposes. You can unsubscribe or opt-out from receiving marketing communications in your settings (in the “Account” section) when you login to your LivingLab account.

    13. We may also engage Third Parties, who may be located outside of the EEA, to provide services to us, including but not limited to technology services and services to help verify your identification, to help match the photo on your ID to other photos of yourself you send to us, to conduct checks against databases such as but not limited to public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, to serve targeted ads, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these Third Parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. For example, if we hire Third Parties, where permitted by applicable law, to conduct checks against databases such as but not limited to public government databases, we may provide your Personal Information, such as your full name and date of birth, to the Third Parties for the limited purpose of allowing them to conduct such checks, including background or registered sex offender checks, on our behalf. We will ensure that such Third Parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

    14. For any jurisdiction in which we facilitate the Collection and Remittance of Taxes or Opt-in for Residence Provider Remittance of Taxes as described in the “Taxes” section of the Terms of Service, Residence Providers and Members expressly grant us permission, without further notice, to store, transfer and disclose data and other information relating to them or to their transactions, bookings, Provided Residences and Occupancy Taxes, including, but not limited to, personally identifiable information such as Residence Provider or Member’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received by Residence Providers from Members, or allegedly due, contact information and similar information, to the relevant Tax Authority.

    15. You acknowledge, consent and agree that LivingLab may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against LivingLab; (b) to comply with legal process (for example, subpoenas and warrants), including legal process associated with national security and law enforcement; (c) to enforce and administer our agreements with users, such as the Terms of Service, the Payments Terms of Service, this Privacy Policy, and the Residence Provider Guarantee Terms and Conditions; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of LivingLab, its users or members of the public.

    16. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:

      • providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or

      • we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon LivingLab’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).

    17. In instances where LivingLab complies with legal requests for user data without notice to the user for the reasons described above, LivingLab will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.

    18. We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

  17. STATE PRIVACY LAWS

  18. For California & Vermont residents: LivingLab Payments will not share information it collects about you with Affiliates or Third Parties, except as required or permitted by your state’s law.

  19. BUSINESS TRANSFERS BY LivingLab

  20. If LivingLab undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

  21. HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR LivingLab ACCOUNT

  22. You may review, update, correct or delete the Personal Information in your LivingLab Account. If you would like to correct your information or cancel your LivingLab Account entirely, you can do so by logging into your LivingLab Account. Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your LivingLab Account is cancelled.

  23. SECURING YOUR PERSONAL INFORMATION

  24. We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.

  25. YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

  26. The Platform will contain links to other websites not owned or controlled by LivingLab. LivingLab does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

  27. Some portions of the 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 (located at www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located atwww.google.com/privacy.html), as may be amended by Google from time to time

  28. SPECIAL FEATURES AND PROGRAMS

    1. Referral service and requesting references

    2. The Platform provides a referral service that allows you to invite your friends and contacts to use the Platform. The Platform also allows you to ask your friends and contacts to write a reference for you, to be published on your LivingLab profile.

    3. We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and LivingLab does not collect or retain the contact information that is used to send them.

    4. You may also send invitation/request emails via the Platform itself, in which case we will ask you for the contact information to which to send your invitation/request. You can type in the email addresses or other contact information manually, or you can choose to import the contacts in your address book(s). In both cases, we may use and store this information for the sole purposes of allowing you to send your friends and contacts an invitation or request for a reference, and for fraud detection and prevention. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins LivingLab in response to your referral.

    5. If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.

    6. Meetups

    7. The Platform may allow registered account holders to organize, search for or participate in offline events (“Meetups”) in selected cities.

    8. If you organize a Meetup or indicate that you will attend one, this information, together with some of your public information (such as your profile picture and public profile page) and any messages that you post about that Meetup, will be visible to users who browse the event. However, LivingLab will never disclose where you are staying to another meetup user.

  29. CHANGES TO THIS PRIVACY POLICY

  30. We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

  31. It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your LivingLab Account. You can find out more about how to deactivate your LivingLab Account at www.LivingLab.com/help.

  32. GOT FEEDBACK?

  33. Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please contact us directly.

  34. COOKIE POLICY

  35. LivingLab uses “cookies” in conjunction with the Platform to obtain information. A cookie is a small data file that is transferred to your device (e.g. your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

  36. Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

    1. LivingLab cookies and Third Party cookies

    2. LivingLab may place our cookies on your device via the Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.

    3. We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes.

    4. There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.

    5. Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

    6. Other technologies

    7. The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

    8. Uses for LivingLab cookies

    9. LivingLab uses cookies and similar tracking technologies for a number of purposes, such as the following:

      • to enable, facilitate and streamline the functioning of the Platform across different webpages, devices and browser sessions.

      • to simplify your access to and use of the Platform and make it more seamless.

      • to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.

      • to show you content (which may include advertisements) that is more relevant to you.

      • for fraud detection and prevention.

    10. Uses for Third-Party cookies

    11. Our partners’ cookies are intended to obtain information to help them provide services to LivingLab. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise LivingLab listings or services to you on the Platform and Third-party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests.

    12. In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the LivingLab mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.

    13. Disabling Cookies

    14. Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the the Adobe website and make changes at the Global Privacy Settings Panel.

    15. Changes to this Cookie Policy

    16. We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email.

    17. It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your LivingLab Account. You can find out more about how to deactivate your LivingLab Account by contacting us directly.