Last Updated: Oct 7, 2017
Thank you for using Kytewall!
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.
There are three general categories of information we collect.
We collect information you share with us when you use the Kytewall Platform.
When you use the Kytewall Platform, we collect information about the services you use and how you use them.
We may collect information that others provide about you when they use the Kytewall Platform, or obtain information from other sources and combine that with information we collect through the Kytewall Platform.
We use, store, and process information about you to provide, understand, improve, and develop the Kytewall Platform, and to create and maintain a trusted and safer environment.
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 Kytewall Account.
To help facilitate bookings, we may share your information with other Members as follows:
We don’t share your billing and payout information with other Members.
The Kytewall Platform lets you publish information that is visible to the general public. For example:
Information you share publicly on the Kytewall 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 We do not control the practices of third party search engines, and they may use caches containing your outdated information.
Mentors may use third party services available through the Kytewall Platform to assist with managing their Accommodation or providing additional services, such as cleaning services or lock providers. Mentors may use features on the Kytewall Platform to share information about the Mentee (like check-in and check-out dates, Mentee name, Mentee phone number, and Mentee anonymized email address) with that third party service provider for the purposes of coordinating the stay, managing the Accommodation, or delivering other services.
Kytewall Payments may share your personal information to: (i) provide the Payment Services, (ii) facilitate your use of the Kytewall Platform, and (iii) jointly market products or services to you with other financial third parties with whom Kytewall Payments has a formal agreement. You can unsubscribe or opt-out from receiving such marketing communications in your Account settings.
Kytewall 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 Kytewall, (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 Kytewall, 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 Kytewall’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.
We may display parts of the Kytewall Platform (e.g., your Listing page) on sites operated by Kytewall’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.
In jurisdictions where we facilitate the Collection and Remittance of Occupancy Taxes as described in the “Taxes” section of the Terms of Service, Mentors and Mentees expressly grant us permission, without further notice, to disclose Mentors’ and Mentees’ data and other information relating to them or to their transactions, bookings, Accommodations and Occupancy Taxes to the relevant tax authority, including, but not limited to, the Mentor or Mentee’s name, listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Mentors from Mentees, and contact information.
If a booking is designated as being for business purposes and made by a Mentee affiliated with a company or other organization enrolled in our Business Mentorship Program (either or both an “Enterprise”), we may disclose information related to the booking to the Enterprise, such as the name of the Mentor, the Accommodation 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 mentorship management, financial reporting, personnel management, crisis management, or other services.
If you have linked your Kytewall 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 mentees, pricing, Listing details, the Accommodation 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 mentorship 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, Kytewall may also share relevant information it believes is necessary to safely and quickly address the situation.
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.
We may review, scan, or analyze your communications on the Kytewall 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.
You may link your Kytewall 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:
The Kytewall 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”). Kytewall 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, Kytewall, 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.
You may review, update, or delete the information in your Kytewall Account by logging into your Kytewall Account and reviewing your Account settings and profile.
For information on how to cancel your Kytewall Account, visit www.Kytewall.co/help. Note that information that you have shared with others (like Reviews or forum postings) may continue to be publicly visible on the Kytewall Platform in association with your first name, even after your Kytewall Account is cancelled.
If you reside in the EU or Japan, you may request in writing copies of your personal information held by us. We will provide you with a copy of the personal information held by us as soon as practicable, and in any event not more than 40 days after receiving a valid request in writing. There may be a charge to access your personal data (which will not exceed €6.35 in Ireland and £10 in the United Kingdom, and will not be applicable in Japan). We may request proof of identification to verify your access request.
If your personal information that we hold is inaccurate, let us know and we will update the relevant information. You may also request the erasure of your personal information in accordance with the relevant data protection legislation. We will notify you within 40 days of your valid request about the relevant action taken.
Requests in this section should be addressed to: Kytewall Ireland UC, Data Protection Compliance Officer, 8 Hanover Quay, Dublin 2, Ireland.
You are entitled to see and challenge information third parties provide to us as part of our fraud detection, prevention and risk assessment efforts if all of the following factors apply: (i) we use third parties to carry out automated checks or risk assessments, (ii) we make a decision which has legal consequences for you or which significantly affects you, and (iii) such decision is based solely on such automated checks or risk assessments.
Requests should be addressed to: Kytewall Ireland UC, Data Protection Compliance Officer, 8 Hanover Quay, Dublin 2, Ireland. We may request proof of identification to verify your request.
Under the Privacy Shield Framework, Kytewall is subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at Kytewall, Inc., Legal Department, 888 Brannan Street, San Francisco, CA 94103 or via email. If we are not able to resolve your concern, you may also contact your European Data Protection Authority or Commissioner or seek assistance from our designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.
Kytewall 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.
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.