Privacy policy

Last Updated: Oct 7, 2017

Thank you for using Kytewall!

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

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

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

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.

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 Kytewall Platform.

  • Account Information. When you sign up for an Kytewall Account, we require certain information such as your name, email address, and date of birth.
  • Profile Information. To use certain features within the Kytewall 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.
  • 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 Kytewall and other Members. When you communicate with Kytewall or use the Kytewall 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 Kytewall Platform, like inviting them to use Kytewall.
  • 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 Kytewall Account, respond to surveys, post to community forums, participate in promotions, or use other features of the Kytewall Platform.
1.2 Information We Automatically Collect from Your Use of the Kytewall Platform.

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

  • Usage Information. We collect information about your interactions with the Kytewall Platform, such as the pages or other content you view, your searches for Listings, bookings you have made, and other actions on the Kytewall Platform.
  • Location Information. When you use certain features of the Kytewall 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 Kytewall Platform, even if you have not created an Kytewall Account or logged in. That information includes, among other things: details about how you’ve used the Kytewall 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 Kytewall Platform.
  • Transaction Information. We collect information related to your transactions on the Kytewall 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 Kytewall 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.
1.3 Information We Collect from Third Parties.

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.

  • Third Party Services. If you link, connect, or login to your Kytewall 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 Kytewall public profile page.
  • Background Information. For Members in the United States, to the extent permitted by applicable laws, Kytewall 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, Kytewall 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 Kytewall 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 Kytewall Platform, and to create and maintain a trusted and safer environment.

2.1 Provide, Improve, and Develop the Kytewall Platform.
  • Enable you to access and use the Kytewall Platform.
  • Enable you to communicate with other Members.
  • Operate, protect, improve and optimize the Kytewall 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 Accommodation 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 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 Kytewall 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 Kytewall 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 Kytewall Account.

3.2 Sharing between Mentors, Mentees and Co-Mentors.

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

  • When you as a Mentee submit a booking request, certain information about you is shared with the Mentor (and Co-Mentor, if applicable), including your full name, the full name of any additional Mentees, your cancellation history, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the trip, like your phone number.
  • When you as a Mentor (or Co-Mentor, if applicable) have a confirmed booking, certain information is shared with the Mentee to coordinate the booking, such as your full name, phone number, and Accommodation or Experience address.
  • When you as a Mentor invite another Member to become a Co-Mentor, you authorize the Co-Mentor to access your information and Member Content, including but not limited to certain information like your full name, phone number, Accommodation 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 Kytewall 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 Accommodation or Experience’s approximate location (neighborhood and city), Listing description, calendar availability, the Mentor public profile photo, aggregated demand information (like page views over a period of time), and any additional information the Mentor chooses to share.
  • After completing a booking, Mentees and Mentors 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 Kytewall Platform, that content is publicly visible.

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.

3.4 Service Providers.

We use a variety of third party service providers to help us provide services related to the Kytewall Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). 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 Mentors.

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.

3.6 Kytewall Payments.

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.

3.7 Safety and Compliance with Law.

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.

3.8 Corporate Affiliates.

To help us provide the Kytewall 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 Kytewall Platform.

  • Sharing with Kytewall Ireland. If you reside in the United States, some of your information may be shared with Kytewall Ireland when you create a Listing or when you book a Mentor Service located outside of the United States (other than in China). The information shared in these circumstances may include: (i) your name, e-mail address and phone number, (ii) information relating to the Listing or Mentor Service, including its address, (iii) booking information for the Listing or Mentor Service, including but not limited to booking dates and payment amounts, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Mentees. Additionally, when you send a message to a Mentor or Mentee outside of the United States (other than China), your first name, profile picture and message content sent via the Kytewall Platform will be shared with Kytewall Ireland.
  • Sharing with Kytewall China. Even if you don’t reside in China, some of your information will be shared with Kytewall China in the following circumstances:
  • Creating a Listing. If you create a Listing in China: (i) your name and phone number, (ii) information relating to the Listing (e.g., address), (iii) booking information relating to the Listing, such as Mentee details as set out below in Mentor Services, booking dates, and payment amounts, and (iv) messages between you and prospective and confirmed Mentees at the Listing.
  •  If you book a Mentor Service located in China: (i) your name and phone number, (ii) booking dates, (iii) messages between the Mentor and you or other Mentees on the same booking, and (iv) the names, nationalities, and identification details (including passport/national ID numbers and expiry dates) of any Mentees.
  • Sending Messages. If you send a message to a Mentor in relation to that Mentor’s Listing in China, your first name, profile picture and message content.

We’ll notify you in advance in the above situations, and in specific situations where we apply any practices for China that differ from what is described in this Privacy Policy (including practices pertaining to disclosures to Chinese government agencies).

3.9 Widgets.

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.

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, 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.

3.11 Mentor Information Provided to Business Mentorship Program Customers.

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.

3.12 Mentee Information Provided to Business Mentorship Program Customers.

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.

3.13 Business Transfers.

If Kytewall 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 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.

4.2 Linking Third Party Accounts.

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:

  • some of the information you provide to us from the linking of your accounts may be published on your Kytewall Account profile;
  • your activities on the Kytewall Platform may be displayed to your Friends on the Kytewall 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 Kytewall public profile;
  • other Kytewall 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 Kytewall 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 Kytewall through this linkage is subject to your settings and authorizations on the Kytewall Platform and the third party site.
4.3 Google Maps/Earth.

Parts of the Kytewall 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 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.

6. YOUR CHOICES

6.1 Access and Update.

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.

6.2 Account Cancellation.

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.

6.3 EU and Japan Residents: Review and Update Your Information.

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.

6.4 EU Residents: Access and Challenge Information Provided to Us By Third Parties.

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.

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 Kytewall 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 Kytewall Platform, you consent to transferring your data to these countries.

7.1 EU-US & Swiss-US Privacy Shield.

Kytewall complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Kytewall has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more, see Kytewall’s Privacy Shield certification.

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.

As explained in this Privacy Policy, we sometimes share information with third parties to perform services on our behalf. Kytewall remains responsible for information that is shared under the Privacy Shield with these third parties, except where we can establish that Kytewall was not responsible for the violation.

7.2 California & Vermont Residents.

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.

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

Kytewall 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 Kytewall 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 Kytewall Platform will constitute acceptance of the revised Privacy Policy.

10. CONTACT

If you have any questions or complaints about this Privacy Policy or Kytewall’s information handling practices, you may contact us at: hello@Kytewall.co