Privacy Policy

Last Updated: January 7, 2020

1. INTRODUCTION

Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Sharecube.

This Privacy Policy describes how we collect, use, process, and disclose your personal information, in conjunction with your access to and use of the Sharecube Platform.

1.1 Definitions

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

1.2 Data Controller

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

2. INFORMATION WE COLLECT

 There are three general categories of information we collect.

2.1 Information You Give to Us.

2.1.1 Information that is necessary for the use of the Sharecube Platform.

We ask for and collect the following personal information about you when you use the Sharecube Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

• Account Information. When you sign up for a Sharecube Account, we require certain information such as your first name, last name, email address, and date of birth.
• Profile and Listing Information. To use certain features of the Sharecube Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
• Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws).
• Payment Information. To use certain features of the Sharecube Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.
• Communications with Sharecube and other Members. When you communicate with Sharecube or use the Sharecube Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

2.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using Sharecube Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

• Additional Profile Information. You may choose to provide additional information as part of your Sharecube profile (such as gender, preferred language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page and will be publicly visible to others.
• Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your Sharecube Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of the Sharecube Platform.

2.1.3 Information that is necessary for the use of payment services.

The Payments Data Controller (Stripe) needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

• Payment Information. When you use the Payment Services, the Payments Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
• Identity Verification and Other Information. If you are a Host, the Payments Data Controller may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.

2.1.4 Information We Automatically Collect from Your Use of the Sharecube Platform.

When you use the Sharecube Platform, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Sharecube Platform.

• Geo-location Information. When you use certain features of the Sharecube Platform, we may collect information about your precise or approximate location as determined through data such as your IP address.
• Usage Information. We collect information about your interactions with the Sharecube Platform such as the pages or content you view, your searches for Listings, bookings you have made, and other actions on the Sharecube Platform.
• Log Data and Device Information. We automatically collect log data and device information when you access and use the Sharecube Platform, even if you have not created a Sharecube Account or logged in. That information includes, among other things: details about how you’ve used the Sharecube Platform, IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Sharecube Platform.
• Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimise our website experience. In some cases we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Sharecube Platform or engage others to track your behavior on our behalf.
• Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. more information on our use of these technologies, see our Cookie Policy.
• Do Not Track Signals. While you may disable the usage of cookies through your browser settings, the Sharecube Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardisation regarding how that signal should be interpreted.

2.1.5 Information We Collect from Third Parties.

Sharecube may collect information, including personal information, that others provide about you when they use the Sharecube Platform or obtain information from other sources and combine that with information we collect through the Sharecube Platform. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

• Third Party Services. If you link, connect, or login to your Sharecube Account with a third party service (e.g. Google or Facebook), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
• If you are invited to Sharecube, the person who invited you may submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. We may receive information about you and your activities on and off the Sharecube Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2.2 Children’s Data.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any personal information directly from children under 16. If you believe that we processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

3. HOW WE USE INFORMATION WE COLLECT

We may use, store, and process personal information to (1) provide, understand, improve, and develop the Sharecube Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with Sharecube Policies) and (3) provide, personalise, measure, and improve our advertising and marketing.

3.1Provide, Improve, and Develop the Sharecube Platform.

We may use the personal information to provide, improve, and develop the Sharecube Platform such as to:

• enable you to access and use the Sharecube Platform,
• enable you to communicate with other Members,
• operate, protect, improve, and optimise the Sharecube Platform and experience, such as by performing analytics and conducting research,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• to operate, protect, improve, and optimise the Sharecube Platform and experience, and personalise and customise your experience.

We process this personal information for these purposes given our legitimate interest in improving the Sharecube Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

3.2 Create and Maintain a Trusted and Safer Environment.

We may use the personal information to create and maintain a trusted and safer environment such as to:

• detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• conduct security 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, including background or police checks, to the extent permitted by applicable laws and with your consent where required,
• comply with our legal obligations,
• Resolve any disputes with any of our Members and enforce our agreements with third parties,
• enforce our Terms of Service and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Sharecube Platform, your profile information and other content you submit to the Sharecube Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Sharecube Platform if such processes detect activity that we think poses a safety or other risk to the Sharecube Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

We process this personal information for these purposes given our legitimate interest in protecting the Sharecube Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

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

We may use the personal information to provide, personalise, measure, and improve our advertising and marketing such as to:

• send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Sharecube or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Instagram),
• personalise, measure, and improve our advertising,
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Sharecube or its third party partners,
• conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Sharecube Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,
• enrolling in an email subscription will not affect the frequency of administrative emails that we may send in connection with any Sharecube Account. No fee is charged for sending promotional emails to you, but third-party data rates may apply. Note that you may not be able to take advantage of certain promotions if you do not have a Sharecube Account, and
• invite you to events and relevant opportunities.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

3.4 How the Payments Data Controller uses the Personal Information Collected.

• Enable you to access and use the payment services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Payments Data Controller processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3.5 Your Choices

You have choices on the promotional messages that you choose to receive.

• You can limit the information you provide to Sharecube. Participation in promotions and marketing programs is voluntary.
• You can limit the communications that Sharecube sends to you.
• To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you or access the notification settings in your Sharecube Account.

4. SHARING & DISCLOSURE

4.1 Advertising and Social Media; Sharing With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorise a third party application or website to access your Sharecube Account or when you participate in promotional activities conducted by Sharecube partners or third parties.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Sharecube Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.

The social media platforms with which we may share your personal information are not controlled or supervised by Sharecube. Therefore, any questions regarding how your social media platform service provider processes your personal information should be directed to such provider.

4.2 Sharing between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

• When you as a Guest submit a booking request, certain information about you is shared with the Host, including your profile, full name, and other information you agree to share. When your booking is confirmed, we will disclose additional information to assist with coordinating the booking, like your phone number.
• When you as a Host have a confirmed booking, certain information is shared with the Guest to coordinate the booking, such as your profile, full name, phone number.

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

4.3 Profiles, Listings, and other Public Information.

The Sharecube Platform lets you publish information, including personal 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.
• Listing pages are publicly visible and include information such as the Space’s approximate location (neighborhood and city), Listing description, calendar availability, your public profile photo, and any additional information you choose to share.
• After completing a booking, Guests may write Reviews. Reviews and Ratings are a part of your public profile page and may also be surfaced elsewhere on the Sharecube Platform (such as the Listing page).
• If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Sharecube Platform, that content is publicly visible.

Based on our legitimate interest to promote the Sharecube Platform we may display parts of the Sharecube Platform (e.g., your Listing page) on sites operated by Sharecube’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.

Information you share publicly on the Sharecube Platform may be indexed through third party search engines.

4.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Sharecube may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Sharecube, (iii) to respond to a valid legal request 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 (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Sharecube, its employees, its Members, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Sharecube Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

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

4.5 Business Transfers.

If Sharecube undertakes or is involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.6 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 other anonymised information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

5. OTHER IMPORTANT INFORMATION

5.1 Analyzing your Communications.

We may review, scan, or analyse your communications on the Sharecube Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we may scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse 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 analyse your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Sharecube’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

5.2 Third Party Partners & Integrations

The Sharecube 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”). Sharecube 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, Sharecube, 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.

Parts of the Sharecube Platform may use third party services such as Google Maps/Earth services, including the Google Maps API(s), and Stripe for Sharecube Payments. Use of these respective services is subject to their privacy policies such as Google Maps/Earth Additional Terms of Use, and the Google Privacy Policy, Stripe Privacy Policy.

6. YOUR RIGHTS

Consistent with applicable law, you may exercise any of the rights described in this section before Sharecube. Please note that we may ask you to verify your identity and request before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Account settings.

6.2 Rectification of Inaccurate or Incomplete Information.Y

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Sharecube Account).

6.3 Data Access and Portability.

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

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Sharecube Account for fraud or safety reasons, we may retain certain information from that Sharecube Account to prevent that Member from opening a new Sharecube Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Sharecube may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Sharecube Platform, even after your Sharecube Account is cancelled. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Sharecube Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing.

If we are processing your personal information based on your consent you may withdraw your consent at any time by sending a communication to Sharecube specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Sharecube override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Sharecube not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Sharecube will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Sharecube to cease processing your data for these direct marketing purposes by sending an e-mail to optout@sharecube.com

6.7 Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with us via the “Contact Us” section below or with a supervisory authority.

7. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Sharecube Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorised use of your Sharecube Account, please contact us following the instructions in the Contact Us section below.

9. CHANGES TO THIS PRIVACY POLICY

Sharecube 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 Sharecube 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 to or use of the Sharecube Platform will be subject to the revised Privacy Policy.

10. CONTACT US

If you have any questions or complaints about this Privacy Policy or Sharecube’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at:

Sharecube, Digital House, Seafield Business Park, Youghal, Co. Cork, Ireland. P36 E702

Email: privacy@sharecube.com