Privacy Policies

1. INFORMATION WE COLLECT

1.1. Information necessary to use the MyPlaces Platform.

We collect your personal information when you use the MyPlaces Platform. Without this information, we may not be able to provide you with all the services you request. This information includes the following:

• Contact, account, and profile information. Such as your first name, last name, phone number, mailing address, email address, date of birth, and profile picture, some of which depend on the features you use.
• Identity Verification and Payment Information. For instance, images of your official identification (as allowed by applicable laws), your identification number or other verification information, a selfie when we verify your identification, bank account or payment account. If you’re not a user on MyPlaces, we may receive payment information related to you, for example, when a MyPlaces user provides their payment card for completing a reservation. If a copy of your identification is provided to us, we may inspect, use, and store the information contained in your identification to verify your identity and for security reasons.

1.2. Voluntarily Provided Information.

You can choose to provide additional personal information. This information may include the following:

• Additional Profile Information. Such as gender, preferred languages, city, and personal description. Some of this information, as indicated in your account settings, is part of your public profile page and will be publicly visible.

1.3. Information Automatically Collected through the MyPlaces Platform and our Payment Services.

When you use the MyPlaces Platform and Payment Services, we automatically collect personal information and other information. This information may include the following:

• Geolocation Information. Such as precise or approximate location determined from your IP address, your device’s GPS, or other information you share with us, based on your device’s settings. We may also collect this information when you’re not using the app if allowed through device settings or permissions.
• Cookies and Similar Technologies, as Described in Our Cookie Policy.
• Payment Transaction Information. Such as the payment instrument used, date and time, payment amount, payment instrument’s expiration date, and billing postal code, IBAN information, address, and other transaction-related details.
• Guest Travel Insurance. If you file a claim under our Guest Travel Insurance policy, we receive information about your claim to process, manage, or assess it, as indicated in this Privacy Policy.

2. HOW WE USE COLLECTED INFORMATION

2.1. Providing, Improving, and Developing the MyPlaces Platform. We use personal information, among other purposes, to:

• Enable you to access the MyPlaces Platform and make and receive payments.
• Enable you to communicate with other members.
• Process your requests.
• Conduct analytics, debugging, and research.
• Provide customer service, training.
• Send you messages, updates, security alerts, and notifications about your account.
• Process, manage, or assess insurance or similar claims.

2.2. Creating and Maintaining a Trusted and Safe Environment. We use personal information, among other purposes, to:

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activities.
• Conduct risk assessments and take appropriate actions.
• Verify or authenticate the information you provide.
• Perform checks against databases and other sources of information, including criminal background checks.
• Comply with legal obligations, protect the health and safety of our guests.
• Enforce our agreements with third parties.
• Determine eligibility for certain types of bookings, such as Instant Book.
• Comply with the law, respond to legal requests, prevent harm, and protect our rights.

2.3. Providing, Personalizing, Measuring, and Improving Advertising and Marketing. We may process this information for purposes such as:

• Sending you promotional messages, marketing, advertisements, and other information based on your preferences and social media advertising through social media platforms.
• Personalizing, measuring, and improving our advertising.
• Administering referral, reward, survey, sweepstakes, contest, or other promotional programs sponsored or managed by MyPlaces or its external business partners.
• Analyzing characteristics and preferences to send promotional messages, marketing information, advertisements, and other information we believe may interest you.
• Inviting you to relevant events and opportunities.
• Sending you, with your consent, promotional messages, marketing information, advertisements, and other information that may interest you based on your preferences.

2.4. Analyzing and Sharing Communications.

We may review, inspect, or analyze your communications on the MyPlaces Platform for reasons described in the “How We Use Collected Information” section of this policy, including fraud prevention, security investigations, risk assessment, regulatory compliance, product development, studies, analysis, compliance with our Privacy Policy. For instance, as part of our fraud prevention efforts, we inspect and analyze messages to remove contact information and references to other websites, and subject to applicable law, we inspect and analyze all images users upload to the MyPlaces Platform in message threads, profiles, ads, and experiences for certain illegal or inappropriate activities (such as evidence of child exploitation) in order to identify and report content violations to the relevant authorities. In some cases, we’ll also inspect, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods when feasible. However, at times, we may need to manually review certain communications, such as fraud investigations and customer service, or evaluate and improve the functionality of these automated tools. We won’t review, inspect, or analyze your communications to send you third-party marketing messages, and we won’t sell reviews or analyses of these communications. We may also share your communications as described in the “Sharing and Disclosure of Information” section.

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

• Detect and prevent money laundering, fraud, abuse, and security incidents, and perform risk assessments.
• Comply with legal and regulatory obligations (such as anti-money laundering regulations and sanctions enforcement).
• Enforce payment terms and other payment policies.
• Provide and improve Payment Services.

3. SHARING AND DISCLOSURE OF INFORMATION

3.1. Information Shared with Your Consent or at Your Request.

Where permitted by applicable law, we may use certain information such as your email address, de-identify it, and share it with social media platforms to generate leads, drive traffic to MyPlaces, or promote our products and services.

3.2. Information You Post in Profiles, Listings, and Other Public Information.

You can allow certain information to be visible publicly, such as:

• Your public profile page, including your profile picture, your name (or initials where applicable), a description, and your city.
• Listing pages that contain information like the approximate or exact location of the accommodation or experience, date availability, profile picture, aggregated demand information (such as page visits over a period of time), and additional data you choose to share.
• Reviews, ratings, and other public comments.
• Content in a community or discussion forum, blog, or social media post.

We may display parts of your public profile and other content you make available publicly on MyPlaces on third-party websites, platforms, and applications.

The information you publicly share on the MyPlaces Platform may be indexed through third-party search engines. In some cases, you may disable this feature in your account settings.

3.3. Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protecting Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, authorized third parties, or other members, to the extent required or permitted by law, or when disclosure is reasonably necessary to: (i) comply with our legal obligations; (ii) respond to a valid legal request (such as a subpoena or court order) or to address claims against MyPlaces; (iii) respond to a valid legal request related to a criminal investigation to address allegedly illegal activity, or respond to other activity that may expose us, you, or any other user to legal or regulatory liability; (v) protect the rights, property, or personal safety of MyPlaces, its employees, members, or the public.

Where appropriate and permitted by law, we may notify members about legal requests unless: (i) notifying is prohibited by the legal process itself, by a received court order, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, would create a risk of injury or physical harm to an individual or group, would create or increase a risk of fraud or harm to MyPlaces, our members, or would expose MyPlaces to a claim for obstructing justice.

When required or allowed by law, in accordance with applicable law, we may disclose guest information to tax authorities or other governmental agencies to determine whether they are adequately fulfilling their corresponding tax obligations. Corresponding tax obligations include MyPlaces’ tax obligations on its service fees, the facilitation of accommodation taxes, and tax withholdings. Disclosable information may include, but is not limited to, guest names, accommodation addresses, tax identification or registration numbers, birthdates and/or contact information, tax zone code numbers, billing information, transaction dates and amounts, number of nights and booked guests, gross and net booking values and amounts collected by MyPlaces on behalf of guests, to the extent known by MyPlaces.

3.4. Programs with Administrators and Hosts.

We may share guest personal information with property owners, management companies, homeowner associations, landlords, and/or property managers (“Building Management”) as needed, such as reservation information and information related to complying with applicable laws, in order to facilitate programs with building management. For example, guest personal information and reservations, including guest contact information, may be shared with building management, the complex, or community where the host lives or where the accommodation is located, to facilitate host services, compliance with applicable laws, security, billing, and other services.

3.5. Business Transfers.

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

4. YOUR RIGHTS

You can exercise any of the rights described in this section in accordance with applicable law. Please note that we may ask you to verify your identity before processing your request.

4.1. Managing Your Information.

You can access certain personal information and update it through your account settings. If you connect your MyPlaces account to a third-party service like Facebook or Google, you can modify your settings and unlink from that service within your account settings. You are responsible for keeping your personal information up to date.

4.2. Access to Data and Portability.

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

4.3. Data Deletion.

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

• We may retain your personal information as necessary for our legitimate business interests, such as preventing money laundering, detecting and preventing fraud, and enhancing security. For example, if we suspend a MyPlaces account for fraud or security reasons, we may retain information from that account to prevent that member from opening a new MyPlaces account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, MyPlaces may retain your information to comply with tax, legal, and auditing obligations.
• Information you shared with others (e.g., Reviews, forum posts) may remain publicly visible on MyPlaces, even after you cancel your MyPlaces account.
• Because we take steps to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period.

5. SECURITY

While no organization can guarantee perfect security, we continuously implement and update security measures, administrative, technical, and physical, to protect your information from unauthorized or unlawful access, loss, destruction, or alteration.

6. MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, in accordance with applicable law. If we do, we will post the modified Privacy Policy and update the “Last Updated” date at the top. In case of significant changes, we will also communicate the modifications via email at least thirty (30) days prior to the effective date. If you do not agree with the modified Privacy Policy, you can cancel your account. If you do not cancel your account before the effective date of the modified Privacy Policy, any access or use of the MyPlaces Platform you perform from then on will indicate your acceptance of it.

7. CONTACT INFORMATION AND RESPONSIBLE ENTITIES OF MYPLACES

If you have questions or complaints about this Privacy Policy or the treatment of personal information by MyPlaces, you can directly contact the Superintendency of Industry and Commerce, accessible through the address www.sic.gov.co; you can also email us at info@myplaces.com or contact us via WhatsApp at 302 252 36 09. For payment-related matters, you can contact us through the aforementioned channels (WhatsApp and/or email).

8. PRIVACY SUPPLEMENT FOR COLOMBIA

Responsible Party Identification

Payment services for all activities: MyPlaces (Contact Lines)

All other activities: MyPlaces

Processing of Sensitive Data

MyPlaces may access and process sensitive data in accordance with applicable law and must obtain explicit and informed consent before such access and processing, where necessary. By accepting the MyPlaces Privacy Policy, this Supplement, you acknowledge that MyPlaces informs you of the discretionary nature of providing us with sensitive data unless required or permitted by applicable law. Sensitive data includes, among others, data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, social affiliations, sexual life, health, or biometric data.

Processing of Minors’ Data

According to our privacy policy, registration is only allowed for legal entities, associations, and natural persons over 18 years of age.

9. Your Rights

You have rights as established in the Privacy Policy, the Supplement, and the following, subject to applicable law:

• Free access to personal data processed by the responsible party and
• Request proof of the authorization granted to the responsible party unless such authorization is not required as a requirement for data processing, in accordance with Article 10 of Law 1581 of 2012 (or the legal provisions that modify it).

Procedure to Exercise Your Rights

To exercise your rights and send inquiries, please email pqrs@myplaces.co or info@myplaces.co