Introduction

Your privacy is important to us. We are committed to protecting your personal data.

This privacy policy (together with our Terms of Use and any other documents referred to in it)

• provides information about the personal data we collect, and how and why we collect, store, use and share your personal data; and
• tells you about your rights in relation to your personal data and how to contact us or supervisory authorities if you have a complaint.

‘Personal data’ is any information that can directly or indirectly identify an individual (‘a data subject’).

For the purpose of current data protection laws applicable in the UK, the data controller is My Friends Room Limited, a company registered in England with company number 09631890 and registered address at 160 Park Road, London, England, N8 8JT, t/a MyFriendsRoom or My Friends Room. As a data controller we will comply with all applicable data protection laws.

Should you have concerns about the way we process your data or would like us to stop processing your data please contact contact@myfriendsroom.com.

Information we may collect from you

We will collect the following personal data and other information you generate as a result of interactions with our App or Site from you:

1. Certain information required to register with our App and Site including first and last name, your home address and date of birth together with some basic security information;
2. Your home location and current GPS location are required in order to facilitate a search for other members in that location. Your home location and current GPS location are also required in order to facilitate a search for other members to find you during a location based search. We never share your exact location with other members, we only share the broad locality of the location such as the City. We do not share the distance between members;
3. Details of your property including address, location, type of property and size;
4. Your e-mail address and password;
5. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
6. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); listings you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
7. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our App or Site (including date and time); listings you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
8. Although it is not compulsory to provide this information, if you do not then you cannot register as a Member of our App or Site or make a booking for accommodation with our Hosts or become a Host by listing your space for other Members to book.
9. Billing information such as your credit card number and expiry date will not be collected by us, it will be collected by Stripe.com our payment processor and will not be held on our App or Site.

We do not collect any special categories of personal data (which include sensitive personal information such as details about your race, ethnicity, religious beliefs, political affiliation and sexual orientation).

How we collect your personal data

We collect most of this information from you directly, for example, your name, address, e-mail address, details about payments to and from you and other details of services you have purchased from us when you fill in forms, correspond with us by email, phone, post or otherwise when you:

• create an account on our app or website to comment on our blog posts;;
• purchase services from us;
• subscribe to our e-newsletter
• request marketing, promotional material or information to be sent to you; or
• give us some feedback.

We may also collect information from

• automated technologies, such as cookies which collect technical information about your equipment and browsing activities;
• [publicly accessible sources, such as Companies House];
• providers of technical, payment and delivery services, such as Stripe.com
• analytics providers [such as Google, based outside the EU];
• a third party with your specific consent (e.g. your bank);

Our Social Media Pages

This App and Website contains links to our social media pages on Facebook, Twitter and YouTube.

These third-party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.

Should you visit those social media pages and choose to follow us on Facebook, Twitter, YouTube, we may receive identity, contact or transaction data from the social media providers, including:

• Name;
• Address (email and/or postal);
• Telephone number(s);
• IP address;
• Social media account URL;
• Date of birth; and/or

If we do receive any personal information about you from these third party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent, or it is otherwise lawful for us to do so (e.g. you have previously used our services).

Use of this information

We (MyFriendsRoom) will use this information to:

1. administer your booking;
2. provide your Host with your address when you are making a booking;
3. provide your Host with your contact details and address when you have booked to stay in your space.
4. share details of your property listing with other Members;
5. collect payment of MyFriendsRoom Fees for our Service from you;
6. keep you up to date with your bookings and what’s happening in your MyFriendsRoom social network;
7. make general improvements to our App or Site and the Service we offer;
8. analyse how you are making use of our Site;
9. notify you of certain offers and new products (subject to your right to unsubscribe or opt-out).
10. for location services within our App or Site. We only share your general location. We never share your address except for booking purposes.

Sharing this information

1. Credit or debit card payments will be collected by Stripe.com our payment processor.
2. We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
3. We will not share with any third party the personal information that we obtain about you for the purposes of marketing unless you have provided your specific consent for us to do so and those third parties have agreed to make no independent or further use of that data and to maintain its confidentiality
4. Other than as set out above, we will not disclose any of your personal information without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).

Cookies

1. When you visit our App or Site we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of our Site and helps us to provide you with a more customised service.
2. We use cookies for the following purposes:
   1. Storing details about your app or site preferences (for instance which language you wish to view pages in);
   2. Storing details about any properties you have short-listed;
   3. Enabling our web server to track your session between pages of the app or site and provide a continuity of experience.
   4. You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but certain parts of the App or Site are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.

This information is not used to develop a personal profile of you.

1. When using our App or Site, there are a number of third parties who also need to store cookies for essential running of the app or site. These include but are not limited to:
   1. EuroVPS for the hosting of our site;
   2. Google for the hosting of our app and to enable Interactive Maps, help us with Analytics and provide re-marketing campaigns tailored to your browsing using Google Advertiser Features.

Your rights

1. You have the following rights over the way we process personal data relating to you. We aim to respond as soon as practicable but within one month at the latest. We do not charge a fee to respond to your request:

• to ask for a copy of data we are processing about you and have inaccuracies corrected;
• to ask us to restrict, stop processing, or to delete your personal data;
• to request a machine-readable copy of your personal data, which you can use with another service provider;

To make a request in relation to any of your rights, please email us at contact@myfriendsroom.com

1. Our App or Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.
2. In addition, if you linked to our App or Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Where we store your information

1.  
   1. As part of the services offered to you through the App or Site, the information you provide to us may be transferred to countries outside of the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU or one of our service providers is located in a country outside of the EU. We may also share information between group companies, which may be located in countries worldwide.

Please be aware that destinations outside the EEA to which your information may be transferred may have data protection laws which do not offer the same level of protection for your information as those in force in the EEA. By using our website and submitting your information to us, you agree to the transfer, storing and processing of such information outside the EEA as set out in this privacy policy.

1. If you use the App or Site while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
2. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our app or site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our app or site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Children
We do not knowingly use the App or Website to solicit data from or market to children under the age of 13.

Security

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered if you use our app or website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our App or Website visitors.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of our App or Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept that you provide your information at your own risk.

Retention
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. Once the purpose for which information has been collected has been fulfilled, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Complaints
We hope that we can resolve any query or concern you may raise about our use of your information.  You have the right to make a complaint at any time to the Information Commissioner’s Officer (ICO), the UK Supervisory Authority for data protection issues: https://ico.org.uk/.  We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance at contact@myfriendsroom.com