- When you provide Personal Information to us via the Platform, Spareroom, Inc ("we", "us" "our"), and in certain instances, as further explained in clause 2.9 below, the applicable third party, will be the data controller in respect of any such Personal Information you submit to us or which we collect from you when you use our Platform. “Personal Information” means any information relating to a living individual by which such individual may be personally identified. Personal Information may include first and last name, e-mail address, mailing address, telephone number, social security number and other identifying information. We are a company registered in Delaware with file number 6113758 – our trading address is at 234 5th Avenue, #413, New York, NY, 10001. For more information see 'about us'.
234 5th Avenue, #413
Phone: 1 877 834 2909
The information we collect from you
- We collect the information you provide to us when you register on the Platform, including your name, gender, email address and search preferences. We use this information to create a User account for you on our Platform and to provide our services to you, including publishing your adverts on the Platform and facilitating introductions with other Users of our Platform. However, we will not share your email address with other Users of our Platform unless you have specifically chosen to disclose it. Where you have not opted out of receiving them, we will also use this information to send you email notifications of other Users’ adverts matching your search preferences and/or newsletters about our own services we think may be of interest to you from time to time. We will not sell or rent any of this information to any third parties nor send you any third party marketing communications unless you have specifically opted in to receiving them.
- Any information you include in any advert you post on our Platform will be collected by us and stored on our servers for the purposes of making the Platform, and the content contained within it, available to our users, and to enable our users to search for and respond to adverts on the Platform.
- In the event you are asked to submit any sensitive Personal Information as part of the process for posting adverts on the Platform you’ll be asked to tick a box to demonstrate your consent to our collecting and storing that information and to us making that information available to other users through the Platform.
- We may collect any information contained in correspondence between you and us. For example, if you contact us we may keep a record of that correspondence. We may also ask you for information when you report a problem with our Platform or any content or services made available through the Platform.
- We may also collect and store any information contained in communications between yourself and other Users on the Platform, where such communications have taken place via the messaging system of our Platform. We do not routinely monitor all communications but we may use software to track communications and we reserve the right to monitor them in order to investigate any suspected breach of our terms and conditions, illegal behavior or any other misuse of our service or for any other reasonable reason as determined by us from time to time.
- We may also collect other information about your activity on the Platform that is specific to your User account, such as your search history, your search and account preferences and adverts you have posted. We use this information to improve your Platform experience and to send you content and messages that are relevant to you. We may use tracking technologies including cookies to collect this information.
- If you choose to register and log in to our Platform using your Facebook profile you are agreeing to share some of the information contained in your Facebook profile with us, such as your age, gender, friends list, your education and work history, your email address and your interests. We may use this information to improve your user experience on the Platform and to match you with other users of the Platform who you are already friends with on Facebook, or who have similar interests or histories to you. If at any time you would like to request that the information we have received from Facebook is deleted, then please contact us using the contact details that are set out in section 1.2 above.
- We may also receive Personal Information about you from various third parties. For example, we may receive details such as your mobile number, name, address, email address, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details from your wireless operator via our third party ID verification service provider.
- If you are a journalist or social influencer, we may receive Personal Information about you, such as your name, email address, job title, place of work, phone number, and social media information from third party providers of contact databases relating to journalists and social influencers. We may use this information to provide you with information that may be of interest to you or relevant to you.
Use of your information
- to ensure that content from the Platform is presented in the most effective manner for you and for the device you’re using;
- to send you alerts about adverts that match your search preferences and to let you know when other users of the Platform have expressed an interest in any adverts you have posted to the Platform;
- to provide you with other marketing communications by post and/or electronic means (such as email, SMS and/or MMS) about our products, services, contests and sweepstakes, events, special discounts and offers, which you have requested to be sent or which we feel may interest you, where you have not opted out of being contacted for such purposes;
- to send you other general (non-marketing) commercial communications, such as information about the Platform and services provided to you by us at that time;
- to provide customer service in relation to your use of the Platform, to contact you, to deal with enquiries and complaints relating to the use of the Platform and to notify you about changes to our services;
- to develop, improve and personalise our Platform in order to improve your experience. We share data with the organisations listed below, which will never share your data with anyone else:
- Firebase & Fabric - to assist with reducing iOS and Android application crashes and monitoring
- AppsFlyer - Application usage information and advertising campaign attribution
- HotJar - to improve website user experience
- Facebook Analytics - to help us understand our users' usage and behaviour across our platforms
- to provide third parties with statistical information about our users – this information will not be able to be used to identify any individual user.
Disclosure of your information
- We may disclose your Personal Information to:
- a third party, if you have chosen to log on to our Platform by using your profile and account details from that third party’s own website or mobile application, such as Facebook;
- any third party who intends to publish any comments or reviews you’ve written about our Platform in any medium, including on third party websites or mobile applications, so your comments and reviews can be verified by that third party;
- any third party to whom disclosure is necessary to enable us to provide you with any services or products that you have requested through the Platform;
- comply with any court order, law, or legal process, including to respond to any government, regulatory or administrative request and to any person to whom disclosure is necessary or appropriate to enable us to enforce our legal rights, or to protect the rights, property or safety of Spareroom, Inc, any company within the same corporate group as Spareroom, Inc or our customers or employees or others;
- any acquirer or potential acquirer of all, or substantially all, of the share capital or assets of Spareroom, Inc; and/or
- other companies within the same corporate group as Spareroom, Inc.
- You should note that the public elements of the Platform, including any adverts you post on the Platform, will be visible to other users of the Platform anywhere in the world. You should therefore be careful when submitting information about yourself and only submit information you’re happy to be publicly available.
Cookies and other tracking technologies
- Some cookies we use are necessary for our Platform to function properly and to enable you to move around the Platform and use its features. In addition we also use so called "functional" cookies, which allow our Platform to remember choices you’ve made in relation to the Platform, so as to provide a more personalized and enhanced user experience. Examples of the functional cookies we use on the site, and the information we collect through the use of those cookies, include those that remember details about your account preferences, including your password and login details, your search history and adverts you have posted to the Platform, the types of alerts and newsletters you have opted to receive and the types of adverts you are interested in hearing about.
- As mentioned above, we may also use an analytics service provider, such as Google Analytics, for website and mobile application traffic analysis and reporting. Analytics service providers generate statistical and other information about website and mobile application use by means of tracking technologies including cookies that are stored on users' devices. The information generated relating to the Platform may be used to create reports about the use of the Platform - the analytics service provider will store this information.
- In addition, we are also using the following types of cookies/tracking technologies on the Platform:
- Google AdWords
- Using Google AdWords code, we are able to see which pages helped lead to registering and, where applicable, upgrading. This allows us to make better use of our paid search budget on Google. You can also choose to opt-out of AdWords remarketing here.
- We use Google Analytics remarketing codes to log when users view specific pages or take specific actions on the Platform. This allows us to provide targeted advertising in the future when you browse other websites.
- Facebook Pixel
- We use the Facebook Pixel to understand how people we advertize to on Facebook, and Facebook partners, interact with our site. The Facebook Pixel also allows us to identify groups of Facebook users who are similar to groups of users of the Platform and advertize our services to them. Guidance on how to opt out is available here.
- Google Analytics Demographics and Interest Reporting
- These help us better understand who our users are so we can make content on other channels, such as YouTube, more relevant. You can choose to opt out of these cookies here.
Turning off cookies or other tracking technologies
- If you don’t want us to install cookies on your devices for these purposes, you can change the settings on your internet browser to reject cookies. All modern browsers allow you to change your cookie settings. These settings will typically be found in the 'options' or 'preferences' menu of your browser. In order to understand these settings the following links may be helpful, otherwise you should use the 'Help' option in your browser for more details:
- How We Respond to Do Not Track Signals
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Platform. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.
All payment for any products or services offered through our Platform, including for any adverts or Early Bird access, are made via a secure server provided by our third party payment processors, currently Stripe, WorldPay and Paypal. We will not collect, store or process any credit card or other payment information on our own servers.
Security and data retention
- We employ appropriate technological and operational security measures to protect against any unauthorized access to or unlawful processing of any Personal Information about you that we hold. We will retain your information for the period as defined in our data retention policy unless a longer retention period is required or permitted by law. For the avoidance of doubt, save where your account has been closed for a breach, Personal Information associated with any account on our site will be retained for a maximum period of 12 months following an account closure. We reserve the right to access this data during this period for the purposes of fraud prevention and/or to investigate any complaints we may receive. In cases where a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the information will be blocked instead of deleted.
- Data transmission over the internet is inherently insecure. Although we employ appropriate technological and organizational security measures to protect your data, including your Personal Information, we cannot guarantee the security of any data sent over the internet.
International data transfers
- Our servers are hosted in the U.S., however we collect data from wherever users are situated. The information we collect will therefore be transferred to the US from any other country in which you may be located. Use of the service constitutes consent to the transfer of your Personal Information to the United States.