Campable Privacy Policy

Campable Limited (hereinafter referred to as "Campable", "we", "us" or "our") operates a platform and community marketplace that helps people create, list, host, discover, book and use overnight camp sites and experiences around the world, whether through our website or our mobile applications (“Platform”).

This Privacy Policy is intended to inform you about how we treat Personal Information that we collect and process about you while you access and use our Platform. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform to you, and you should stop accessing the Platform and deactivate your Campable account.

1. DEFINITIONS

Where the definition of a term does not appear in this Privacy Policy (such as “Guest”, “Host” etc.), it shall be given its definition as outlined in our Terms and Conditions

“Aggregated information” means information about all of our users or specific groups or categories of users that we combine together and which is anonymous and does not include the users’ Personal Information.

"Data Controller" means Campable, the company responsible for the use of and processing of Personal Information.

"Personal Information" means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

1. HOW DO WE COLLECT INFORMATION?

a. Information that you give us

We receive, store and process information that you make available to us when accessing or using our Platform, such as your name, email, telephone number, home address, demographic information (such as postal code), photos, or payment information (such as account or credit card number). The types of Personal Information we collect will vary depending on your use of the features of the Platform. We collect this information from you so that you are able to use our services and products via the Platform. If you do not provide us with all information requested, we may not be able to provide you with the services and products you have requested.

So that you can use our services and products, we collect information directly from you when you:

• fill in any form on the Platform, such as when you register or update the details of your user account;

• access or use the Platform, such as to search for or host a site, make or accept bookings, pay for overnight stays, enter your bank account number so you can be paid for hosting travellers, book or pay for any associated services that may be available, post comments or reviews, or communicate with other users;

• link your account on a third party site (e.g. Facebook) to your Campable account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you;

• use WiFi services provided by us, or purchase mobile data services from us; and

• communicate with Campable staff.

b. Information we collect from your use of the Platform

We also collect information from you indirectly when you use our Platform so that we can provide effective service and products. We collect information from you indirectly as follows:

• Mobile Data- When you use our mobile applications (including mobile data provision) we may receive, store and process different types of information about your location, including general information (e.g., IP address, post or zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

• Log Data - We may also receive, store and process log data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Campable or logged in to your Campable account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.

• Cookies – Campable uses cookies and other similar technologies on the Platform. When you access or use the Platform, you will provide or make available certain information to us and third parties. Please see our “Cookie Policy” for further details about how we may collect Personal Information through cookies.

• Tracking Technologies - We may, either directly or through third parties and individuals we engage to provide services to us, track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform. We may also, either directly or through third parties and individuals we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and third party websites.

• Third Party Social Plugins - Our Platform may use social plugins which are provided and operated by third party websites, such as Facebook’s Like Button. This means that you may send to the third party website the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged into your account with the third party, then the third party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the third party. Please refer to the third party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.

1. HOW CAMPABLE USES AND PROCESSES THE INFORMATION WE COLLECT FROM YOU

We use and process information about you for the following general purposes:

• to enable you to access and use the Platform;

• to operate, protect, improve and optimize the Platform, Campable’s business, and our users’ experience, such as to perform analytics, conduct research, and for advertising and marketing;

• to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your site listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;

• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

• with your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information sent on behalf of our business partners that we think you may find interesting. You will be able to unsubscribe or opt-out from receiving these communications by following instructions included in each of the relevant communications;

• to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Campable or our business partners;

• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

• to assist you if you have any problems with a Host, Site, Guest, or other Traveller.

1. HOW CAMPABLE USES AND PROCESSES USER COMMUNICATIONS

We may review, scan, or analyze your communications with other users exchanged via the 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, the Platform may scan and analyze messages to mask contact information and references to other websites. This helps to prevent fraudulent actors from asking Guests to send them money outside of the Platform, such as by bank transfer or other money transfer methods. We may also scan, review or analyse messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug product offerings.

We will not review, scan, or analyze your communications for sending third party marketing messages to you. We will also not sell these reviews or analyses of communications to third parties. We will also use automated methods to carry out these reviews or analyses where reasonably possible. However, from time to time we may have to manually review some communications. By using the Platform, you consent that Campable, in its sole discretion, may review, scan, analyze, and store your communications, whether done manually or through automated means.

1. WHEN CAMPABLE DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM

IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries

We may transfer, store, use and process your information, including any Personal Information, to countries outside of the European Economic Area ("EEA") including the United States. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

a. Your Personal Information may be disclosed to other users of the Platform and the general public, as follows:

• Parts of your public profile page that contain some Personal Information may be displayed in other parts of the Platform to other users for marketing purposes.

• Your public listing page will always include some minimum information such as the city and neighborhood where the Site is located, photos and images provided by you (including images of property and public profile images), and your responsiveness and performance as a Platform user. Parts of your public listing page may be displayed in other parts of the Platform to other users for marketing purposes. The Platform may also display the Site’s geographic location on a map, such that a user can see the general area of the Site.

• The Platform allows your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages will be indexed by search engines and may be published as search results. This option is enabled by default, and you may opt out of this feature by changing your settings on the Platform. If you change your settings or the information on your public profile or public listing pages, third-party search engines may not update their databases quickly or at all. We do not control the practices of third-party search engines, and they may use caches containing outdated information, including any information indexed by the search engine before you change your settings or the information on your public profile or public listing pages.

• When you submit a request to book a Site, some of your details will become visible to the Host. You agree to be contacted by the Host or Campable by phone, email or via the platform when submitting your request and the Host (or Campable) decides to do so. By making or receiving a booking, or using services on the platform, you give permission for your contact details to be shared. In any other case, we will not share your phone number unless you have granted specific permission.

• As a Host, when you receive a booking, you agree to be contacted by the Guest or Campable via the platform, and when the Guest or Campable decides to do so.

• When your request to book a Site is accepted by the Platform, or when you accept a Guest’s request to book your Site, we will disclose some of your Personal Information to the Site Owner or Guest (such as vehicle registration details). However, your billing information will never be shared with another user.

• When a Guest uses your Site or when you use a Site, we will ask you to review the Guest or the Site. If you choose to provide a review, your review may be public on the Platform.

b. Your Personal Information may be disclosed to third parties, as follows:

• You may link your account on a third party social networking site to your Campable account. We refer to a person’s contacts on these third party sites as “Friends”. When you create this linkage:

• some of the information you provide to us from the linking of your accounts may be published on your Campable account profile;
• your activities on the Platform may be displayed to your Friends on the Platform and/or that third party site;
• other Campable 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 Campable 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 site(s); and
• 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.

The publication and display of information that you provide to Campable through this linkage is subject to your settings and authorizations on the Platform and the third party site.

• We may distribute parts of the Platform (including your listing) for display on sites operated by Campable’s business partners, using technologies such as HTML widgets. If and when your listings are displayed on a partner’s site, information from your public profile page may also be displayed.

• We may allow our related entities such as our parent company, subsidiaries, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we have to protect your Personal Information under this Privacy Policy.

• We may also engage third parties and individuals, who may be located outside of New Zealand, to provide services to us, including services to help verify your identification or to conduct checks against databases such as public government databases (where legally allowed). We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. Where we transfer, store and process your Personal Information outside of New Zealand we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

• You acknowledge, consent and agree that Campable may access, preserve and disclose your account information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against Campable; (b) to comply with legal process (for example, subpoenas and warrants); (c) to enforce and administer our agreements with users, such as the Terms of Service; (d) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (e) to protect the rights, property or personal safety of Campable, its users or members of the public. We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless prohibited by law or by the government request, or if doing so would be futile or ineffective.

• We may also publish, disclose and use Aggregated Information and non-personal information for industry analysis, demographic profiling, marketing and advertising, and other business purposes.

1. BUSINESS RESTRUCTURE

If Campable undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. In this event, we will notify you if your Personal Information is transferred and becomes subject to a different privacy policy.

1. YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by Campable. Campable does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use and Google’s privacy policy, as may be amended by Google from time to time.

1. CAMPABLE’S INTERACTIVE AREAS

Campable is not liable for any information posted in interactive areas. Campable may provide interactive areas such as reviews and discussion forums to enhance the user experience and build a healthy community around our website's products and services. You acknowledge that should you participate in such interactive areas, the information you voluntarily post about yourself and third parties in such areas might be accessed, collected and used by third parties outside of Campable. WE RECOMMEND THAT YOU DO NOT POST ANY PERSONALLY IDENTIFIABLE INFORMATION SUCH AS YOUR EMAIL ADDRESS IN OUR PUBLIC AREAS. You may not post any defamatory, obscene, slanderous, or otherwise illegal material, or any material which infringes any third-party copyrights or other intellectual property rights on any interactive areas. Violators may have their accounts terminated and legal action may be taken against them. Although we employ advanced security technology, it cannot guarantee complete security in personal websites or password-protected areas, and Campable will not be held liable for any user's or other visitor's disclosure of personal information on Campable or any other website or Platform operated by us.

1. SPECIAL FEATURES AND PROGRAMS

The Platform may provide a referral service that allows you to invite your friends and contacts to use the Platform. The Platform may allow your friends and contacts to write a reference for you, to be published on the Platform.

We may integrate the Platform with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Campable does not collect or retain the contact information that is used to send them.

You may also send invitation/request emails via the Platform itself, in which case we will ask you for the email addresses to send these emails to. You can type in the email addresses manually, or you can request Campable to import the contacts in your email account address book(s). In both cases, we will use the information sent to us for the sole purpose of sending your friends and contacts a one-time email, inviting him or her to visit the Platform or to write a reference for you. With respect to referrals, we will also store the email addresses of your invitees to track if your friend joins Campable in response to your referral.

If you request us to import your contacts, we will collect, but not store, the username and password for the email account you wish to import your contacts from. We will use this information only for the purpose of importing your contacts.

If you are allowed to join Campable’s referral Program and you sign up for it, you will be requried to provide us with certain Personal Information to enable us to provide the Referral Program to you.

1. HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR CAMPABLE ACCOUNT

You may review, update or correct the Personal Information in your Campable account by logging in to your account. If you would like to cancel your Campable account entirely, you can do so by contacting support@campable.com or writing a letter to the Data Protection Compliance Office at:

Campable Limited 14 McDonald Street Sandringham Auckland New Zealand

Please also note that any reviews, forum postings and similar materials posted by you may continue to be publicly available on the Platform in association with your first name, even after your Campable account is cancelled.

1. KEEPING YOUR PERSONAL INFORMATION SECURE

We will use best endeavours to protect your Personal Information. We have implemented reasonable administrative, technical, and physical security measures to protect your Personal Information against the unauthorized access, destruction or alteration of your information. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.

Your Personal Information will only be held for as long as necessary to fulfil our obligations to you, to protect our legal interests, to comply with a law or as otherwise stated when we collect your information.

1. YOUR RIGHTS TO REVIEW AND UPDATE INFORMATION

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 the request in writing. There may be a charge to access your personal data (which will not exceed $20). We may also request proof of identification to verify your access request. All requests should be addressed to our Data Protection Compliance Officer, Campable Limited, 14 McDonald Street, Sandringham, Auckland, New Zealand.

We endeavor to keep your information accurate, complete and up to date. If your Personal Information that we hold is inaccurate, please let us know and we will make the necessary amendments, erase or block the relevant information and notify you within 40 days of your request that the relevant action has been taken.

You may also request the erasure of your personal data if you believe it is no longer necessary for us to retain your Personal Information or that we are otherwise in breach of relevant data protection legislation. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. All requests should be addressed to our Data Protection Compliance Officer, Campable Limited, 14 McDonald Street, Sandringham, Auckland, New Zealand. There is no charge for making such a request.

1. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy at any time. If we do so, the updated policy will be displayed on our website at www.campable.com and we will also update the “Last Updated Date” at the top of this Privacy Policy or we will email it to you (at our discretion). If we let you know of changes to the Privacy Policy through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It is important that you review the changed Privacy Policy. If you do not wish to agree to the updated Privacy Policy, then we will not be able to continue giving you access to the Platform, and your only option will be to stop accessing the Platform and deactivate your Campable account.

1. GOT FEEDBACK?

Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at support@campable.com.

COOKIE POLICY

Campable uses "cookies" in conjunction with the Platform to obtain information which then allows us to personalise content and ads. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Platform to recognize your browser, while another could store your preferences and other information.

Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies.

USES FOR CAMPABLE COOKIES

Campable uses cookies for a number of purposes, including:

• to enable, facilitate and streamline the functioning of the Platform across different webpages and browser sessions.

• to simplify your access to and use of the Platform and make it more seamless.

• to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.

• to show you content (which may include advertisements) that is more relevant to you.

CAMPABLE AND THIRD PARTY COOKIES

We may place cookies on your device via the Platform. Accordingly, our “Privacy Policy” will apply to our treatment of the information we obtain via our cookies.

We may also allow certain third parties to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, third parties may also place cookies on your device for advertising purposes.

There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”.

Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

USES FOR THIRD PARTY COOKIES

Our partners’ cookies are intended to obtain information to help them provide services to Campable. For example, third parties and individuals we engage to provide services to us may track your behavior on our Platform to market and advertise Campable listings or services to you on the Platform and third party websites. Third parties that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or third party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Platform – it just will not be tailored to your interests.

In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the Campable mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.

OTHER TECHNOLOGIES

The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

DISABLING COOKIES

The first time you visit our website we will ask you to consent to Campable’s use of cookies and monitoring tools. You can also modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar.

If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

CHANGES TO THIS COOKIE POLICY

We can change this Cookie Policy at any time. If we do so, the updated policy will be displayed on our website at www.campable.com and we will also update the “Last Updated Date” at the top of this Cookie Policy or we will email it to you (at our discretion).

It is important that you review the changed Cookie Policy. If you do not wish to agree to the updated Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and deactivate your Campable account.