PRIVACY POLICY

Last updated: September 2022

Overview
Personal data we process
Your rights regarding personal data, customer request
Your options
Protecting personal data
Retention of personal data
Other significant information on personal data and services
Updates to this privacy policy
Applicability of this privacy policy
Dispute resolution
Additional and contact information

ESSENTIAL PROVISIONS

1. OVERVIEW

Infoholders s.r.o. and its subsidiaries (collectively, “Roompire”, “we”, “us”, “our”) value privacy and the personal data we receive from you as a customer. In case you have questions or comments about this Privacy Policy or ways we process personal data, please refer to the contact information at the bottom of this Privacy Policy.

Roompire is a social platform which allows users to share their own content, enjoy the content of other users or do both. Here the users who provide their content are referred to as “Creators”, while the users who consume Creators’ content are referred to as “Fans”. This Privacy Policy describes the methods of collecting and processing the users’ personal data including the information collected via our website located at https://roompire.com, our services offered via our website, related social media (Twitter, Instagram, Facebook, etc.), or other communication means if any (collectively, the “Services”).

Please read the following information to understand how we process and protect your personal data. By using any of our Services and/or voluntarily providing us with personal information, you acknowledge that you have read and accepted the methods described in this Privacy Policy. Some provisions of this Privacy Policy may be revised occasionally, so please check this Privacy Policy recurrently to stay informed.

2. PERSONAL DATA WE PROCESS

We gather information that may directly or indirectly identify, be associated with or relate to a specific customer (hereinafter referred to as “personal data”). Furthermore, we may collect and process non-personal data, which is the data that is not associated with you, to the extent this data relates to personal data.

a. Types of Personal Data We Collect

We may collect the following categories of your personal data:

Identifiers like a real name, alias, ID or passport number, social security number, driver’s licence number, postal address, as well as any other similar identifiers.
Biometric information. Please note: generally we do not collect biometric information. Anyway you may resort to authentication services that we apply and these services may collect biometric information in accordance with their privacy policy. However, these services do not grant us access to this information.
Employment-related data.
Commercial data, such as records of personal property, purchased products or services, etc.
Electronic, visual, audial, or similar information.
Internet or any other network activity data (including, but not limited to, email address, internet protocol address, account name, browsing and\or search history, etc.)

We do not gather personal data other than of the categories above. In case we collect other types of personal data, we will inform you on this at or prior to the time of collection.

b. How Your Personal Data is Used

We gather and process your personal data for the following business purposes:

Developing, maintaining, providing and enhancing the Services and your user experience including customer service, identity verification, payments or transactions processing, etc.
Communicating and sharing information with you via email or the Services.
Resolving security problems, ensuring protection against malicious or fraudulent activities.
Rectifying existing or possible errors in the functionality of the Services.
Maintaining and improving safety and top quality of the provided Services.
Bringing into effect our Terms of Service and other policies.
Complying with applicable laws and regulations of related law enforcement institutions.
Protecting the rights and interests as well as security of our users and third parties to the extent this Privacy Policy allows.

We do not use the personal data we collected for any other incompatible or unrelated purposes without informing you and receiving your consent.

c. Sources and Recipients of Your Personal Data

We use the following sources for obtaining your personal data:

Directly from you.
When you provide these data to us when creating or using your personal account.
Indirectly from you.
As a result of your usage of your personal account and our Services.
From service providers.

We share your personal data with the following third parties:

Our affiliated parties.
Our service providers.
Legal institutions, agencies and regulators under requirement of those to protect and fulfil our rights and interests as well as those of our users and other third parties involved.

d. Legal Basis for Processing Data

We process your personal data taking into account the following legal bases:

Fulfilment of the Contract. We process various personal data within the contract concluded as a result of your use of our Services.
Legal Interests. We may process your personal data to meet our legal interests that may include but not be limited to observation of applicable laws and regulations, prosecution, investigation and enforcement of our Terms of Service; protection of our, our users' or any third party’s rights and security as well as fulfilment of our rights and obligations by legal process.

3. YOUR RIGHTS REGARDING PERSONAL DATA, CUSTOMER REQUEST

As a customer you have specific rights related to collecting and processing of personal data. You may invoke these rights in accordance with the provisions below or via contacting us by the information at the bottom of this Privacy Policy.

Your rights may include the right:

to be aware of the sources, purposes and agents of processing.
to know the parties your personal data has been shared with.
to know what personal data we collect and process.
to access and modify your personal data.
to request a copy of personal data we have collected about you in the past 12 months.
to request deletion of your personal data we have collected about you. Please note that we reserve the right to deny your request or retain some elements of your personal data if this is necessary for:
1. fulfilling of our commitments and providing the Services for you and other users, including ensuring security and debugging of existing or possible errors in the functionality of the Services;
2. protecting of our rights as well as rights of our users and third parties, including but not limited to the right of free speech;
3. engaging in scientific, historical, or statistical research in the public interest and under all other applicable ethic charters and privacy laws, in case the deletion of the information requested by you may inhibit the achievement of such research;
4. complying with applicable laws and regulations;
5. any other legally permitted internal use to the extent the context in which you provided us these data allows.
to opt-in to the sale or opt-out of the sale of your personal data if you wish to. Please note, that we do not sell your personal data.
to receive non-discriminatory treatment from us unless otherwise is required by applicable laws and regulations.
to revoke your consent if the processing was based on it.
to submit a complaint to a supervisory authority in the jurisdiction of your residence or the location of the alleged rights violation.

You may invoke any of the above mentioned rights if you have registered your personal account with us. If you are unable to add, modify or delete your personal data from your account, please contact us.

Only you, or your representative authorized by you to act on your behalf, may submit a request regarding your personal data at support@roompire.com twice within a 12-month period. This request must include:

accurate and sufficient information about the requester (you or your authorized representative);
proof that you granted your representative a signed permission to submit a request on your behalf;
details of your request that allow us to properly understand and respond in a proper manner to your request.

We may deny your request if we cannot verify your identity or identity of your representative, or have reason to believe that the request is fraudulent.

We will process and respond to a verifiable request within forty-five (45) days since its receipt. In case more time is required for processing of the request, we will inform you on the grounds for this and the period of time necessary for processing. Our response may also include the reasons for denial in processing your request if any. Processing of a customer request is free of charge, but we will inform you of additional fees if any occurred during the processing of your request.

a. Accessing and Modifying Your Personal Data

We do our best to maintain integrity and accuracy of the personal data obtained from you and make quickest possible corrections in these data if you inform us on any. We must ensure that all the data you share with us via your account are exact and complete. Therefore, please make sure that the data you enter or modify in your account meet these requirements before sharing it with us. In accordance with related applicable laws you may request access to, review or modify the personal data you have shared with us. Please contact us using the information at the bottom of this Privacy Policy if you wish to do so. However, we reserve the right to deny that access in case applicable laws and regulations allow or demand to do so.

4. YOUR OPTIONS

You are provided with some options you may choose regarding specific information we collect and process. You may refuse to provide these data, which, however, may block some of the functionality of the Services.

a. Communication Opt-Out.

You may refuse to receive email notifications from us at any time by following unsubscribe instructions from the received email, by contacting us, or via your account settings.

b. Location Data.

You may prevent or restrict transferring of your location information via our Services in your device settings.

c. Cookies and Web Tracking.

Please refer to our Cookie Policy for more information.

5. PROTECTING PERSONAL DATA

We apply reasonable and appropriate physical and technical means and practices to maintain and ensure security in our systems and services as well as protect the privacy and integrity of collected personal data. Those means and practices include backup storages, data encryption, network security measures as well as recurrent testing and improving of these means and practices.

Although we do our best to provide maximum security when processing your personal data, we can not guarantee that these protection measures are sufficient.

6. RETENTION OF PERSONAL DATA

We retain personal data for a six (6) months period after a user closes or deletes their account. Some elements of personal data may require a longer retention period for reasons that may include but are not limited to compliance with applicable laws and regulations, processing of personal data, protection of our, our users’ and third parties’ rights and interests, maintenance of our Services and other reasons mentioned above. Under some applicable laws, we are obliged to retain certain financial information for up to seven (7) years.

7. OTHER SIGNIFICANT INFORMATION ON PERSONAL DATA AND SERVICES

a. Identity Verification.

We apply mandatory identity checks for Creators to make sure that we do not provide our Services or collect personal data from anyone under age of 18 or using false identity and optional identity checks for Fans. These checks may include practices and services that require provision of sufficient personal information as well as means to verify this information. By proceeding with use of our Services you admit that you are aged 18 or older.

b. Payment Data.

Payment operations performed by Fans are processed by our third party payment providers. In the course of processing of these operations the payment providers may require your payment card number, expiration date, and security code as well as other data that are processed in accordance with their privacy policy and terms of service. We do not obtain your full payment card related data.

c. Third-Party Websites and Services.

We may provide links to any third-party websites and services (including but not limited to our affiliated parties and service providers). As soon as you access these third parties, you abandon the scope of our Services and come under the privacy policy and terms of use of those third parties. This means that we are not responsible for security and privacy means applied to those third parties and you make use of those third parties’ services at your own risk. Please note that this Privacy Policy does not apply to any third-party services.

d. Transfer of Business.

We may transfer some or all of our product, Services or assets to a third party by means of acquisition, consolidation, etc. Personal data we collect with our Services may be disclosed to any potential or actual third-party acquirer.

8. UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is to be regarded in priority to all previous information that may have been provided to you about our Services. We reserve the right to modify this Privacy Policy at any time with all the modifications being effective since the time of publication of the updated Privacy Policy. We will resort to all reasonable means to inform you on the crucial changes.

9. APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy is subject to the Terms of Service that define your use of our Services. This Privacy Policy does not apply to any data about you collected by any third-party services or applications associated with our Services. Your personal data collected or processed by those third parties is subject to their own privacy policies, terms and regulations.

10. DISPUTE RESOLUTION

1. The Slovak Republic law governs this agreement and will apply to any claim that may arise or relate to this agreement. The User will also be able to rely on mandatory law and regulations of the country where he or she lives.

2. Any claim related to this agreement must be brought in the courts of the Slovak Republic.

11. ADDITIONAL AND CONTACT INFORMATION

Roompire is a product by Infoholders s.r.o. registered in Slovak Republic with company registration number 51161869 and office register address located at Magurská 37, Banská Bystrica, 974 11, Slovenská republika. Our VAT number is SK2120610932.

If you have any questions or concerns about this Privacy Policy, or would like to gain more information, please contact our support team at support@roompire.com.