Last updated: September 26th, 2019
In handling any and all kinds of the personal data DIWERENT aims to adhere to the best practices in the area of data protection and complies with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.
This policy uses certain terms which shall have the following meaning: A “Member” is any person who has registered a DIWERENT account within the Platform, including Hosts and Guests. A “Host” is any person who offers accommodation services (“Host Services”) through listings published on the DIWERENT Platform (“Listings”). A “Guest” is any person who uses or has the intention to use the Hosts Services. “Accommodation” or “Property” means a vacation or other residential property listed through the Platform and/or offered for booking.
All data collected by DIWERENT is stored in secure hosting facilities in Seattle, USA, provided by Hostwings LLC, 12101 Tukwila International Blvd #320, Seattle, WA 98168.
1. Collected information
There are three general categories of information collected by DIWERENT.
1.1. Information provided by you.
The information provided to DIWERENT upon your use of the Platform is collected by us in order to ensure that any agreements or arrangements between you and DIWERENT or you and other Guests/Hosts are performed or executed in a proper way. This is a essential for using the DIWERENT Platform, since otherwise you will not be able to receive the services that you seek to receive.
If acting in a capacity of a Host, certain additional information may be required from you such as your ID or tax ID (where required by applicable law), and other proof of identity in order to verify your personality and comply with applicable laws, rules and requirements.
Communications with DIWERENT
DIWERENT collects information about your communications and any information you provide during your communications with DIWERENT, whether through the Platform or otherwise.
1.2. Information collected during the use of the DIWERENT Platform.
DIWERENT collects information about your use of the Platform, the services you use and the way and circumstances in which you use them. This information can be collected regardless of whether you have signed up for a DIWERENT account. Legal grounds for the use of such information are given below in section 2 hereof.
1.3. Information received from third parties.
DIWERENT may receive certain information about you from the third parties during their use of the Platform or otherwise. Such information may combined with information about you obtained by us through the Platform. DIWERENT does not control, supervise or respond to how any third parties providing your information receive, use, store, collect, transfer or process your personal data. You must request any information regarding the disclosure of your personal information to DIWERENT directly from such third parties.
Third party services. When you use a third party service (e.g., Facebook or Google), to enter or to create your DIWERENT Account, we may collect certain information from these third party services, such as your registration and profile information. This information is controlled by that particular service and can be deleted, changed or restricted by you through adjusting your privacy settings of that service.
When you use the Platform by booking a listed Property or a service, DIWERENT will require the following additional information from you to complete the transaction:
- your debit/credit card details (such as cardholder name, card number and sort code).
Additionally, DIWERENT may permit other kinds of interactions between the Platform and a third party website, service, or other content provider, such as enabling you to “like” or share content to a third party social network service (for example, Facebook). If you choose to “like” or share content, or to otherwise share information from or via the Platform with a third party website or service, that information may be publicly displayed through such third party website or service, and the third party may have access to information about you and your use of the Platform. These features may collect information about your IP address, the page you are visiting on the Platform, and may set a cookie to enable the feature to function properly. Your interactions with third parties through third party services or websites or similar features are governed by the respective privacy policies of those third parties.
2. How the information collected is used
Information about you is collected, stored and processed in order to enable DIWERENT to provide, maintain, improve, and develop the DIWERENT Platform, and to create and maintain a trusted and safe environment.
2.1. DIWERENT’s aim to provide, maintain, improve, and develop the DIWERENT Platform allows us to (i) enable you to access and use the DIWERENT Platform; (ii) contact you regarding your booking requests, listings, the planning of your or your Guests’ stay at the Property, and arrange and manage your bookings whether as a Host or a Guest; (iii) allow you to communicate and make arrangements with other users of the platform; (iv) operate, provide, improve and optimize the DIWERENT Platform and your user experience, by performing constant analytics and monitoring and conducting relevant research; (v) personalize, customize or otherwise improve your experience by, inter alia, making accommodation suggestions, adjusting or ranking search results or showing you ads based on your search or booking history and any preferences you provide to us, where available; (vi) enable you to access and use payment services, including collecting payment on your behalf when you act in a capacity of a Host; (vii) provide customer service and support and constantly work on its improvement; (viii) send you service or support messages, such as security or maintenance alerts, updates and account notifications when necessary.
If you choose to provide us with your contact information it may be stored, used or processed by us in order to: (i) manage your referral invitations; (ii) detect and prevent fraud; and (iii) for any other purpose upon your authorization at the time of collection.
This information is stored and processed for the purpose of us improving the DIWERENT Platform and user experience as well as to ensure proper work of the Platform and performance contracts and arrangements in which you participate.
2.2. DIWERENT’s aim to create and maintain a trusted and safe environment is determined to: (i) detect and prevent fraud, spam, security breaches, abuse of the DIWERENT’s systems and all other harmful activities by third parties; (ii) conduct ongoing or periodic investigations and risk assessments; (iii) ensure that any information provided to DIWERENT by you is valid, true, authentic and up-to-date (for example, verify your personal ID or e-mail provided by you during your registration within the Platform); (iv) compare information provided by you with information contained in third-party databases and other information sources; (v) comply with all our legal obligations; (vi) resolve any disputes with or between any of our users and enforce agreements between third parties and DIWERENT or our users; (vii) enforce our Terms of Service.
2.3. DIWERENT seeks to provide, personalize, evaluate and improve its advertising and marketing on an ongoing basis. In order to do so, we may: (i) send you promotional messages, marketing, advertising, and other information and materials, whether present on the Platform or not, that may be interesting or useful to you, based on your preferences known to us; (ii) improve, personalize and conduct evaluations and investigations with regard to our advertising and marketing strategies; (iii) implement and operate DIWERENT’s or its partners’ referral programs, reward schemes, conduct or quality surveys, organize sweepstakes, contests, or other promotional activities or events in various forms; (iv) profile or categorize your preferences and platform usage based on the information accessible to us in order to send you promotional messages, marketing, advertising and other information that we find may be interesting or useful to you.
3. Sharing and disclosure of information
3.1. Based on your consent or where authorized by Law.
3.2. Sharing between Hosts and Guests.
Notwithstanding the above, DIWERENT does not disclose your billing or payout information to any Members, Platform users, service providers or any third parties, unless required or permitted by the law or where such disclosure is made according to your request.
3.3. Reviews, listings, and other public information.
The DIWERENT Platform publishes or allows publishing information that may be accessible to the general public, including:
It is possible that information shared publicly on the DIWERENT Platform may be indexed through automated or manual search engines operated by the third parties. In some cases you may, by means of adjusting your browser or otherwise, restrict indexation of such information by the search engines or demand them to delete or update your information or to cease such indexation. However, you should note that some traces of such information already collected and indexed may still be left in their systems or databases. DIWERENT does not control, supervise or respond to how any third party search engines find, collect, index, handle or store such information.
3.4. Service providers.
DIWERENT ensures adequate provision of services offered by the DIWERENT Platform through engaging multiple third-party service providers, who help us verify or authenticate our users’ identities; compare information in our possession with information contained in third-party databases and other information sources; perform background checks, risk assessment and participate in prevention of fraud, misuse or other misconduct by the third parties; provide various types of services such as customer support, advertising and marketing, payment services, etc. These third-party service providers only receive limited parts of your information necessary for adequate provision of their services to you.
3.5. Tax Authorities.
Legislation of some jurisdictions may require DIWERENT to collect and remit certain taxes, such as occupancy taxes, residence taxes, room taxes, etc. Where such requirement takes place, you, whether as a Host or a Guest, expressly grant DIWERENT permission to disclose any part of your information relating to your transactions, bookings, accommodations and/or taxes due to the relevant tax authority. Such disclosed information, inter alia, includes your name, contact information, listing addresses, transaction dates and amounts, tax identification number (where applicable), the amount of taxes received (or due), etc.
3.6. Aggregated data and pseudonymisation.
DIWERENT may share psuedonymised, aggregated or otherwise deidentified information (meaning that such information will not allow the receiving party to identify you by using such information) with the third parties for marketing, analytical, profiling, advertising or other business purposes.
4. Other important information
4.1. Analysis of your communications.
Your communications through the DIWERENT Platform may be reviewed, scanned or analyzed in order to prevent fraud, evaluate risks, comply with applicable laws, improve and develop product and marketing strategies and provide better customer support. We will not share your communications with third parties for marketing purposes.
DIWERENT carries out these activities in its legitimate interest in ensuring DIWERENT’s compliance with applicable laws, preventing fraud and spam, providing safe environment of the Platform, and improving overall performance of the Platform and provided services.
5. Google Analytics
We use Google Analytics, a web analysis service of Google Inc. (hereinafter referred to as Google) on DIWERENT website. Google Analytics is a web analysis tool with which we analyse the relationship between visitors and our website and the way they interact. In so doing we are able to continuously improve our website services.
The website controller, in order to optimize both the website and its advertising, has an integral interest in processing and analyzing usage by visitors to the website. Data saved by cookies, includes such things as frequency of visits, time of visits, and location of the user.
On behalf of DIWERENT, Google will use the aforementioned information to analyse your usage of the website, to compile reports on the website activities and to provide further services associated with the usage of the website and the Internet towards the website operator.
You can at any time prevent cookies from being stored by Google Analytics by activating a setting in your browser software, but it should be pointed out that in doing so you may impede some of the functionality of the website.
You may also stop the collection of data generated by cookies which relates to your website usage (this includes your IP address) and transmission of such data to Google and the processing of these data by Google, by downloading and installing the browser plug-in, accessed through the following link: https://tools.google.com/dlpage/gaoptout?
For additional information on data protection with regard to Google Analytics please refer to: https://policies.google.com/privacy#infosecurity at Google.
6. Newsletter data
If you choose to subscribe to our newsletter a valid email address is required as well as an acknowledgement that you agree to receive this newsletter. This data is used merely to distribute our newsletter, none of which is passed on to third parties, nor do we collect any additional data.
Any data you submit on the contract form is processed only with your express consent per Art. 6 (1) (a) GDPR. At any time you may withdraw your consent to the storage of your email address, including its use for sending you our newsletter, by following the ‘unsubscribe’ link within the newsletter page.
Any data processed prior to receiving your request may still be legally processed, and the data you provide at the time of subscribing to the newsletter will be used to distribute the newsletter until such time as you choose to cancel your subscription, at which time this data will be deleted. Any data stored for other purposes will remain unaffected.
What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Platform or a third-party to recognize you and make your next visit easier and the Platform more useful to you.
When you use and access the Platform, we may place a number of cookies files in your web browser.
- your ID;
- your authentication token;
- your chosen currency.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Platform, deliver advertisements on and through the Platform, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
8. Plugins and tools
The DIWERENT Platform uses plugins from YouTube, a service owned and run by Google. The operator of the service is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.
The Platform will establish connection to the YouTube servers upon your visit at any of our pages that feature a YouTube plug-in. YouTube will receive information about the Platform page that you have visited.
If you’re logged in to your YouTube account, YouTube may collect certain information from you. Such collection of your information and its further handling is regulated by the relevant policy of YouTube which can be found at https://www.google.de/intl/de/policies/privacy. You can prevent this by logging out of your YouTube account before visiting the DIWERENT Platform.
YouTube is used to help make the Platform appealing. This constitutes a justified interest as defined in Art. 6 (1) (f) GDPR.
Google Web Fonts
The DIWERENT Platform uses web fonts provided by Google to ensure correct representation of fonts. When you first open any page of the Platform your browser will automatically download web fonts into your browser cache directly from Google servers. If your browser does not support or is unable to download web fonts, a standard font will be used instead.
Google thus becomes aware that you have visited a certain page of the DIWERENT Platform from your IP address. We use Google Web fonts in the interest of a uniform and attractive presentation of the Platform. This constitutes a justified interest as defined in Art. 6 (1) (f) GDPR.
Google’s policies regarding handling user data can be found at
https://developers.google.com/fonts/faq and at https://www.google.com/policies/privacy/.
DIWERENT uses the Google Maps map service via an application programming interface (API). It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Using Google Maps requires saving your IP address, which is transmitted to a Google server located in the US and stored there. DIWERENT does not control, supervise or respond to such data transfer.
DIWERENT uses Google Maps in order to make the Platform appealing and to facilitate the location of the Properties listed therein. This constitutes a justified interest as defined in Art. 6 (1) (f) GDPR.
Google’s policies regarding handling user data can be found in the data protection declaration of Google at https://policies.google.com/privacy.
DIWERENT uses Zendesk services provided by Zendesk, Inc., 1019 Market Street San Francisco, CA 94103, United States in order to facilitate your communications with DIWERENT.
Your contact information, such as your contact phone number, e-mail address and other information indicated by you upon sending a message to DIWERENT using any web recourses such as social networks, feedback forms or e-mail communications, will be collected by Zendesk and sent to DIWERENT.
Zendesk’s privacy and data protection policies can be found at https://www.zendesk.com/company/customers-partners/privacy-policy/
DIWERENT measures the effectiveness of individual ads, special offers and other promotional features by using Google's AdWords conversion tracking services. It is done by setting a cookie as soon as you click on a Google ad. This cookie is not used to identify your personality, instead it allows DIWERENT to track whether you return to the page associated with the promotional material that you previously clicked on within the cookie’s period of validity, which is about 30 days.
Google Dynamic Remarketing
DIWERENT uses Google Dynamic Remarketing to link the advertising audiences created with Google Dynamic Remarketing with the cross-device features of Google AdWords and Google DoubleClick. In other words, we use this feature to customize and personalize our ads shown to you on a certain device (for example, a smartphone) based on analysis of your interests as well as your previous usage of and behavior on other devices or kinds of devices (such as a tablet or a laptop).
In order to do so, Google, with your duly received consent, links your web and app browsing history together in your Google account. This allows Google to show you the same or similar personalized ads on any device you use to log in to your Google account.
Google Analytics does this by collecting Google IDs of users who get linked to our Google Analytics data. These IDs are used to determine and form the audiences for cross-device targeted marketing.
If you don’t want Google to show you cross-device commercials you are free to turn off personalized advertising in your Google account’s settings.
DIWERENT uses Google AdSense to show you targeted advertising materials that may be interesting for you. Google does this by collecting, sorting and analyzing information received from web beacons and cookies. This information may be as well transferred to third parties. To learn more about transferring of this information to third parties please visit https://support.google.com/dfp_sb/answer/94149).
If you don’t want Google to show you interest-based advertising materials you are free to turn off personalized advertising in your Google account’s settings.
DIWERENT uses a tool called Mouseflow to monitor user behavior across the DIWERENT platform. This monitoring is performed solely for the purpose of client usability and conversion analysis of the platform and further improvement of user experience.
Mouseflow allows recording and replaying actions you take on our website including clicks, taps, scrolls, keystrokes and other meta data. It can show DIWERENT which pages of the website you browse and what elements you interact with including forms that you fill in. Mouseflow cannot identify you personally, but it can be used to gather and show us certain information about you, such as your approximate location and IP-address, as well as information about the device and browser you use to access the DIWERENT platform. We do not use Mouseflow to collect your passwords and/or any of your payment information.
Additional information about how Mouseflow ensures protection of EU residents’ personal data can be found here: https://mouseflow.com/privacy-shield/
You can opt-out from being tracked by Mouseflow here: https://mouseflow.com/opt-out/
9. Linking third party accounts.
If you sign up for or log in to DIWERENT through a third party social networking services like Facebook or Google, you authorize us to collect your authentication information, such as your username and other information about your account with the third party social networking service, including the following information:
Your information from the linked third-party accounts is only collected by DIWERENT to the minimal extent necessary in order to ensure that any agreements or arrangements between you and DIWERENT are performed or executed in a proper way, or to ensure DIWERENT’s compliance with applicable laws, or where you have given DIWERENT your consent for the same.
10. Your choices.
10.1 Managing your information.
You can access, update, delete and correct most of your basic personal information held by DIWERENT by logging into your DIWERENT account and reviewing and adjusting your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by DIWERENT. In some cases, and where permitted by law, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested by you. It is your responsibility to keep your personal information up-to-date. Where permitted by applicable law, you may also request rectification of your personal information.
10.2 Account cancellation and data retention.
Your information is retained by DIWERENT for as long as it is necessary to provide you with access to the DIWERENT Platform, or for as long as you keep your account active. If you want us to cease using your information (and subsequently lose your access to the DIWERENT platform and its services) you may deactivate your Account or request us to erase your personal information. In this case please, however, not that:
10.3 Data portability.
You may be entitled under applicable laws in certain jurisdictions to ask for a copy of your personal data, which we hold based on the consent you have given or as fulfilment of contracts, or to request that your personal information be moved to a different service provider.
We will in such cases, with due regard to our legal obligations, provide all information in a formalized and generally used and machine-readable format. In such cases, and in line with our legal obligations, we will provide you or the service provider with information in a structured and commonly used machine-readable format that is able to exchange and make use of information.
Should you require that we transfer your data to an alternative responsible data holder, this can be done only to the extent that this is technically possible.
10.4 Right to restrict processing.
In the event that you believe that the DIWERENT website holds inaccurate data about you, and compliant with applicable laws, you may ask DIWERENT to restrict, for a temporary period, our use of your data for a limited period of time, until the extraordinary circumstances that prompted your objections no longer apply.
10.5 Right to object to processing.
You may be entitled in some jurisdictions and under applicable laws to require DIWERENT to refrain from processing your personal information for specific and particular purposes, especially in the realm of profiling or marketing. This includes your right to demand that we stop using any automated decision-making regarding your personal information.
10.6 Exercising rights and lodging complaints.
11. Payment service providers
Any payments made with a credit card will be processed through the payment service Stripe. In order to process your payment, we will share your information provided during the ordering process and the information about your order (your name, address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number) to the service provider. DIWERENT does not control, supervise or respond to how the service provider uses, stores or processes your payment data. This information can be found in the service provider’s privacy statement at https://stripe.com/us/privacy.
12. Storage, transfer and processing
Your information collected through the DIWERENT Platform may be stored and processed in Europe, Singapore, US or any other country in which DIWERENT or its subsidiaries, affiliates or service providers have their place of operation. DIWERENT may transfer information collected from you to its subsidiaries, affiliates or service providers located in different parts of the world and subject to different laws and jurisdictions. DIWERENT aims to ensure maximum protection of your personal information and therefore we choose to work with partners, service providers and other third parties to whom we may transfer your personal information based on the requirement that they provide an adequate level of protection of your personal data as determined by the PDPA and, where applicable, the European General Data Protection Regulation (GDPR).
13. How we protect your information.
DIWERENT aims to ensure maximum protection of your personal information, but we cannot guarantee security of any information you share with DIWERENT or warrant that your information transmitted to the DIWERENT Platform is secure from being accessed, disclosed, or otherwise intervened to by breach of any of our industry standard physical, technical or managerial safeguards.
Sensitive information that you transmit to or through DIWERENT (such as your login information or payment details) will be encrypted using secure socket layer technology (SSL). This cannot, however, provide a 100% guarantee of safety of your transmissions over the Internet. We encourage you to diligent while transmitting, uploading, publishing or otherwise sharing your information through the Internet and, particularly, the Platform.
Any question about the Platform’s security can be addressed to us at email@example.com.
13.1 Encrypted payments on the Platform
DIWERENT may require your payment information in order to provide you certain services or facilitate your agreements or arrangements made through the Platform. Payment transactions made with commonly used means of payment like Visa/MasterCard debit or credit cards are only made via encrypted SSL or transport layer security (TLS) connections. You can know that you are using an encrypted connection whenever a lock icon shows up in your browser address line, and the page address changes from http://” to https://. This means that no third party can read your payment details submitted through the encrypted page.
13.2 Data transferred when signing up for services and digital content
DIWERENT may process your data in order to fulfill a contract with made with you or for measures preliminary to such contract. However, any personal data that we transmit to third parties is limited to the extent required to fulfill the terms of your contract with us. For example, we transmit such data to banks or financial organizations in order to process your payments according to agreements or arrangements made between you and DIWERENT. We will not transmit your data for any other purpose without your express permission and will not share it with third parties for advertising purposes without your express consent.
You may also email us at: firstname.lastname@example.org