RAKUTEN CHW STAY PRIVACY POLICY

Last Updated: June 29, 2020
CONTENTS
- What This Privacy Policy Covers
- Collection of Information
- Use of Information
- Sharing of Information
- Your California Privacy Rights
-Additional Notices
- Retention
- Information Security
Changes to the Privacy Policy
Contact Us
1.WHAT THIS PRIVACY POLICY COVERS
This website, located at https://www.chw-stay.com/ (the “Site”), pertains to Rakuten CHW Stay (“CHW Stay,” “we” or “us”) a business unit of Rakuten USA, Inc. d/b/a Rakuten Americas (“Rakuten Americas”), part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten, Inc., based in Tokyo, Japan ( collectively “Rakuten Group”).This Privacy Policy explains how CHW Stay, which provides private corporate housing solutions, collects, uses, and discloses information about you when you access or use our Site, book accommodations through the Site (“Services”), or otherwise communicate with us about the Services or Site.
Please note that the Site and Services are intended only for employees of Rakuten Group and members of Rakuten Americas’ business incubation platform, RakuNest.
2.COLLECTION OF INFORMATION
Types of Information We May Collect
When you visit our Site or use our Services, we may collect the following types of information about you:
  • Identifiers, such as your name, username, address, email address, IP address, account information, unique online identifiers, driver’s license or government ID information, as well as the names and addresses of anyone staying with you
  • Additional Customer Records Information, such as your signature, your image which contains your physical characteristics or description, your telephone number, and/or your payment information (for which you will be redirected to a payment processing portal hosted by a third-party payment processor who collects payment information and processes payments on our behalf without sharing the credit card information with us).
  • Characteristics of Protected Classifications under California law, such as your gender or that of others staying with you
  • Commercial Information, such as records of services or products you requested, obtained, or considered
  • Internet or other network activity information, including online browsing or search history, or information about your interaction with our website

Notice regarding information of minors: Our Site and Services are intended for adults over 16 years of age, and we do not knowingly collect or sell personal information of minors under 16 years of age without affirmative authorization or without affirmative, verifiable consent from a parent for those under age 13.

Sources of Collection
We may collect the above types of information in various ways, as described below:
Information You Provide to Us Directly
We collect information you provide directly to us, such as when you fill out a form, or otherwise submit, send or provide your information to us yourself.
Automatically Collected Information
When you access or use our Site, we use data collection technologies to automatically collect certain information about you from the device you use to access our Site, including:
  • Log and Device Information: We systematically collect standard information related to your access to and use of our Site and the device you used to access the Site, such as the type and version of your browser and operating system, hardware model, mobile network information, access times and dates, pages viewed, the referrer page from which you linked to our Site, and IP address.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers and other third parties) may also use technologies like cookies (small data files related to your Site visit that are stored on your hard drive or in device memory) and web beacons (embedded electronic images that help deliver cookies and detect or measure events) to automatically collect information related to your Site visit.For more information on how Cookies are used, please see the Cookie Policy.
3.USE OF INFORMATION
Specifically, we may use the information we collect about you for the purposes listed below:
A.To Provide Our Services
We use your information to provide you with the reservation and accommodation Services. For example, we use your ID information to verify your identity, use your name and booking details to make the accommodation available at the specific time, fulfill your requests, and to keep track of our reservations, and we use your payment details to charge you for the accommodations.
B. To Communicate with You
We may contact you directly or through our service providers regarding our Services in order to deliver transactional or service-related communications.
C.To Provide Customer Service
We use your information in order to respond appropriately to your inquiries, complaints, or requests in relation to the Site or our Services. Further, we may use your email address to communicate service-related messages to you, such asany updates on terms or information applicable to your stay.
D.For Site Improvement
We use your information for our everyday business operations such as auditing, administration of the Site, and analytics. Your information may also be used to improve the content and/or functionality of the Site.
E.For Development and Analytics
We may use your information for our internal business purposes including analytics, capacity planning,and for other strategic purposes.
F.For Network Security Purposes
We may use information to protect against spam, malware, malicious activities, and/or security risks, and to improve and enforce our security measures.
G.To Protect You, Others and Our Business
We may use your information by actively monitoring, investigating, preventing, and mitigating any alleged or actual prohibited, illicit, or illegal activities on the Site or related to CHW Stay properties. We also use your information to investigate, prevent, or mitigate violations of our internal terms, agreements, or policies, or to enforce our agreements with third parties and service providers.
4.SHARING OF INFORMATION
We may share all the categories of collected information about you for business purposes, as follows:
A.Disclosure to Vendors
We may disclose your personal information only as necessary to vendors, service providers, and third parties that perform services for us or on our behalf, including website development, payment processing, facility management, and travel-related services.
B.To Comply with Law
We may disclose your personal information in response to a request for such information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
C.To Protect You, CHW Stay or Others
We may disclose your personal information to relevant authorities if we believe you may be in danger or need to be alerted regarding community or location-based issues, your actions are inconsistent with our user agreements or policies, there are reasonable indications you have violated the law, or to protect the rights, property, and safety of you, CHW Stay, or others.
D.In Connection with a Business Transaction
We may share your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
In addition to the above listed disclosures of personal information, we may also share aggregated or de-identified information that cannot reasonably be used by the recipients to identify you.
5.YOUR CALIFORNIA PRIVACY RIGHTS
Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act of 2018 (“CCPA”)(California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83).If you are a California resident, this section applies to you.
Description of Your Privacy-Related Rights
If you are a California resident who meets the CCPA’s definition of “Consumer,” you are entitled to the following rights:
Right to Know and Access:You have the right to request that we provide certain information to you about our collection and use of your personal information over the past 12 months.Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Access, and Delete below), we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
○sales, identifying the personal information categories that each category of recipient purchased; and
○disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Request Deletion:You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions.Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Right to Opt-Out of Sale of Personal Information:We do not sell your personal information for money, but we may permit our vendors to use tracking technologies to help us and them understand our Site traffic and the use of their technologies to power your Site experience, to enhance your online experience, and customize our offerings in ways that may be deemed a “sale” of personal information under the CCPA. To the extent we or our vendors use such technologies on the Site, we offer an opt-out here: DO NOT SELL MY PERSONAL INFORMATION.
Right to Non-Discrimination:We will not discriminate against you for exercising any of your CCPA rights.Unless otherwise permitted by the CCPA, we will not:
  • deny you goods or services
  • charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
  • provide you a different level or quality of goods or services, or
  • suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
because you request to know, access, or delete your information or opt out of its sale.
How To Exercise Your Rights to Know, Access, and Request Deletion
To exercise your right to know, access, or delete as described above, you may submit a request to us by either:
Calling us at +1 (650) 383-1328
Contacting us by email at this address: email: RUSA-privacy@rakuten.com.
You may only make a request to know or access twice within a 12-month period.
Your request must be verifiable.In order for us to verify your identity, we will need to match certain information that you provide in your request with data that we maintain and have determined to be reliable for the purposes of verification.We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that the you are the consumer whose personal information is the subject of the request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.We may require any agent making a request on your behalf to provide written permission from you to submit a request on your behalf and to verify their identity and authorization to do business in California, or demonstrate that he or she has power of attorney in connection with your request to know, access or delete.
6.ADDITIONAL NOTICES
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes.We do not share your information with third parties for their direct marketing purposes.
California Do Not Track Disclosure
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings.We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.We continue to monitor and review new technologies and will modify this policy accordingly in the event of a change.
Notice regarding information of minors

Our Site and Services are intended for adults over 16 years of age, and we do not knowingly collect or sell personal information of minors under 16 years of age without affirmative authorization or without affirmative, verifiable consent from a parent for those under age 13.

7.RETENTION
We may retain information about you for as long as it is necessary to fulfill the purposes described above in Section 3. Some of your information may be retained in our systems even after you request your information to be deleted in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, otherwise use internally in a lawful manner that is reasonably aligned with the expectations of the consumer or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing.
8.INFORMATION SECURITY
We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.

9.CHANGES TO THE PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage). We encourage you to review the Privacy Policy whenever you access the Site or Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
10.CONTACT US
If you have any questions about this Privacy Policy, please contact us at:
Rakuten USA, Inc., d/b/a Rakuten Americas
RE: CHW Stay
800 Concar Drive,
San Mateo, California, 94402
Email: rusa-privacy@rakuten.com

Tel: +1 (650) 383-1328 

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