Privacy Policy

Last Updated: October 30, 2020

We are a community built on trust. A fundamental part of earning that trust means being clear about how we use your information and protect your human right to privacy. This Privacy Policy describes how Igniv Ltd. and its affiliates (“we,” “us,” or “Igniv”), process personal information that we collect through the Igniv Platform. Depending on where you live and what you are doing on the Igniv Platform, the supplemental privacy pages listed below may apply to you.

1. DEFINITIONS

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service.

2. PERSONAL INFORMATION WE COLLECT

2.1 Information needed to use the Igniv Platform.

We collect personal information about you when you use the Igniv Platform. Without it, we may not be able to provide you with all services requested. This information includes: Contact Information, Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use. Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by the laws of England & Wales), your ID number or other verification information, bank account or payment account information. 2.2 Information you choose to give us. You can choose to provide us with additional personal information. This information may include: Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible. Address Book Contact Information. Address book contacts you import or enter manually. Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it.

2.3 Information Automatically Collected by Using the Igniv Platform and our Payment Services. When you use the Igniv Platform and Payment Services, we automatically collect personal information. This information may include:

Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions. Usage Information. Such as the pages or content you view, searches for Listings and other actions on the Igniv Platform.

Log Data and Device Information. Such as details about how you’ve used the Igniv Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Igniv Platform. We may collect this information even if you haven’t created an Igniv account or logged in. Cookies and Similar Technologies Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

2.4 Personal Information We Collect from Third Parties. We collect personal information from other sources, such as:.

Third-Party Services. If you link, connect, or login to the Igniv Platform with a third party service (e.g. Google, Facebook, WhatsApp), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorised by you via your privacy settings at that service. Other Sources. To the extent permitted by law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Igniv Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.

3. HOW WE USE INFORMATION WE COLLECT

3.1 Provide, Improve, and Develop the Igniv Platform. We use personal information to: enable you to access the Igniv Platform and make and receive payments, enable you to communicate with other Members, perform analytics, debug and conduct research, provide customer service, send you messages, updates, security alerts, and account notifications, if you provide us with your contacts’ information such as your friends or co-travellers, we may process this information: (i) to facilitate your referral invitations, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorise, personalise and customise your experience based on your interactions with the Igniv Platform, your search and booking history, your profile information and preferences, and other content you submit, and enable your use of our enterprise products.

3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to: detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,

conduct security investigations and risk assessments, verify or authenticate information provided by you, conduct checks against databases and other information sources, including background or police checks, resolve disputes with our Members, enforce our agreements with third parties, comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5) in connection with the activities above, we may conduct profiling based on your interactions with the Igniv Platform, your profile information and other content you submit to Igniv, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Igniv Platform if such processes detect activity that we think poses a safety or other risk to Igniv, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us via the Contact Information section below.

3.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing. We may use personal information to:

send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,

personalise, measure, and improve our advertising,

administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Igniv or its third-party partners,

analyse characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and

invite you to events and relevant opportunities.


3.4 Provide Payment services. Personal information is used to enable or authorise third parties to use Payment Services:

Detect and prevent money laundering, fraud, abuse, security incidents.

Conduct security investigations and risk assessments.

Comply with legal obligations (such as anti-money laundering regulations)

With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

Provide and improve the Payment Services.


4. SHARING & DISCLOSURE

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorising a third-party application or website to access your Igniv account or participating in promotional activities by Igniv partners or third parties.

We may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Igniv or otherwise promote our products and services.

4.2 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

Your public profile page, which includes your profile photo, first name, description, and city.

Content in a community or discussion forum, blog or social media post.


We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms and apps.

Information you share publicly on the Igniv Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

4.3 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.

We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Igniv, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to protect the rights, property or personal safety of Igniv, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Igniv, our Members, or expose Igniv to a claim of obstruction of justice.

4.4 Service Providers.

We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Igniv Services through third-party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Igniv’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

4.5 Business Transfers.

If Igniv undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5. OTHER IMPORTANT INFORMATION

5.1 Analysing your Communications.

We may review, scan, or analyse your communications on the Igniv Platform for reasons outlined in the “How We Use Information We Collect” section of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your messaging communications to send third-party marketing messages to you and we will not sell reviews or analyses of these communications.

5.2 Linking Third-Party Accounts.

You can link your Igniv account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

some of the information provided to us from linking accounts may be published on your public profile,

your activities on the Igniv Platform may be displayed to your Friends on the Igniv Platform and/or that third-party service,

a link to your public profile on that third-party service may be included in your Igniv public profile,

other Igniv users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,

other Igniv 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 service,

information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and

publication and display of information that you provide to the Igniv Platform through this linkage is subject to your settings and authorisations on the Igniv Platform and the third-party service.


5.3 Third-Party Partners & Integrations.

Parts of Igniv may link to third-party services, not owned or controlled by Igniv, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of UseGoogle Privacy Policy (see here for more information on how Google uses information), and Citi Privacy Policy. Igniv does not own or control these third parties and when you interact with them you are providing your information to them.

6. YOUR RIGHTS

You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.


6.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Igniv Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

6.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

6.3 Data Erasure.

In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:

We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend an Igniv Account for fraud or safety reasons, we may retain information from that Igniv Account to prevent that Member from opening a new Igniv Account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Igniv and Igniv Payments may keep information for tax, legal reporting and auditing obligations.

Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Igniv, even after your Igniv Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.


7. SECURITY

While no organisation can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration.

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Igniv Platform will be subject to the revised Privacy Policy.

9. CONTACT INFORMATION AND RESPONSIBLE Igniv ENTITIES

For questions or complaints about this Privacy Policy or Igniv’s handling of personal information contact Igniv Ltd., Legal Privacy, International House, 12 Constance Street, London, E16 2DQ, UK.