Privacy Policy
Last Updated: June 30, 2016
MOORINGO PRIVACY POLICY Mooringo (hereinafter referred to as “Mooringo”, “we”, “us” or “our”) operates a platform and a market place that connect hosts who have berths to rent with guests seeking to rent such berths, 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 process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform or Services to you, and you should stop accessing the Platform and deactivate your Mooringo Account.
DEFINITIONS
Where the definition of a term does not appear in this Privacy Policy (such as “Listing”, “Berth”, “Content,” “Services” etc.), it shall be given its definition as outlined in our Terms of Service. “Affiliates” means companies related by common ownership or control. They can be financial and non-financial companies. “Data Controller” means Mooringo, the company responsible for the use and processing of Personal Information. “Third Parties” means companies or persons not related by common ownership or control (i.e. non-affiliates) or other unrelated individuals. Third Parties can be financial and non-financial companies, or persons other than you and Mooringo. “Personal Information” means information (which may include sensitive 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.
WHAT TYPES OF INFORMATION DOES MOORINGO GATHER ABOUT ITS USERS?
Information that you give us
We receive, store and process information, including Personal Information, that you make available to us when accessing or using our Platform and Services. Examples include when you:
- fill in any form on the Platform, such as when you register or update the details of your user account, or when you supplyID and other verification information;
- access or use the Platform, such as to search for or post Berths, make bookings, pay for Berths, book or pay for any associated services that may be available (such as but not limited to electricity or water), post comments or reviews, or communicate with other users;
- communicate with Mooringo; and
- share information with another Member.
Information we get from your use of our Platform
We also receive, store and process information, possibly including Personal Information, when you access or use our Platform and Services, including but not limited to:
- Mobile Data
When you use certain features of the Platform, in particular our mobile applications we may receive, store and process different types of information about your location, including general information (e.g. IP address, 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 Mooringo or logged in to your Mooringo 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, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
- Cookies and other Tracking Technologies
Mooringo uses cookies and other similar technologies, such as mobile application and other device identifiers, on the Platform. We may also allow our business partners to use their cookies and other tracking technologies on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to us and to our business partners. While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Mooringo services on Third-Party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements. We may, either directly or through Third Parties we engage to provide services to us, also continue to 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 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 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 or about the Platform – it just will not be tailored to your interests. In addition, if you disable cookies, you may lose some of the features and functionality of using our Platform, Application and Services, as cookies are necessary to track and enhance your use and access. Third Parties may not collect information about users’ online activities on the Platform except as described in this policy.
HOW MOORINGO USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process information about you for the following general purposes:
- to enable you to access and use the Platform;
- to enable you to communicate with other Members, including but not limited to by sending them messages or other information during the booking process;
- to operate, protect, improve and optimize the Platform, Mooringo’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and to provide customer service;
- to help create and maintain a trusted and safer environment on the Platform and Services, such as detection and prevention of actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms and policies, verifying the location of your listings, verifying any identifications provided by you, and conducting checks against databases and information sources for fraud detection and prevention, risk assessment and harm prevention purposes. In this regard, we may do any or all of the foregoing with or without further notifying you;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing, advertising, and promotional messages and other information that may be of interest to you, including information about Mooringo, our services, or general promotions for partner campaigns and services; and
- 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.
How Mooringo Uses and Processes User Communications
We may, either directly or through Third-Parties we engage to provide services to us, 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 analyze messages for research and product development purposes to help make search, booking and user communications more efficient and effective, as well as to debug, improve and expand 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 Mooringo, in its sole discretion, may, either directly or through Third-Parties we engage to provide services to us, review, scan, analyze, and store your communications, whether done manually or through automated means.
WHEN MOORINGO DISCLOSES OR SHARES YOUR PERSONAL INFORMATION, AND TO WHOM
Your Personal Information may be disclosed 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 or if you post content in a community forum or other features on the Platform that are visible to the general public.
- Your public Listing page will always include some minimum information such as the location of the Berth, your listing description, your calendar availability, your photos, and any additional information you share with other Members. Your public Listing page may also include aggregated demand information (such as number of page views over a period of time). Parts of your public Listing page may be displayed in other parts of the Platform to other Members and/or Third Party platforms for marketing purposes.
- When you submit a booking of a Berth, your full name, and your full phone number, and other Personal Information you agree to pass through to the Host(s) will become visible to the Host(s) of any Listing you Book.
- When a Guest books your Berth, we will disclose some of your Personal Information to the Guest. However, your billing and payout information will never be shared with another user.
- When a Host receives your booking, the Host may elect to use Third-Party services to assist with managing the Berths, such as providing electricity or water. The Host may share information about the Guest with that Third-Party service provider for the purposes of coordinating the stay or managing the Berth, including check-in and check-out dates, Guest name, Guest’s phone number, and the Guest’s email address.
- When a Guest stays at your Berth or when you stay at a Host’s Berth, we may ask you to review the Guest, Host, or the Berth. If you choose to provide a review, your review may be public on the Platform. Likewise, another Member’s review of you as a Guest or Host may be public on the Platform.
- You may link your account on a Third-Party social networking site to your Mooringo 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 Mooringo Account profile;
- your activities on the Platform may be displayed to your Friends on the Platform and/or that Third-Party site;
- a link to your public profile on that Third-arty social networking site may be included in your Mooringo public profile;
- other Mooringo 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 Mooringo 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);
- 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; and
- the publication and display of information that you provide to Mooringo through this linkage is subject to your settings and authorizations on the Platform and the Third-Party site.
- You acknowledge, consent and agree that Mooringo may access, preserve and disclose your account information and Collective Content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary (a) to respond to claims asserted against Mooringo; (b) to comply with legal process; (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 Mooringo, its users or members of the public.
- We will use commercially reasonable efforts to notify users about law enforcement requests for their data unless:
- providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law; or
- we believe that providing notice would (a) be futile, (b) be ineffective, or (c) would create a risk of injury or bodily harm to an individual or group, or (d) create or increase a risk of fraud upon Mooringo’s property, its Members, the Platform, Application, or Services (collectively, “Risk Scenarios”).
- In instances where Mooringo complies with legal requests for user data without notice to the user for the reasons described above, Mooringo will use commercially reasonable efforts to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply.
- We may also publish, disclose and use aggregated information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
HOW TO ACCESS, CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR MOORINGO ACCOUNT
You may review, update, correct or delete the Personal Information in your Mooringo Account. If you would like to correct your information or cancel your Mooringo Account entirely, you can do so by logging in to your Mooringo Account. 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 Mooringo Account is cancelled.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
The Platform will contain links to other websites not owned or controlled by Mooringo. Mooringo 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.
CHANGES TO THIS PRIVACY POLICY
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion.We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you. We will also update the “Last Updated” date at the top of this Privacy Policy. If we let you know of changes 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’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Mooringo Account.
GOT FEEDBACK?
Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at info@mooringo.com.
COOKIE POLICY
Mooringo uses “cookies” in conjunction with the Platform to obtain information. 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.
Mooringo cookies and Third Party cookies
Mooringo may place our 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 our business partners to place 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.
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.
Uses for Mooringo cookies
Mooringo uses cookies and similar tracking technologies for a number of purposes, such as the following:
to enable, facilitate and streamline the functioning of the Platform across different webpages, devices 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.
- for fraud detection and prevention.
Uses for Third-Party cookies Our partners’ cookies are intended to obtain information to help them provide services to Mooringo. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise Mooringo listings or services to you on the Platform and Third-arty websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites 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 or about the Platform – it just will not be tailored to your interests.
Disabling Cookies Most browsers automatically accept cookies, but you can 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 make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email. It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your Mooringo Account.