BBOASIS Privacy Policy
Effective Date: April 17, 2023
I. Introduction
This Privacy Notice explains how BBOASIS, Inc., and each of its subsidiaries (details of which are available by clicking here), (together "BBOASIS" or "we") collects, uses, protects, and shares personal information. As used in this Privacy Notice, "you" refers to an individual who is a user of BBOASIS's products or services including a Host or Guest, actual or prospective supplier, contractor or employee, and/or a member of the public who engages with us. Where you use our services, or your personal data is processed in connection with such services, and we control the purpose for which such personal data is processed, BBOASIS will be the data controller of such information. From time to time, there may be more than one data controller of your information within our group where you have engaged different parts of our broader organization to provide different or jointly delivered services.
This Privacy Notice applies:
to your use of any of our services where we are performing a data controller function;
where you apply to us for a job or work placement;
to your supply of services to us where this involves any personal data; and/or
to any personal information collected from third parties where we are the controller of such information.
This Privacy Notice additionally applies to our website and online services and any other website, mobile app, or other online service created or hosted by us from time to time on which this Privacy Notice appears (together, our "online services") through which we may collect certain details if, for example, you want to subscribe to any publications or newsletters that we may periodically issue. Please note that our online services make use of cookies and similar technologies, as described in more detail in our Cookies Policy. This Privacy Notice does not apply to, and BBOASIS is not responsible for, any third-party websites that may be accessible through links from this website (please see Online services - Links to third-party sites, services, and content below for more information). Please note, our Services are not intended for children under the age of majority in your jurisdiction of residence. If you are under the age of majority in your jurisdiction of residence, do not use or provide any personal information on or through the Services or about yourself to us. If you believe that we might have personal information from or about a child under the age of majority, please contact us.
II. Collection of User Information
"Personal data, Personal Information and, if the context requires, information" is any information that can be used to identify you or that we can link to you. We collect and process your personal information to provide you with an optimal experience possible when you interact with us. The following table describes the type of information we collect, the source of that information, our purposes for using the information, and the third parties with whom we may share the information.
Classification of Data
Categories of Data
Source of Collection
User Data: Data we collect about the individuals who use our services. We associate this data with a unique ID (Host ID or Guest ID) depending on the type of user.
Name, email address, zip code, phone number (including country code), city, government ID, title, affiliated organizations such as professional or employment-related information, uploaded photos, social media handles, website URLs affiliated with the user, communications to and from users (including email and chat feature communications), identity verification information, which may include Social Security Numbers (SSNs) or Social Insurance Numbers (SINs).
Provided by you (Users) and third parties.
Identity verification information: Information collected that can help us verify that users are who they claim to be.
We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers, and addresses as well as information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including for fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. If you object to the use of Stripe for biometric verification, you may contact us to discuss alternative means to verify your identity.
Provided by you (Users) and third parties.
Device and Location Data: Data we collect about the device you are using.
Internet and associated network information, browser type, device type, method of sign-on, device ID information, IP address.
Devices.
Platform Activity Data: Information we collect about how you interact with the BBOASIS Platform.
Access date/time, pages viewed, searches made, messages sent, inquiries made, requests made, bookings made, reviews written, boards created, analytics data, error logs.
Users and devices.
Cookies and Similar Data: BBOASIS's website uses cookies, pixels, and other technologies to make the website work properly and to provide the most relevant services to our site visitors.
Cookies send information back to the originating website on each subsequent visit or to another website that recognizes that cookie to develop a record of the user's online activity.
BBOASIS and third parties.
Information about Spaces: Information associated with the spaces listed on our service, which may be associated with a particular individual but typically is associated with a business. We assign a Space ID to unique spaces as well as a Listing ID to unique listings.
Address (street address, city, state, province, zip, postal code, country, metropolitan area), latitude and longitude of space, time zone, venue capacity, onsite contact information, space entry instructions, Wi-Fi access instructions.
Users and third parties.
Booking Information: Information related to a particular Booking. We assign Booking IDs to each unique Booking.
Start/End date, start/end time, Booking details (services descriptions, event description, attendee count, prices, taxes, fees), communications regarding Booking.
Users.
Vendor Information: Information we collect about vendors who provide services via our Services.
Vendor email, services description, locations, contact information, website, survey responses, vendor questionnaire responses.
Vendors.
Survey/Feedback Information: We collect information when you fill out a form, provide feedback, or otherwise communicate with us.
Survey question responses, feedback, email correspondence.
Users.
Contract Information: We collect information related to the agreements signed between users.
Contracts signed, signatures (including electronic signatures), affiliate information, contract terms, and other information.
Users, vendors, and third parties.
Sensory Information: Audio data, such as a recording of your voice when you contact us via Support.
Your voice, recordings of support phone calls, calls connecting you with other users.
Users.
Payment Data: We collect information about the means by which you submit or receive payment through our platform.
Credit card information, bank account information.
Users and third parties.
Other Data: We collect additional information from individuals depending on how they use our Services.
Calendar information (if access is provided), Space Wi-Fi information, miscellaneous communication information, information related to Events, Bookings, Spaces, or Users (including guest lists, diet restrictions, physical restrictions, or other information).
Users, vendors, and third parties.
User Interaction/Dispute Resolution: We collect information related to the interactions between our users and other users or third parties. Sometimes this is to facilitate communications between individuals, to resolve disputes, or for other business purposes compatible with the reason for collection.
Information provided in relation to our business purposes.
Users, vendors, and third parties.
Background Check Information: We may conduct background checks on various individuals as part of our efforts to ensure the safety and security of users on the site.
Information related to background checks.
Background check service providers.
Employment History Data: reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability, and criminal record checks.
Information provided in relation to a job or work placement with BBOASIS.
Job application, background check service providers.
III. Legal Basis for Usage of Personal Data
Where we intend to use your personal data, we rely on the following legal grounds:
Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, this could be any form of commercial contract to which we are both a party, or if you are going to work for us, an employment contract, or if you are a Host and you make Spaces available on the Platform or where you are a Guest and you make a booking on the Platform, and where we respond to your requests and provide you with services in accordance with our BBOASIS Services Agreement (“BSA”) or other applicable terms of business agreed with you or with your employing organization.
Legitimate interests: Where we consider the use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own or a third party’s legitimate purpose, we may use your personal data, which may include:
for our own direct marketing or continued communication, subject to your express consent if required in your country of residence;
the prevention of fraud; our own internal administrative purposes; personalization of the service(s) we provide to you;
ensuring network and information security, including preventing unauthorized access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
reporting possible criminal acts or threats to public security to a competent authority.
Compliance with a legal obligation: We may be required to process your information due to legal requirements, including employment laws, tax laws, and other regulatory provisions applicable to BBOASIS.
Consent: You may be asked to provide your consent in connection with certain services that we offer, for example, in respect of any processing of your personal data for our marketing purposes where you or your employing organization is not a client of BBOASIS, or in respect of certain special categories of personal data such as your health or racial background for which we are legally obliged to gain your consent due to the sensitive nature of such information and the circumstances in which it is gathered or transferred. Where we are reliant upon your consent, you may withdraw this at any time by contacting us; however, please note that we will no longer be able to provide you with the products or services that rely on having your consent.
IV. Our Operational and Commercial Purposes
Depending upon the circumstances in which we gather your personal data, we may use your information to provide you with services and information or for any of the following purposes:
to provide you with BBOASIS’s services that you or your employing organization request;
accepting, coordinating, managing, and processing Listings and Bookings;
facilitating purchase transactions for goods and services;
providing top-level customer support, accommodations, personalized services, and amenities;
to respond to your inquiries and maintain and develop our relationship with you;
engaging in quality control to improve our offerings to you;
facilitating communications between parties;
to engage in content-based or interest-based advertising,
to provide you on an ongoing basis with information and services, including relevant marketing communications related to BBOASIS and other information or materials that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us;
to evaluate, recruit, and hire personnel;
ensuring the safety and security of our users, our staff, and all other persons visiting our platform or the properties listed on it, including verifying your identity;
to prevent, detect, and investigate fraud, cyber incidents, or other illegal activity;
communicating with you and others in relation to your use of our services, including providing legal updates;
administering our record-keeping for legal, tax, and operational purposes;
exploring new and unique ways to provide products and services; and
doing our best to fulfill your requests.
Our commercial purposes are to advance our commercial interests, including advertising and marketing. To learn more about how your personal information is processed for marketing and advertising, please see Your Marketing and Ad Choices below.
We may not be able to do some or all of these things without your personal data.
If at any time we intend to change the purpose for which we hold your personal data, for example, to offer you a complimentary service that we may provide in the future, we will give you prior information about that new purpose so you are aware of this.
V. Disclosures of Your Personal Information
In order to provide you with our service and fulfill our business and commercial purposes, we may disclose your personal information to the different entities and subsidiaries within BBOASIS's group for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organization with services, provided in all instances that such processing is consistent with the legal basis for usage of personal data above and applicable law. Information disclosed to facilitate bookings and other interactions between customers and to enable your use of the BBOASIS platform may include demographic information; financial information; government identifiers; protected classification characteristics; transaction history; internet, application, and network activity; location data; sensory (audio data); professional or employment-related information; and inferences about you.
Publicly Posted Information: Some user information is posted publicly on the platform and is visible to others. This may include profile information, information related to a Space or Listing, reviews, ratings, and other feedback, reviews of Guests completing Bookings, reviews of attendees that have attended an event organized by Guests, and other information that a user submits to be posted. Precise location information is not publicly posted.
Sharing Between Users: Our Services are designed to connect users and to facilitate interaction between them. We also disclose your personal information to any agents or third parties to whom you authorize us to disclose it, including the operators, managers, agents, or other parties associated with an Event or when you agree to a Booking. This sharing is necessary to ensure the performance of the contract between you and BBOASIS, and/or you and a third party.
Our Service Providers: We may share your information with our trusted third-party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors, payment processors, insurance providers and third-party administrators, dispute resolution providers, advertising providers, governmental entities, social networks, background verification providers, and other users. When appropriate or required by applicable law, we will put in place appropriate contracts containing standard data protection clauses to protect that information and the rights of individuals.
Other Disclosures: In addition to the foregoing, we may disclose personal information in the following circumstances:
If you have consented to us sharing your personal information in this way;
We deem it reasonably necessary to provide you with the services that you have required at any particular time;
Such sharing is to law enforcement bodies or other governmental authorities;
Such sharing is in order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, governmental, or local authorities;
To exercise and defend legal or payment-related claims;
When such disclosure is necessary to protect the rights and freedoms of other individuals, property, or the safety of BBOASIS, BBOASIS employees, our clients, or others;
As part of a prospective or completed merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of BBOASIS; and
In any other manner permitted by law, including engaging in protected speech.
Third-Party Links: Links to websites that are not operated by or for us ("Third Party Sites") are provided solely as a convenience to you. If you use these links, you will leave our website. This Privacy Notice does not apply to Third Party Sites. We have not reviewed the Third-Party Sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.
Building Management and Owners: We may disclose personal information of Hosts and Guests such as booking information and information related to compliance with applicable laws and property management agreements with landlords, management companies, and/or property owners to facilitate the Host Services. For example, Guest Booking and personal information, including Guest contact information, may be shared with the owner/management, staff, reception, or caretaker of the building, complex, or community where a Host lives and/or the listing is located, to facilitate Host Services, compliance with applicable laws, security, billing, and other services.
Any third parties that we may share your data with are obliged to keep your details secure and to use them only to fulfill the service they provide you on BBOASIS's behalf. When such third parties no longer need your personal data to fulfill this service, they will dispose of such details following BBOASIS's procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
We may share information that does not reasonably identify you or your organization as permitted by applicable law.
VI. Retention
We retain the information we collect for no longer than is reasonably necessary to fulfill the purposes for which such data was originally collected in accordance with our internal data retention policies or to comply with our legal and regulatory obligations.
A maintained copy of our retention policy is available upon request. Should you wish to review our retention policy, please contact us.
VII. Security
We are committed to protecting the security of any personal information you provide. We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.
All financial information you provide, such as credit card data, will generally be transferred over a Secured Socket Layer (SSL) connection (provided that it is supported or enabled on your browser). Despite these protections, any information submitted over the Internet could be intercepted or otherwise corrupted during transmission, and we cannot guarantee the complete security of any data submitted over the Internet. Sensitive personal information is stored on servers or locations protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. The servers are under our control at all times but may be hosted, managed, or otherwise maintained by third-party service providers with whom we contract. These third-party service providers have no right to use or access this data other than in performing their services for us.
All employees, officers, or contractors of BBOASIS and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.
While we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such, we cannot guarantee the security of your data transmitted to our online services, which is at your own risk.
If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted, or received by persons other than the intended recipient.
Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorized access, modification, or disclosure.
You may access and change certain information that you submitted during registration (if you have registered at the Site) at any time by providing your username and password. Please keep your password in a safe place and do not provide this information to anyone. We strongly encourage you to check the accuracy of your data regularly as we will use your e-mail, phone number, and home address to communicate with you regarding products or services that you have requested. We will not be liable for any problems or difficulties that arise as a result of your failure to keep your information up to date.
VIII. International Data Transfers
BBOASIS, Inc. operates in the United States and has subsidiaries in various jurisdictions worldwide. As a result, the personal information we collect from you may be processed and stored in the United States and other jurisdictions where we operate. The data protection laws in the United States and those other jurisdictions may differ from the data protection laws in your country of residence.
When we transfer your personal information outside of your jurisdiction, we will take all necessary steps required by law to ensure that your privacy rights continue to be protected. For data transfers outside of the UK / EEA or Australia, we will enter into appropriate data transfer agreements containing the Standard Contractual Clauses, as amended from time to time.
IX. Your Marketing and Ad Choices
BBOASIS advertises and markets its services in various ways. We may use cookies and related technologies to recognize you and collect information about your activity on our website. For detailed information about how we use cookies and your options, please refer to our Cookie Policy, which you can access by clicking here.
X. Information for UK / EEA Users about Your Rights
Under the EU General Data Protection Regulation (GDPR) and the UK GDPR, we have a responsibility to ensure that your personal data is accurate and up to date. If your personal information has changed or if you believe that any information we have collected about you is inaccurate, please contact us to update or correct your information.
You can exercise your rights under the GDPR, including:
Access to the personal data we hold about you
Correction or updates to your personal data
Erasure of your personal data
Portability of personal data you have provided to us in a structured, commonly used, and machine-readable format
Object to or request the restriction of our use of your personal data
To exercise any of these rights, please contact us using the contact details provided at the end of this Privacy Notice. Please note that there may be exceptions or limitations to these rights under applicable data privacy laws, and we may need to verify your identity before processing your request.
If you have concerns about our data processing activities, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK or the relevant supervisory authority in your country of residence.
XI. Information for Australian Users
The definition of personal data in this policy for individuals located in Australia is "information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not."
In accordance with the Australian Privacy Act, we may collect personal data from you only with your express consent, including sensitive personal data or health information, unless otherwise required or permitted by law. If you choose not to provide us with the personal data we request, we may not be able to provide our services or effectively communicate with you.
We may use or disclose personal data in circumstances expressly permitted by the Australian Privacy Act, including where it is necessary to prevent a serious threat to life, health, or safety; to investigate unlawful activity or misconduct; or to assist with the location of a missing person.
Your personal data may be stored physically and electronically in the United States. Some electronic services we use may process data in other countries, but those services are not entitled to access or use the personal data held by us except as required for the delivery of the contracted service. The information published on our website is accessible globally.
If you would like to know if we hold personal data about you or request access, corrections, or deletion of your personal data, please contact us. We may refuse to provide access or delete personal data in certain circumstances as permitted by the Australian Privacy Act.
If you have a privacy complaint, we will respond to let you know how your complaint will be handled. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
XII. Information for Canadian Users
As a Canadian resident, you have the right to access, update, and correct inaccuracies in your personal information that we hold. To exercise these rights, you may contact us using the contact information provided below. We may request certain personal information from you to verify your identity before processing your request.
XIII. California Privacy Rights
If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA). Please refer to our California Consumer Privacy Notice for more detailed information about your rights and our practices.
XIV. Information for Spanish Users
In accordance with the Spanish Constitutional Law 3/2018, Peerspace, Inc. wants to inform you about the protection of personal data and guarantee of digital rights:
The personal information we require from you to provide our services will be processed and stored by us in a confidential and secure manner. This information is used exclusively for purposes related to providing services and maintaining commercial relationships with users. We will not sell this information to third parties for advertising or other purposes without your consent, except when required by a public authority or when the information you provide is considered public information.
You have the right to access, rectify, erase, and portability of your personal data. You also have the right to object to the processing of your personal data and to withdraw your consent at any time. You can exercise these rights by contacting us using the provided addresses.
We take appropriate measures to ensure the security and integrity of the personal information we possess in accordance with applicable regulations.
XV. Children's Policy
Our website and services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18. If we receive personal information that we discover was provided by a child under the age of 18, we will promptly delete such information. Parents are encouraged to supervise their children's online activities and provide a child-friendly online environment.
XVI. Agreement and Changes
By submitting your personal information through our website, you agree to the collection and use of your personal information as described in this Privacy Notice. If you do not agree, please do not provide any personal information to us.
We may update this Privacy Notice from time to time to reflect changes in our data collection and privacy practices. We will indicate any material changes by prominently posting and/or communicating the updated Privacy Notice. Information collected under previous versions of our Privacy Notice will then become subject to the terms of the updated Privacy Notice.
XVII. Contact Information
If you have any questions or comments about our privacy practices or this Privacy Notice, please contact us at the following email address: privacy@bboasis.com.
CALIFORNIA CONSUMER PRIVACY POLICY
Last Updated: July 6, 2023
The purpose of this California Consumer Privacy Policy is to explain our data collection and privacy practices when you use our services. Please read this policy carefully to understand our practices regarding your personal information. If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with certain additional privacy rights related to the personal information we collect about you.
